In an Ohio case, deciding claims under both Federal FMLA law and Ohio's Civil Rights Act (OCRA), a federal judge rules that an employee's failure to properly notify her employer of her intention to take leave under the FMLA barred her claim. The court also rejected her state-law discrimination claims because she was not "disabled" within the definition of the OCRA statute after she admitted that her eating disorder, bipolar disorder, post-traumatic stress disorder and other disorders did not prevent her from performing her job duties or limit any major life activities. The judge summarily rejected her intentional infliction of emotional distress and invasion of privacy claims because the evidence against the employer failed to meet the burden-of-proof (B/P) requirement (for that intentional tort claim) of conduct that is "so extreme and outrageous as to go beyond all possible bounds of decency."
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