Justia U.S. 11th Circuit Court of Appeals Opinion Summaries

Plaintiff worked as a hospital nurse for St. Vincent’s Health System. After St. Vincent’s fired her, Plaintiff sued, alleging race discrimination and retaliation under Title VII and 42 U.S.C. 1981. The district court granted summary judgment for St. Vincent’s, and Plaintiff appealed.On appeal, Plaintiff claimed she presented sufficient evidence to survive summary judgment as to all her claims. She also claimed that the district court erred in applying the McDonnell Douglas framework to a “mixed-motive” retaliation claim.The Eleventh Circuit held that Plaintiff's hostile work environment claim failed because there was no evidence of severe or pervasive harassment; Bostock v. Clayton County, 140 S. Ct. 1731 (2020) did nothing to undermine the application of McDonnell Douglas to retaliation claims because but for causation still applies; Plainitff's retaliation claim cannot survive; and disparate-treatment claim fails because there is no evidence that race played a role in her termination. View "Cynthia Diane Yelling v. St. Vincent's Health System" on Justia Law

Plaintiff was hired as the Superintendent of Dothan City Schools in Dothan, Alabama. The employment contract stated Plaintiff could only be terminated for cause. Furthermore, the contract stated that the termination would not be effective until the Board provided Plaintiff with a statement of the cause for termination and allowed her an opportunity for a hearing. Lastly, the employment contract provided that Plainitff could resign with or without cause as long as she gave at least 120 days notice in writing of her resignation to the Board. Six days after Plaintiff’s intent to resign was sent, Plaintiff alleges that the Board voted to terminate Plaintiff’s contract. She brought claims for deprivation of due process and the Fifth and Fourteenth Amendments, conspiracy to violate civil rights in violation of 42 U.S.C. Section 1985, and breach of contract. The district court dismissed Plaintiff’s claims with prejudice.   The Eleventh Circuit reversed the district court’s denial of Plaintiff’s due process claims and affirmed the district court’s denial of Plaintiff’s conspiracy and breach of contract claims. The court explained that instead of construing all ambiguities in Plaintiff’s favor, the district court used the minutes to recharacterize the allegations within Plaintiff’s complaint. When taking the factual allegations in Plaintiff’s complaint as true, there is a plausible claim for relief. In paragraph 18 of the complaint, Plaintiff’s classifies her communication as an “intent” to resign, not an actual resignation. The court wrote that the district court erred by ignoring that Plaintiff had a plausible claim to relief and not drawing reasonable inferences in her favor. View "Phyllis Edwards v. Dothan City Schools, et al" on Justia Law

Plaintiff, a black nurse who was disciplined and ultimately fired by her employer, Public Health Trust of Miami-Dade County—appealed the district court’s entry of summary judgment on her Title VII and state-law claims alleging (1) employment discrimination, (2) hostile work environment, and (3) retaliation. Harris contends that the district court erred in rejecting all three claims.   The Eleventh Circuit affirmed. The court wrote that Public Health Trust says that several incidents that occurred at Jackson Reeves shouldn’t be considered because they weren’t caused by Plaintiff’s race. The court wrote that it agreed with Public Health Trust that three of the incidents weren’t caused by Harris’s race and, accordingly, shouldn’t be considered as part of the hostile-work-environment calculus. Further, the court reasoned that even considering Plaintiff’s limited evidence in the light most favorable to her, these are not, given the totality of the circumstances, sufficiently severe or pervasive to alter the terms and conditions of her employment and create an abusive working environment. View "Mary E. Harris v. The Public Health Trust of Miami-Dade County" on Justia Law

TASER International, Inc., obtained an injunction against “Phazzer [Electronics] and its officers, agents, servants, employees, and attorneys; and any other persons who are in active concert or participation with Phazzer Electronics or its officers, agents, servants, employees, or attorneys” (the “2017 injunction”). The injunction prohibited Phazzer Electronics from distributing or causing to be distributed certain stun guns and accompanying cartridges that infringed on TASER’s intellectual property. At the time of the TASER-Phazzer Electronics litigation, Steven Abboud controlled Phazzer Electronics, and Phazzer Electronics employed, among others, Defendant. In 2018, after the district court found Abboud in contempt for violating the 2017 injunction, Abboud and Defendant went to work for other entities with “Phazzer” in their names. Based on that activity, the district court found Defendant (and others) in contempt of the 2017 injunction. At issue on appeal is whether the 2017 injunction extended broadly enough to bind Defendant and prohibit her conduct under the theories of liability that the government has pressed and the district court decided   The Eleventh Circuit vacated Defendant’s conviction. The court concluded that the record cannot sustain Defendant’s conviction.  The court explained that the district court did not make factual findings about whether Defendant was a key employee. Nor did it determine whether she so controlled Phazzer Electronics and the litigation that resulted in the 2017 injunction that it would be fair to say she had her day in court on that injunction. View "USA v. Diana Robinson" on Justia Law

Petitioner was employed at Office Depot as a senior financial analyst. He was responsible for, among other things, ensuring data integrity. One of Ronnie’s principal duties was to calculate and report a metric called “Sales Lift.” Sales Lift is a metric designed to quantify the cost-reduction benefit of closing redundant retail stores. Petitioner identified two potential accounting errors that he believed signaled securities fraud related to the Sales Lift. Petitioner alleged that after he reported the issue, his relationship with his boss became strained. Eventually, Petitioner was terminated at that meeting for failing to perform the task of identifying the cause of the data discrepancy. Petitioner filed complaint with the Department of Labor’s Occupational Safety and Health Administration (OSHA), and OSHA dismissed his complaint. Petitioner petitioned for review of the ARB’s decision.
The Eleventh Circuit denied the petition. The court explained that Petitioner failed to allege sufficient facts to establish that a reasonable person with his training and experience would believe this conduct constituted a SOX violation, the ARB’s decision was not arbitrary or capricious, an abuse of discretion, or otherwise not in accordance with the law. The court wrote that Petitioner’s assertions that Office Depot intentionally manipulated sales data and that his assigned task of investigating the discrepancy was a stalling tactic are mere speculation, which alone is not enough to create a genuine issue of fact as to the objective reasonableness of Petitioner’s belief. View "Chris Ronnie v. U.S. Department of Labor" on Justia Law

Plaintiff appealed the district court’s affirmance of the Social Security Administration’s (SSA) denial of his claim for disability insurance benefits (DIB) and supplemental security income (SSI) following the Appeals Council’s remand. He argued that the Administrative Law Judge (ALJ) erred on remand by reconsidering a prior finding of Plaintiff’s residual functional capacity (RFC) after the prior decision had been vacated, in violation of the law-of-the-case doctrine and the mandate rule.   The Eleventh Circuit affirmed. The court explained that the mandate rule, which is “a specific application” of the law-of-the-case doctrine, binds a lower court to execute the mandate of the higher court without further examination or variance. The court wrote that even assuming the law-of-the-case doctrine and mandate rule apply, the ALJ was free to reconsider Plaintiff’s RFC because the 2018 Decision was vacated. The court reasoned that the district court order made no findings about how the ALJ erred in his determination on Plaintiff’s disability. Instead, the district court remanded the case on a motion from the Commissioner without making specific factual findings, including whether or not the ALJ properly determined Plaintiff’s RFC. As a result, the Appeals Council had no factual findings in the remand order from which it could deviate. Additionally, the Appeals Council explained that Plaintiff filed a new SSI claim in 2019, and it consolidated that claim with his initial claims, which stemmed from the same disabilities. The SSA regulations allow an ALJ to consider any issues relating to the claim, whether or not they were raised in earlier administrative proceedings. View "George Weidner, III v. Commissioner of Social Security" on Justia Law

After eight years of litigation involving ten different parties, Continental Holdings, Inc. (Continental) appealed the district court’s denial of its November 2015 motion to voluntarily dismiss Houston Pipe Line Company, L.P. and HPL GP, LLC (collectively, Houston) from the case pursuant to Federal Rule of Civil Procedure 41(a)(2). Continental argues that we should reverse the district court’s Rule 41(a)(2) decision and vacate all of the subsequent orders governing its dispute with Houston.   The Eleventh Circuit dismissed the appeal. The court explained that over the course of this litigation, many parties filed motions pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii) in an attempt to voluntarily dismiss their claims against another party. For each motion, fewer than all parties involved in the litigation provided a signature. Yet, Rule 41(a)(1)(A)(ii) only permits a plaintiff to dismiss an action without a court order by filing “a stipulation of dismissal signed by all parties who have appeared. The court explained that because multiple motions made under this Rule were not signed by all parties who appeared in the lawsuit, they were ineffective, and the claims they purported to dismiss remain pending before the district court. Consequently, there has not been a final judgment below, and the court explained that it lacks jurisdiction to consider the merits of this appeal. View "City of Jacksonville v. Jacksonville Hospitality Holdings, L.P., et al" on Justia Law

Plaintiff was the Chief Meteorologist at CBS46, an Atlanta news station. But during his tenure, female colleagues raised repeated complaints that he engaged in inappropriate conduct and sexual harassment—including “compliments” about appearance, sexually charged language, requests for nude photos, and more. Plaintiff, who is white, alleges that he was terminated because of his race in violation of 42 U.S.C. Section 1981. The sexual harassment justification, he says, was just a pretext. The district court granted summary judgment to Defendants.   The Eleventh Circuit affirmed. The court wrote that the ultimate question in any discrimination case is whether the defendant intentionally discriminated against the plaintiff based on race. Here, Plaintiff failed to show that a reasonable jury could conclude that Defendant terminated his employment because he was white.   The court explained that Plaintiff notes that the station’s new meteorologist is a Hispanic woman. However, Plaintiff mostly argued that the existence of race data on the corporate form meant that he was fired because he was white. The court explained Plaintiff lacked direct evidence of discrimination, he lacked evidence that Defendant treated his race as a factor favoring his termination, and he lacked evidence that Defendant treated similarly situated non-white employees more favorably. On the other hand, Defendant has produced extensive evidence of Plaintiff’s sexual harassment, which is a valid, nondiscriminatory reason for his termination. The court explained that on this record, no reasonable jury could infer that Defendant’s justification was pretext for race discrimination. View "Paul Ossmann v. Meredith Corporation" on Justia Law

Employer provides security for NASA and employs approximately 40 security officers. Employee was hired as a security officer in 2018. After learning that his pay did not increase as promised after completing his training, Employee and a co-worker who was in a similar position sought reimbursement of unpaid wages. Employee wired both employees their missing wages, but Employee was not paid for other reimbursements he believed he was entitled to.After Employee and several co-workers were caught using their personal cell phones, Employee was suspended pending an investigation. The other co-workers received less severe disciplinary sanctions, if any.After review, the NLRB found that Employee engaged in protected concerted activity on several occasions and that Employer violated Section 8(a)(1)5 of the NLRA. Employer filed a petition for review with the Eleventh Circuit.The Eleventh Circuit denied Employer's petition for review of an NLRB decision finding that Employer unlawfully terminated Employee for engaging in activity protected under the National Labor Relations Act. View "Security Walls, LLC v. National Labor Relations Board" on Justia Law

A nine-year-old girl took her own life after a classmate repeatedly delivered racist insults to her. The girl's mother and grandmother sought to hold the school system and several school officials accountable for her death. The family filed a lawsuit asserting claims arising under federal and state law against the school system and the school officials. The district court granted summary judgment to the school system and its officials, concluding that the family failed to satisfy various elements of their federal statutory claims and that qualified immunity barred at least one of the claims. The court concluded that the state law claims failed on immunity grounds. The family appealed.The Eleventh Circuit affirmed. Although the response of the school system and its officials was "truly discouraging," the standard for relief in cases of student-on-student harassment was not met. The court explained that a reasonable jury could not find that DCS acted with deliberate indifference, that it intentionally discriminated against the girl, or that Defendants' actions were arbitrary or conscience-shocking. Thus, the district court did not err in granting summary judgment to the defendants on the family's Title IX, Title VI, equal protection, and substantive due process claims. View "Jasmine Adams, et al v. Demopolis City Schools, et al" on Justia Law