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

Articles Posted in Labor & Employment Law

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Plaintiff filed suit against the City, the police department, and others, alleging claims of disability and/or racial or gender discrimination. In regard to the disability discrimination claim, the Eleventh Circuit held that plaintiff's evidence was insufficient to meet her prima facie burden of demonstrating that she was actually disabled, but was sufficient on whether she was regarded as disabled; the district court erred in holding that plaintiff failed to produce sufficient evidence that she was a qualified individual; plaintiff met her prima facie burden of demonstrating that the city discriminated against her because of her perceived disability; and plaintiff produced sufficient evidence that she was not a direct threat. In regard to the race and gender discrimination claims, the court held that the evidence of arbitrary personnel decisions surrounding plaintiff's termination, the pretextual justifications offered for the same, the differing treatment of her white male colleagues, and other evidence amounted to sufficient circumstantial evidence to create a triable issue of material fact on whether the police department's actions were discriminatory on the basis of race and/or gender. Finally, the court rejected plaintiff's municipal liability claim under 42 U.S.C. 1981 for the police chief's discriminatory actions as the final decisionmaker. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Lewis v. City of Union City" on Justia Law

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The Eleventh Circuit vacated and remanded the district court's grant of defendant's motion to dismiss the complaint alleging that defendant demoted plaintiff because of his multiple sclerosis in violation of Title I of the Americans with Disabilities Act (ADA). The court weighed the balancing factors to determine whether an entity acts as an arm of the state entitled to sovereign immunity, and held that, when defendant demoted plaintiff, it did not act as an arm of the state and was thus not entitled to sovereign immunity. In this case, the Alabama Supreme Court previously held that a communications district was not an arm of the state; there was no evidence that the State of Alabama exerts any control over the particular function at issue here; where the entity derives its funds, did not support granting sovereign immunity; and Alabama would not be financially responsible for a judgment against defendant. View "McAdams v. The Jefferson County 911 Emergency Communications District, Inc." on Justia Law

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The Eleventh Circuit affirmed the district court's judgment in favor of defendant in an action alleging unpaid overtime wages under the Fair Labor Standards Act (FLSA). In this case, plaintiff alleged that her employer failed to pay her over 700 hours of overtime for her work at his law office. The court held that the district court did not abuse its discretion by denying relief under Federal Rule of Civil Procedure 59 to alter or amend the judgment where the evidence was newly discovered, the outcome of the trial would have been the same, or there were no manifest errors made by the district court; the district court did not abuse its discretion by denying relief under Rule 60 based on a newly discovered email; the district court did not misapply the burden-shifting framework set out in Anderson v. Mt. Clemens Pottery Co., when it found that plaintiff did not prove she worked overtime; and the civil plain error rule barred the court's review of the district court's sua sponte failure to recuse. View "Jenkins v. S. David Anton, PA" on Justia Law

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Plaintiff filed suit against the county and others, alleging that they violated her First Amendment rights by retaliating against her for engaging in protected speech regarding medical clearance decisions for firefighter applicants. The Fifth Circuit affirmed the district court's grant of summary judgment and denial of reconsideration, holding that plaintiff spoke as an employee and not as a private citizen. In this case, plaintiff worked under contract with the county and, for fifteen years, was the primary person responsible for determining whether firefighter applicants were medically qualified. View "King v. Board of County Commissioners" on Justia Law

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A county school board may require all applicants for substitute teacher positions to submit to and pass a drug test as a condition of employment. The Eleventh Circuit held that the school board may, without any suspicion of wrongdoing, collect and search -- by testing -- the urine of all prospective substitute teachers. Because the school board has a sufficiently compelling interest in screening its prospective teachers to justify this invasion of the privacy rights of job applicants, the court held that the school board did not violate the constitutional mandate barring unreasonable searches and seizures. The court recognized that ensuring the safety of millions of schoolchildren in the mandatory supervision and care of the state, and ensuring and impressing a drug-free environment in our classrooms, were compelling concerns. Therefore, the court affirmed the district court's denial of a preliminary injunction because plaintiff failed to establish a likelihood of success on the merits. View "Friedenberg v. School Board of Palm Beach County" on Justia Law

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The Railroad Retirement Tax Act (RRTA) does not impose a tax on a railroad's stock transfers to its employees nor a railroad's provision of relocation benefits to its employees. The Fifth Circuit reversed the district court's judgment and remanded for further consideration of the statutory requirements and the calculation of CSX's taxable compensation. The court held that the Supreme Court's decision in Wisconsin Cent. Ltd. v. United States, 138 S. Ct. 2067 (2018), was dispositive of the stock issue. Under Wisconsin Central, the phrase "money remuneration" in the RRTA refers only to currency or a medium of exchange. Wisconsin Central, as well as the court's plain meaning of the statute, guided the court's decision regarding the relocation benefits. View "CSX Corp. v. United States" on Justia Law

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The Eleventh Circuit affirmed the district court's grant of summary judgment to defendants in an action filed by plaintiff pro se, alleging claims for wage and sex discrimination based on the Equal Protection Clause and the Equal Pay Act (EPA), and retaliation based on her gender in violation of the EPA, as incorporated into the Fair Labor Standards Act. The court held that plaintiff failed to point to any evidence in the record that tended to demonstrate that the interim county manager's stated reasons for denying her higher salary request were false and a pretext for racial or gender discrimination; plaintiff failed to point to any affirmative evidence establishing that his proffered reasons were false or a pretext for unlawful sex discrimination; and plaintiff failed to establish a pretext for retaliation. In this case, the direct supervisor's reason for terminating plaintiff was because she was no longer a "good fit" and lacked the leadership skills necessary to implement successfully many of the proposed changes in the Clerk's office of the Fulton County Juvenile Court. View "Hornsby-Culpepper v. Ware" on Justia Law

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Plaintiff filed suit against Southern Home under Title VII and 42 U.S.C. 1981, asserting claims for discriminatory termination, hostile work environment, and retaliation. The Eleventh Circuit held that plaintiff's discriminatory termination and retaliation claims failed as a matter of law because she provided insufficient evidence of pretext in response to Southern Home's legitimate, nondiscriminatory reasons for terminating her. The court held, however, that plaintiff offered sufficient evidence to create a genuine issue of material fact that the harassment plaintiff suffered was severe or pervasive to alter the terms or conditions of her employment. The court also held that plaintiff offered sufficient evidence to create a genuine issue of material fact that Southern Home had actual notice of the hostile work environment. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Smelter v. Southern Home Care Services Inc." on Justia Law

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Plaintiff filed suit against Kia for gender and national origin discrimination and retaliation under Title VII of the Civil Rights Act of 1964, as well as race and alienage discrimination and retaliation under 42 U.S.C. 1981. The district court granted summary judgment for Kia. The Eleventh Circuit reversed the district court's judgment as to the retaliation claims under Title VII and section 1981. The court held that, viewing the record in the light most favorable to plaintiff, the manner of her opposition to discrimination was reasonable. In this case, were it not for plaintiff's position as a human resource manager, her action of providing the name of an attorney in connection with her EEOC charge would be protected opposition conduct, because it assisted the employee with filing her own charge. The court affirmed the district court's grant of summary judgment on plaintiff's claim of sex and national origin discrimination under Title VII and section 1981. View "Gogel v. Kia Motors Manufacturing of Georgia, Inc." on Justia Law

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The Eleventh Circuit reversed the district court's award of sanctions against plaintiff and his attorneys in an action against Pro Transport and its owners, seeking to recover unpaid wages under the Fair Labor Standards Act (FLSA). The court held that Slater v. U.S. Steel Corp., 871 F.3d 1174 (11th Cir. 2017) (en banc), made clear that plaintiff and his attorneys did not act in bad faith or took legal action that had no reasonable chance of success in litigating the FLSA claim. Therefore, the district court abused its discretion by imposing sanctions. View "Antonio Silva v. Pro Transport, Inc." on Justia Law