FMLA Multi-State Employer

I am a multi-state employer in the property managment industry, with apartment complexes across the nation. Each property has their own federal I.D., state I.D., UI I.D., etc. and are considered separate entities. We are the corporate office, from where policies are implemented that apply to these apartment complexes. In addition, paychecks for all properties are generated from our Corporate office. Although we manage these properties, the owner in most cases, only has a small percentage of interest in the ownership of the actual property.

My question is, does FMLA apply to any of the properties that have under 50 employees in a 75 mile radius?


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  • This is my favorite lawyer's answer: it depends. You should consult legal counsel because the issue will revolve around the amount of common control exercised. Because you have the possibility that the entities will be considered to be part of the same business, you need to verify whether that is or is not the case. It's a very fact dependent inquiry that requires research and analysis. Good luck.
  • Hi Susan, thank you for your response. Silly me to think I could receive a quick clear cut answer. I have been applying FMLA, to be on the safe side, until I can get to the bottom of this.