Excerpt: A federal appeals court in Philadelphia has ruled that an employee may use a combination of lay and medical testimony to establish that she has a 'serious health condition' under the Family and Medical Leave Act, even though lay testimony alone (her own) would not suffice to establish that such condition resulted in her incapacitation. Schaar v. Lehigh Valley Health Servs. Inc., No. 09-1635 (3d Cir. Mar. 11, 2010).