Case Explained: DANIEL P. MOOK Plaintiff – v. G. ANDREW HALL Defendant – Appellant and CITY OF MARTINSVILLE, VIRGINIA

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-08-04 The Fourth Circuit vacated the district court’s denial of qualified immunity to Defendant G. Andrew Hall in his individual capacity, holding that it was not clearly established in November 2021 that an employer must provide an employee with an opportunity to cure any inauthenticity of a Family and Medical Leave Act (FMLA) certification before contacting the certifying medical provider for authentication purposes. The court applied the qualified immunity standard, which requires that the right alleged to have been violated be “clearly established” such that every reasonable official would understand their conduct is unlawful. Analyzing 29 C.F.R. § 825.307(a), the court concluded that the regulatory term “deficiencies,” which triggers a seven-day cure period under § 825.305(c), reasonably refers only to incomplete or insufficient certifications and does not clearly encompass issues of authenticity. Consequently, Hall’s interpretation of the regulations was reasonable, and he was entitled to immunity on this basis. The court remanded the case for the district court to address the antecedent legal question of whether qualified immunity is an available defense to interference claims under the FMLA. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.