Ramadei v. Radiall USA, Inc.

── Ramadei v. Radiall USA, Inc. ── Case No.: 25-587 Court: Court of Appeals for the Second Circuit Date: March 19, 2026 Category: General 25-587-cv Ramadei v. Radiall USA, Inc. UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL. At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 19th day of March, two thousand twenty-six. PRESENT: MICHAEL H. PARK, WILLIAM J. NARDINI, MARIA ARAÚJO KAHN, Circuit Judges. __________________________________________ GARY T. RAMADEI, Plaintiff-Appellee, v. 25-587-cv RADIALL USA, INC., Defendant-Appellant. __________________________________________ FOR PLAINTIFF-APPELLEE: AMANDA M. DEMATTEIS (Joshua R. Goodbaum, Meaghan C. Kirby, on the brief), Garrison, Levin-Epstein, Fitzgerald & Pirrotti, P.C., New Haven, CT. FOR DEFENDANT-APPELLANT: ANDREW BUTZ, Kiernan Trebach LLP, Washington, DC (Christopher Jefford, on the brief, Kiernan Trebach LLP, Boston, MA).  Appeal from a judgment of the United States District Court for the District of Connecticut (Hall, J.). UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgment of the district court is AFFIRMED. Plaintiff-Appellee Gary Ramadei sued his former employer, Defendant-Appellant Radiall USA, Inc., alleging, among other things, that Radiall terminated his employment in retaliation for taking medical leave under the Family and Medical Leave Act (“FMLA”). The district court denied Radiall’s motion for summary judgment as to Ramadei’s FMLA retaliation claim, and the case proceeded to trial in December 2023. The jury returned a verdict for Ramadei, and the court entered final judgment for Ramadei in the amount of $770,006.06 plus post-judgment interest. Radiall filed post-trial motions for a new trial and for judgment as a matter of law in October 2024, which the court denied. 1 On appeal, Radiall argues principally that (1) the district court erred by using the “motivating factor” causation standard rather than the “but for” causation standard for the FMLA retaliation claim, (2) the jury returned an irreconcilably inconsistent verdict, and (3) the court erroneously admitted testimony from two witnesses. We assume the parties’ familiarity with the underlying facts, the procedural history, and the issues on appeal. I. Motivating-Factor Causation Standard Radiall contends the district court committed legal error by using the motivating-factor rather than the but-for causation standard for Ramadei’s FMLA retaliation claim when it denied Radiall’s summary-judgment motion, created the verdict form, and instructed the jury. Our decision in Woods v. START Treatment & Recovery Centers, Inc. held that “a ‘motivating factor’ 1 The district court construed Radiall’s post-trial