In Bonkowski v. Oberg Industries, Inc., (3d Cir. May 22, 2015), the Third Circuit Court of Appeals ruled that an employee who was admitted to the hospital moments after midnight, and who was discharged more than 14 hours later, was not entitled to protection under the Family and Medical Leave Act (FMLA) because he did not meet the “overnight stay” requirement in the FMLA regulations. The court noted that the pre-midnight time spent by the employee in the hospital’s waiting room prior to his admission did not count toward the overnight stay requirement.