A Suffolk Superior Court jury awarded former Wayfair employee Mary Boyle approximately $4.7 million after finding in her favor on retaliation claims under the Massachusetts Paid Family and Medical Leave Act (PFMLA) and the Massachusetts Fair Employment Practices Act. The April 27, 2026, verdict appears to be the first plaintiff-side jury verdict to uphold a retaliation claim under the PFMLA.
The case, Boyle v. Wayfair, hinges on when an employee takes protected leave: what happens when an employee’s job, compensation, performance record, or employment status changes while the employee is on leave or soon after returning? Massachusetts law gives employees specific protections during this period, including a statutory presumption of retaliation. Boyle v. Wayfair highlights and supports this presumption and these protections.
The Facts Behind the Verdict
Boyle joined Wayfair as a Senior Manager in April 2019 and moved into a Program Manager role in August 2019. Her performance reviews generally rated her as meeting expectations, although her supervisors identified areas for improvement.
According to the allegations, on September 18, 2020, Boyle’s supervisor told her she needed to find another position because she “just doesn’t fit in.” She was then assigned a labor-intensive project that she alleged could not reasonably be completed by the deadline. Boyle expressed concerns about what she believed was discriminatory treatment. Wayfair investigated her concerns and concluded that discrimination had not occurred.
Boyle was subsequently hospitalized and took PFMLA and FMLA leave beginning in October 2020. Her leave continued through June 2021. While she was away from work, she received the lowest possible performance rating. She also alleged that her year-end bonus was cut by 50%, that she was denied an annual pay increase, and that Wayfair changed her position while she was on leave.
After Boyle returned, additional employment actions were taken which further undermined her position at Wayfair.
What Happened After Boyle Returned From Leave?
Eight days after Boyle returned from PFMLA leave, she was placed on a performance improvement plan. Approximately 10 weeks after her return, Wayfair terminated her employment, citing performance problems.
The timing matters because PFMLA protections generally do not end when an employee walks back into the workplace. Massachusetts law generally affords protections to employees even if they return from PFMLA leave.
That makes the sequence of events in Boyle particularly consequential. The alleged changes to Boyle’s employment began while she was on leave and continued after she returned. They involved several different aspects of her employment: her performance evaluation, compensation, position, performance management, and ultimately her job itself.
A retaliation case may not necessarily turn on a single decision. A series of decisions made by an employer, considered together and in relation to their timing, may become part of the question presented to a court or jury.
How PFMLA Retaliation Protections Work in Massachusetts
The PFMLA contains a specific protection against retaliation. Generally, if an employee experiences a negative change in status, pay, benefits, or other terms and conditions of employment while on PFMLA leave or during the first six months after returning, the change is presumed to be retaliatory.
That presumption is important because it affects how a retaliation claim is assessed.
The six-month period after an employee returns is therefore more than a transition back to work. It is generally part of the statutory protection itself.
Why the Wayfair Verdict Matters for PFMLA Leave
The reported $4.7 million award received the most attention, but the legal import of Boyle goes far beyond the extent of the damages.
The jury found in Boyle’s favor on retaliation claims under both the PFMLA and the Massachusetts Fair Employment Practices Act. The award reportedly included $4 million in punitive damages, $600,000 for emotional distress, and more than $75,000 in back pay. As mentioned, Boyle v. Wayfair appears to be the first plaintiff-side verdict validating a PFMLA retaliation claim.
The verdict should not, however, be interpreted to mean that an employee who experiences an adverse employment decision after taking PFMLA leave will necessarily prevail in a retaliation claim, much less receive a comparable award. Employers may make legitimate employment decisions during the protected period.
The facts alleged in Boyle also show the extent to which context can matter in an employment case. The case involved a progression of employment decisions rather than one isolated action. A performance rating was issued while Boyle was on leave. Her compensation allegedly changed. Her position was altered. She was placed on a performance improvement plan shortly after returning. Her employment then ended roughly 10 weeks later.
From an employee perspective, the case highlights that PFMLA retaliation is not limited to an employer firing someone because they took leave. Changes to pay, benefits, position, performance evaluations, or other terms of employment may also fall within the statute’s protections.
Massachusetts Employment Law After Boyle v. Wayfair
PFMLA litigation is still developing. The statute is newer than many of Massachusetts’ longstanding employment laws, and courts and juries will continue to shape how its retaliation provisions operate in practice.
Boyle does not answer every question about PFMLA retaliation. It does, however, demonstrate that the statute’s retaliation provisions can have substantial consequences when a dispute proceeds to trial. It also directs particular attention to the six months following an employee’s return from leave and on employment decisions made during that period. Employment attorneys and their employee clients may anticipate additional guidance by way of future cases concerning how employers’ stated reasons for employment decisions are evaluated against the timing and circumstances surrounding an employee’s leave.
What the Verdict Means for Massachusetts Employees
For employees who take PFMLA leave, the protections provided by the statute generally continue after the employee returns to work. Boyle shows how those protections may become relevant when an employee’s compensation, performance evaluation, position, working conditions, or employment status changes during the protected period.
The case also clearly outlines why the circumstances surrounding an employment decision can matter as much as the decision itself. When several changes occur in proximity to protected leave, the timing and sequence of those decisions may become central to a retaliation claim.
Boyle v. Wayfair is an important development in Massachusetts employment law, particularly as courts and juries continue to interpret the PFMLA’s retaliation provisions. Employees who believe that their treatment at work may have been affected by taking protected leave should consult an experienced Massachusetts employment attorney to discuss the specific facts and circumstances of their situation.
If you believe you have experienced retaliation during or after PFMLA, contact the attorneys at the Maura Greene Law Group for a confidential consultation, or call us at (617) 936-1580.
The Not So Fine Print:
Every case has its unique facts. Before you take any action, you should contact an employment lawyer and get advice on your own situation. We can’t provide legal advice here, and this isn’t intended as legal advice. It is best, if possible, to establish a relationship with an attorney before a workplace issue turns into a crisis.