Bodge et al v. Commonwealth of Massachusetts SJC Docket 13567 (2024) involved a dispute between several Massachusetts State Police officers and the Commonwealth of Massachusetts over the interpretation of the state's Paid Family and Medical Leave Act (PFMLA), M.G.L. c. 175M. The plaintiffs filed a lawsuit challenging a state policy that denied the accrual of employment benefits such as seniority, vacation time, sick leave, and length-of-service credit while on paid family and medical leave.
The plaintiffs took leave under the PFMLA in connection with the birth of their children. They argued that during their leave, they should continue to accrue certain benefits, including seniority and vacation and sick time. The Commonwealth, however, had a policy that prevented the accrual of these benefits while employees were on leave, leading the plaintiffs to claim that this policy violated the PFMLA. The court examined sections 2(e) and 2(f) of the PFMLA. Section 2(e) provides that an employee returning from leave should be reinstated to their prior position with the same benefits they had before taking leave. The plaintiffs argued that section 2(f) allowed for the continued accrual of benefits while on leave.
The Supreme Judicial Court affirmed the dismissal of the plaintiffs' claim that they were entitled to accrue benefits during their leave. The court reasoned that the PFMLA does not expressly provide for the accrual of benefits such as vacation and sick time while on leave. It distinguishes between restoring employees to their previous status upon returning from leave and the continued provision of health insurance, but it does not mandate the accrual of other benefits. The court rejected the plaintiffs' argument that section 2(f) allowed for the continued accrual of benefits, finding that this section only protects existing rights and does not grant new rights to accrue benefits during leave. While the PFMLA guarantees employees the right to return to their positions with the same benefits they had prior to leave, it does not require employers to allow the accrual of benefits during the leave itself.
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