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

MaChelle Joseph, a former head women’s basketball coach at Georgia Tech, and Thomas Crowther, a former art professor at Augusta University, filed separate complaints alleging sex discrimination and retaliation under Title IX and other laws. Joseph claimed that Georgia Tech provided fewer resources to the women’s basketball team compared to the men’s team and retaliated against her for raising these issues. Crowther alleged that he was retaliated against after being accused of sexual harassment and participating in the investigation.The United States District Court for the Northern District of Georgia dismissed Joseph’s Title IX claims, ruling that Title VII precluded them, and granted summary judgment against her remaining claims. For Crowther, the district court denied the motion to dismiss his Title IX claims, allowing them to proceed.The United States Court of Appeals for the Eleventh Circuit reviewed these consolidated appeals. The court held that Title IX does not provide an implied right of action for sex discrimination in employment, reversing the district court’s decision to allow Crowther’s Title IX claims and affirming the dismissal of Joseph’s Title IX claims. The court also ruled that Crowther’s retaliation claim under Title IX, based on his participation in the investigation, did not state a valid claim. Additionally, the court found that Joseph’s claims of sex discrimination under Title VII, based on her association with the women’s team, were not viable. Finally, the court affirmed the summary judgment against Joseph’s retaliation claims under Title VII, Title IX, and the Georgia Whistleblower Act, concluding that she failed to show that the reasons for her termination were pretextual. View "Joseph v. Board of Regents of the University System of Georgia" on Justia Law

Alfreida Hogan, an African-American woman, was employed by the Department of Veterans Affairs (VA) as a nurse practitioner from July 2012 until March 2019, when she was demoted to staff nurse and subsequently resigned. She alleged that her immediate supervisor harassed her and gave her false, negative performance reviews due to her race, leading to her demotion. In April 2019, Hogan contacted her agency counselor, claiming racial discrimination. On July 3, 2019, the counselor informed her that informal resolution efforts had ended and that she could file a formal administrative complaint. Hogan's counsel claimed to have emailed the complaint on July 19, 2019, but the VA never received it. Hogan's counsel did not follow up until April 2020, when he learned the VA had not received the complaint. The VA dismissed the complaint due to the missed 15-day filing deadline.The district court dismissed Hogan's Title VII claims for race discrimination and retaliation, citing the Eleventh Circuit's decision in Crawford v. Babbitt, which held that failure to exhaust administrative remedies was a jurisdictional bar. The district court concluded it lacked subject-matter jurisdiction due to Hogan's untimely filing of her administrative complaint.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court determined that the 15-day deadline to file a formal administrative complaint, set by EEOC regulation 29 C.F.R. § 1614.106(b), is a claims-processing rule subject to equitable tolling, not a jurisdictional requirement. The court noted that Crawford did not control this case because it involved a different issue. The court also referenced the Supreme Court's decision in Fort Bend County v. Davis, which held that Title VII's charge-filing requirement is not jurisdictional. Despite this, the court affirmed the district court's dismissal, concluding that Hogan did not demonstrate due diligence to warrant equitable tolling of the 15-day deadline. View "Hogan v. Secretary, U.S. Department of Veterans Affairs" on Justia Law

Eric and Todd Romano, trustees of the Romano Law, PL 401(k) Plan, filed a class action against John Hancock Life Insurance Company. They claimed that John Hancock breached its fiduciary duties under the Employee Retirement Income Security Act of 1974 (ERISA) by not passing through the value of foreign tax credits received from mutual funds to the defined-contribution plans. The Romanos argued that John Hancock should have used these credits to reduce the administrative fees charged to the plans.The United States District Court for the Southern District of Florida granted summary judgment in favor of John Hancock, concluding that John Hancock was not an ERISA fiduciary regarding the foreign tax credits and did not breach any fiduciary duties. The court also ruled that the Romanos and the class lacked Article III standing because they failed to establish loss causation.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that John Hancock was not an ERISA fiduciary concerning the foreign tax credits because these credits were not plan assets. The court explained that the foreign tax credits were a result of John Hancock's ownership of mutual fund shares and were not held in trust for the benefit of the plans. Additionally, the court found that John Hancock did not have discretionary authority over the management or administration of the separate accounts that would make it a fiduciary under ERISA. Consequently, the Romanos' claims for breach of fiduciary duty and engaging in prohibited transactions failed as a matter of law. View "Romano v. John Hancock Life Insurance Company (USA)" on Justia Law

In this labor dispute, several employees sued their employer, a steel manufacturer, alleging violations of the Fair Labor Standards Act (FLSA) and Alabama common law. They claimed the company failed to pay wages for all hours worked, improperly calculated overtime, and delayed overtime payments. The plaintiffs sought relief for themselves and similarly situated employees.The United States District Court for the Southern District of Alabama ordered the defendant to produce key time and pay records multiple times over two years. The defendant repeatedly failed to comply, offering various excuses and blaming its third-party payroll processor, ADP. The court eventually issued a default judgment against the defendant due to its continuous noncompliance and misrepresentations.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's decision to issue a default judgment, finding that the defendant's conduct warranted such a severe sanction. The appellate court also upheld the district court's denial of the defendant's motion to reconsider the sanctions, noting that the district court had the discretion to revisit its interlocutory orders but did not abuse that discretion in this case.The appellate court also affirmed the district court's determination that the plaintiffs' claims regarding workweek calculations and bonus payments were well-pleaded. However, the appellate court vacated and remanded the district court's calculation of damages, instructing the lower court to provide a more thorough explanation of its reasoning regarding the statute of limitations defense. View "Hornady v. Outokumpu Stainless USA, LLC" on Justia Law

Two plaintiffs, Julia McCreight and Rebecca Wester, were long-term employees of AuburnBank, each with over twenty years of service. McCreight, a mortgage loan originator, and Wester, a loan closer, were both terminated by Michael King, the mortgage department manager. McCreight was fired for sending an unauthorized loan approval letter to a borrower who did not qualify, while Wester was terminated for failing to verify a borrower’s employment status before closing a loan. Both women, over sixty years old at the time of their termination, claimed they were fired due to age and sex discrimination and in retaliation for their complaints about King’s behavior.The United States District Court for the Middle District of Alabama granted summary judgment in favor of AuburnBank and King on all counts. The court found that neither McCreight nor Wester provided sufficient evidence to support their claims of age and sex discrimination or retaliation. The plaintiffs appealed, arguing that the district court erred in its judgment.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court affirmed the district court’s decision, holding that McCreight and Wester failed to present enough evidence for a reasonable jury to conclude that their terminations were due to illegal discrimination. The court clarified that mixed-motive theories of liability do not need to be explicitly pleaded in the complaint but must be raised by summary judgment. The court found that McCreight did not raise a mixed-motive theory at the district court level and failed to provide sufficient evidence for her single-motive theory. Similarly, Wester’s evidence was insufficient to support her claims. The court also held that both plaintiffs failed to show causation for their retaliation claims, as there was no evidence that the decision-makers knew about their discrimination complaints. View "McCreight v. AuburnBank" on Justia Law

Jeremy Hitt, a Remote Control Operator for CSX Transportation, Inc., was terminated after receiving three workplace violations within a three-year period. Hitt's first violation occurred in 2017 for failing to leave unattended train cars at a specified location. In the summer of 2018, Hitt refused to work during a lightning storm, citing safety concerns, and later refused to operate the train at a speed he considered unsafe. His second violation was in November 2018 for failing to secure his train properly. The third violation occurred in January 2019 when Hitt failed a banner test by using the emergency brake to stop the train.The United States District Court for the Northern District of Alabama granted summary judgment to CSX, concluding that Hitt failed to provide sufficient evidence of causation to support his claim under the Federal Railroad Safety Act (FRSA). The court found that Hitt could not establish that his protected activity (refusing to work during the lightning storm) was a contributing factor to his termination.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that Hitt failed to establish causation, as there was no evidence that his protected activity contributed to his termination. The court noted that the decision-makers who terminated Hitt were unaware of his protected activity and that Hitt's supervisor, who allegedly retaliated against him, had no influence over the termination decision. The court also found that the temporal gap between the protected activity and the adverse action was too long to establish causation based on temporal proximity alone. Thus, the court concluded that Hitt could not prove the elements of his FRSA claim. View "Hitt v. CSX Transportation Inc" on Justia Law

A group of drivers sued their employer, Owl, Inc., for breach of contract and violations of the Fair Labor Standards Act (FLSA). They claimed they were not paid the correct hourly rate under their employment contract or overtime wages under the FLSA. The district court granted summary judgment for Owl on the breach of contract claim and limited the damages available to the drivers for the FLSA claim. The parties then settled the FLSA claim for $350,000, and the drivers appealed the district court’s rulings.The district court for the Middle District of Florida granted summary judgment on the breach of contract claim, reasoning that the drivers had agreed to a specific hourly rate, and enforcing a higher rate under the Service Contract Act (SCA) would create a private right of action under the SCA, which does not exist. The court also granted Owl’s motion in limine, limiting the FLSA damages to one-and-a-half times the rate the drivers were actually paid. The drivers settled the FLSA claim but reserved the right to appeal the district court’s rulings.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that it had jurisdiction under 28 U.S.C. § 1291 because the district court entered a final judgment on all claims. The court also held that the drivers had standing to challenge the district court’s rulings despite the settlement. On the merits, the Eleventh Circuit affirmed the district court’s summary judgment on the breach of contract claim, holding that the SCA wage was not incorporated into the employment contracts. However, it reversed the district court’s ruling on the FLSA claim, holding that the “regular rate” under the FLSA should include the prevailing wage required by the SCA. The case was remanded for further proceedings consistent with this opinion. View "Perez v. Owl, Inc." on Justia Law

The case involves a class of current and former Home Depot employees who alleged that Home Depot failed to prudently manage its 401(k) retirement plan, resulting in excessive fees and subpar returns. The plaintiffs argued that Home Depot did not adequately monitor the fees charged by the plan’s financial advisor and failed to prudently evaluate four specific investment options, leading to financial losses for the plan participants.The United States District Court for the Northern District of Georgia found that there were genuine disputes of material fact regarding whether Home Depot had complied with its duty of prudence in monitoring plan fees and three of the four challenged funds. However, the court concluded that the plaintiffs had not met their burden of proving loss causation for any of their claims. The court also found no genuine dispute regarding the prudence of Home Depot’s monitoring process for the Stephens Fund and ruled that the plaintiffs had forfeited their requests for equitable relief by not arguing them at the summary judgment stage.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs bear the burden of proving loss causation in ERISA breach-of-fiduciary-duty claims. The court found that the plaintiffs failed to show that the fees charged by the financial advisors were objectively imprudent, given the size and complexity of Home Depot’s plan. The court also determined that the plaintiffs did not provide sufficient evidence to prove that the four challenged funds were objectively imprudent investments. Additionally, the court agreed with the district court that the plaintiffs had forfeited their claims for equitable relief by not raising them at the summary judgment stage. Therefore, the court affirmed the district court’s grant of summary judgment in favor of Home Depot. View "Pizarro v. The Home Depot, Inc." on Justia Law

The case involves two brothers, Levi and Benjamin Goldfarb, who sought payment of a $500,000 claim under an Accidental Death & Dismemberment insurance policy after their father, Dr. Alexander Goldfarb, died while mountain climbing in Pakistan. The insurer, Reliance Standard Life Insurance Company, denied the claim because the cause of Dr. Goldfarb’s death was unknown, and therefore, his beneficiaries could not show that he died by accident. The Goldfarb brothers challenged the denial in district court under the Employee Retirement Security Act.The district court ruled in favor of the Goldfarbs, stating that Dr. Goldfarb’s death was accidental and that Reliance Standard’s failure to pay the Accidental Death & Dismemberment claim was arbitrary and capricious. The court granted summary judgment to the Goldfarbs and denied Reliance Standard’s cross motion for summary judgment. Reliance Standard appealed this decision.The United States Court of Appeals for the Eleventh Circuit disagreed with the district court's decision. The appellate court found that Reliance Standard’s decision that Dr. Goldfarb’s death was not accidental under the insurance policy was supported by reasonable grounds, and the denial of the Goldfarbs’ claim for benefits was not arbitrary and capricious. Therefore, the court reversed the district court’s grant of summary judgment to the Goldfarbs and directed the court to enter judgment in Reliance Standard’s favor. View "Goldfarb v. Reliance Standard Life Insurance Co." on Justia Law

The case revolves around William Spears, a front desk clerk at hotels operated by Rick Patel Sr. and his son, Rick “Sunny” Patel Jr. Spears was compensated with monthly paychecks and onsite lodging. He sued the Patels and the hotel entities under the Fair Labor Standards Act for wages owed and unpaid overtime. The district court ruled that Sunny was an employer individually liable for the violations. In calculating Spears’s damages, the court considered the stipulated value of Spears’s lodging for unpaid overtime but declined to include it in the minimum-wage calculation.The case went to a bench trial before a magistrate judge. The judge found that Spears was not paid the legally required minimum wage or overtime. The judge ruled that Rick and Sunny were employers under the Act individually liable for those violations. The judge also found that Spears was entitled to damages for unpaid overtime and minimum wages. The judge included the stipulated $630 lodging value to determine Spears’s overtime pay rate but did not give the Patels credit for the value of Spears’s lodging when calculating Spears’s unpaid minimum wages.The United States Court of Appeals for the Eleventh Circuit affirmed the ruling that Sunny was an employer under the Act due to his involvement in the day-to-day operation of the hotels and some financial control. However, the court vacated and remanded for recalculation of damages. The court held that the magistrate judge erred in excluding the stipulated value of Spears’s lodging from the calculation of his unpaid minimum wages but including it for the calculation of Spears’s overtime damages. The court reasoned that the stipulation to the value of Spears’s lodging relieved the Patels of the burden to prove at trial the reasonable cost of lodging. View "Spears v. Patel" on Justia Law