The Seventh Circuit held that expert testimony is not required to prove that an employee is unable to work. More specifically, the record showed that Hansen had exceeded the number of absences that his doctor estimated that Hansen would need on his FMLA certification form for his medical condition. The District Court found that Hansen could not prove his claim because he had no expert evidence to establish that the absences that exceeded that estimate were related to his medical condition. However, the Seventh Circuit held that Hansen did not need to have such expert evidence where his physician was able to testify about his condition and Hansen was able to testify about the reason for those absences.
Furthermore, the Seventh Circuit rejected defendant’s claim that the estimate made by Hansen's doctor in the original medical certification form served as outer limit for the amount of leave that Hansen could take to address his medical condition when taking intermediate leave under FMLA.