Macfarlan v. Ivy Hill SNF, LLC, ___ F.3d ___ (3d Cir. 2012). “Judicial estoppel is a ‘judge-made doctrine that seeks to prevent a litigant from asserting a position inconsistent with one that [he or she] has previously asserted in the same or in a previous proceeding.’” In this Family Medical Leave Act case, a district judge granted summary judgment against plaintiff based on judicial estoppel. The court found that plaintiff was not permitted to contend that he