A recent case highlights the intersection of FMLA and workers’ compensation laws. Angela Samuel (Samuel) was employed by Progressive Casualty Insurance Co. (Progressive) as a retention specialist and primarily worked out of her home. While on a leave of absence covered by the Family Medical Leave Act (FMLA), Progressive notified Samuel that she needed to submit documentation in support of her FMLA request. Previously, Samuel’s documents in support of her FMLA leave were either never received or misplaced by Progressive.
On a Sunday evening, Samuel hand-delivered the paperwork to an unattended reception desk outside of a human resources department at a building on Progressive’s campus. As she was leaving, she slipped in a stairway and fell onto her right side.