Roeder v. Kautz Vineyards, Inc.

CourtDistrict Court, E.D. California
DecidedJune 3, 2025
Docket1:21-cv-01115
StatusUnknown

This text of Roeder v. Kautz Vineyards, Inc. (Roeder v. Kautz Vineyards, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Roeder v. Kautz Vineyards, Inc., (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 Sara Roeder, No. 1:21-cv-01115-KJM-SAB 12 Plaintiff, ORDER 13 v. 14 Kautz Vineyards, Inc., et al., 1S Defendants. 16 17 Sarah Roeder brings this action against Kautz Vineyards, Inc., over the termination of her 18 | employment at Ironstone Vineyards during the COVID-19 pandemic. Roeder alleges Kautz 19 | interfered with her Families First Coronavirus Response Act (FFCRA)/Emergency Family and 20 | Medical Leave Expansion Act (EFMLEA) rights when it fired her. She also alleges she 21 | experienced sexual discrimination and harassment while employed at Kautz and Kautz terminated 22 | her employment in violation of public policy. 23 Kautz moves for summary judgment or, in the alternative summary adjudication, on all of 24 | Roeder’s allegations and asks the court to deny Roeder’s prayer for punitive damages. The court 25 | grants the motion in part and denies in part, as explained below. 26 | ///// 27 | JI 28 | /////

1 I. BACKGROUND 2 Roeder began working at Ironstone Vineyards in June 2019. Kautz Decl. ¶ 3, ECF No. 3 13-4; Henderson Decl. Ex. A (Def.’s Roeder Dep.) at 11–12, ECF No. 13-3.1 By August, Kautz 4 promoted her to tasting room manager. Kautz Decl. ¶ 3. In March 2020, Ironstone closed its 5 tasting room to the public due to the COVID-19 pandemic and furloughed Roeder and other 6 employees. Id. ¶ 6; McLaughlin Decl. ¶ 7, ECF No. 13-5. 7 Possibly on April 20, 2020—Roeder does not remember the date, see Asbill-Bearor Decl. 8 Ex. A (Pl.’s Roeder Dep.) at 6:18–8:8, ECF No. 17-3,—Roeder met with Stephen Kautz, the 9 president of the vineyard and Karen McLaughlin, the human resources manager at the vineyard. 10 Kautz Decl.¶ 7; McLaughlin Decl. ¶ 8. Kautz and McLaughlin asked Roeder about her 11 availability for returning to work at Ironstone. See Kautz Decl. ¶ 7. Roeder, who had children 12 aged 9 and 11 at the time, told McLaughlin and Kautz she was only available on nights and 13 weekends because she had to supervise her children who were attending school at home over 14 Zoom. Pl.’s Roeder Dep. at 8:5–15. She made a request to McLaughlin to provide information 15 on possible leave options. McLaughlin Decl. ¶ 8. The following day, McLaughlin sent Roeder a 16 follow-up email with attachments on leave options if Roeder could not return to work during 17 Ironstone’s operating hours. See McLaughlin Decl. Ex. C. The attachments included information 18 on the FFCRA as well as other leave options. See id. 19 Congress passed the FFCRA in the Spring of 2020 to help Americans with the various 20 challenges the COVID-19 pandemic created. See generally Pub. L. No. 116-127 (2020). One 21 division of the statute, the EFMLEA, allowed eligible employees in 2020 to take leave “because 22 of a qualifying need related to a public health emergency.” 29 U.S.C. § 2612(a)(1)(F). A 23 qualifying need included the “care for the son or daughter under 18 years of age of such employee 24 if the school or place of care has been closed, or the child care provider of such son or daughter is 25 unavailable, due to a public health emergency.” Id. § 2620(a)(2)(A). The first ten days of leave 26 would be unpaid. Id. § 2620(b)(1). After ten unpaid days, the EFMLEA required the employer

1 All page citations are to the top right by the CM/ECF system. 1 to provide paid leave for “an amount that is not less than two-thirds of an employee’s regular rate 2 of pay . . . .” Id. § 2620(b)(2)(A)–(B). The provisions of the EFMLEA became part of the pre- 3 existing Family and Medical Leave Act (FMLA), which grants employees the right to take leave 4 for various reasons. See 29 U.S.C. §§ 2611–2620. Colloquially, seeking leave under the FFCRA 5 also is referred to as seeking “Expanded FMLA” leave. See McLaughlin Decl. Ex. C. 6 To qualify for this leave, the employee needed to provide notice. The EFMLEA required 7 employees, “where the necessity for leave . . . is foreseeable,” to provide “such notice of leave as 8 is practicable.” Id. § 2620(c). The EFMLEA leave provisions incorporated into the FMLA by 9 the FFCRA expired on December 31, 2020. See 29 U.S.C. § 2612(a)(1)(F). 10 Congress gave the Department of Labor (DOL) authority to publish regulations to 11 implement the EFMLEA. See 29 U.S.C. § 2620(a)(3). The DOL’s implementing regulation, 12 published in April 2020 (the April Rule), stated “notice may not be required in advance, and may 13 only be required after the first workday (or portion thereof) for which an Employee takes Paid 14 Sick Leave or Expanded Family and Medical Leave.” 29 C.F.R. § 826.90(b), 85 FR 19326-01, 15 2020 WL 1663275, at *19354 (F.R.). 16 The April Rule also required employees to: 17 [P]rovide the Employer documentation containing the following 18 information prior to taking Paid Sick Leave under the EPSLA2 or 19 Expanded Family and Medical Leave under the EFMLEA: 20 (1) Employee’s name; 21 (2) Date(s) for which leave is requested; 22 (3) Qualifying reason for the leave; and 23 (4) Oral or written statement that the Employee is unable to work 24 because of the qualified reason to leave. 25 29 C.F.R. § 826.100, 85 FR 19326-01, 2020 WL 1663275, at *19355 (F.R.). In August 2020, a 26 district court in the Southern District of New York vacated this notice portion of the April Rule

2 The Emergency Paid Sick Leave Act (EPSLA) constituted Division E of the FFCRA and allowed an employee to take up to two weeks of paid sick leave. See Pub. L. No. 116-127. __________________________. 1 because it held the DOL exceeded its authority by requiring employees to submit documentation 2 to their employer prior to taking leave under the EFMLEA. New York v. U.S. Dep’t of Labor, 477 3 F. Supp. 3d 1, 17–18 (S.D.N.Y. 2020). The district court ruled the provision was “a different and 4 more stringent precondition to leave” and thus was inconsistent with “the statute’s unambiguous 5 notice provisions . . . .” Id. 6 In response, the DOL issued a new temporary regulation (the September Rule). The 7 September Rule required an employee to provide the same documentation as the April Rule but 8 now it was due, “as soon as practicable, which in most cases will be when the Employee provides 9 notice under § 826.90.” 29 C.F.R. § 826.100(a), 85 FR 57677-01, 2020 WL 5531349, at *57691 10 (F.R.). The DOL revised § 826.90(b) to state, “Notice for taking Expanded Family and Medical 11 Leave is required as soon as practicable. If the reason for this leave is foreseeable, it will 12 generally be practicable to provide notice prior to the need to take leave.” 29 C.F.R. § 826.90(b), 13 85 FR 57677-01, 2020 WL 5531349, at *57690–91 (F.R.). 14 The question of notice and leave is at the heart of the dispute between Roeder and 15 Ironstone over her termination on May 14, 2020. Ironstone formalized its reopening plans in 16 early May 2020. See Kautz Decl. ¶ 8; McLaughlin Decl. ¶ 10.

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Roeder v. Kautz Vineyards, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/roeder-v-kautz-vineyards-inc-caed-2025.