Law360, New York ( March 21, 2012, 1:14 PM EDT) -- In Haybarger v. Lawrence County Adult Prob. & Parole, No. 10-3916 (3d Cir. Jan. 31, 2012), the United States Court of Appeals for the Third Circuit recognized, for the first time, that a supervisor of a private employer may be held individually liable for violations of the Family and Medical Leave Act (FMLA), 29 U.S.C. § 2601, et seq....
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