The Seventh Circuit recently decided that a former employee’s travel with her terminally ill mother to Las Vegas could be considered protected “family care” leave under the Family and Medical Leave Act (FMLA). In Ballard v. Chicago Park District, the Seventh Circuit affirmed the district court’s denial of the Chicago Park District’s (CPD) motion for summary judgment, reasoning that the FMLA does not limit the provision of protected family care to a particular geographic location. The former employee and her mother did not travel to Las Vegas to receive any medical treatment, but were instead fulfilling the mother’s end-of-life wish to take a family trip to Las Vegas. On this issue, the Seventh Circuit admittedly split from the First and Ninth Circuits to hold that the FMLA does not require an employee’s active participation in his or her family member’s medical treatment to qualify for FMLA.