Historical firm record and current-law boundary
Original firm-post publication date: March 2, 2017.
This route preserves a historical firm post about medical information and FMLA leave. The original case discussion and broad legal conclusions are not retained as a current statement about any particular disclosure.
FMLA medical-record rule
The FMLA regulation addresses records and documents relating to certifications, recertifications, and medical histories created for FMLA purposes. It requires covered employers to maintain those materials as confidential medical records in separate files, subject to the regulatory exceptions. The scope of that rule depends on the records and circumstances involved.
ADA medical-information rule
ADA employment rules separately address qualifying medical examinations, disability-related inquiries, and medical information. Their application can depend on the employer, source of information, examination or inquiry, and regulatory exceptions. These are not the same question as every workplace conversation about health.
Historical case status
The historical post discussed Holtrey v. Collier County Board of County Commissioners. The public record reflects a motion-to-dismiss ruling followed by a settlement notice and dismissal; this page does not treat that litigation as a merits decision or a general rule.
Selected current federal sources
- 29 C.F.R. § 825.500 — FMLA recordkeeping
- 29 C.F.R. § 825.220 — FMLA protections
- 29 C.F.R. § 1630.14 — ADA medical examinations and inquiries
- U.S. Department of Labor — FMLA
Scope of this historical record
This page does not provide medical, records, disclosure, reporting, filing, deadline, claim, confidentiality, public-form, remedy, representation, or outcome guidance.
Editorial status: Historical source preserved; current-law context requires further editorial and legal review before any indexing decision.

