Telecom Employee Loses Leave Bias Appeal Over Boss’s Criticism

Nov. 25, 2025, 9:39 PM UTC

An Orange Business Services Inc. account manager lacked evidence the company interfered with her right to job-protected leave when she needed time off to care for sick family members, the Second Circuit ruled Tuesday.

The decision highlights that criticism directed at the substantive aspects of an employee’s performance aren’t enough to raise a triable issue of Family and Medical Leave Act interference under the theory that the use of leave was discouraged.

Patricia Haran didn’t dispute that her supervisor at the international telecommunications company granted all her requests to take time off to care for her daughter, who’d been diagnosed ...

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