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

Plaintiff entered into a joint stipulation with NHMA purporting to voluntarily dismiss a 42 U.S.C. 1981 claim pursuant to Federal Rule of Civil Procedure 41(a)(1) and then moved the district court to enter final judgment on her remaining employment-related claims. The district court denied the motion because it no longer had jurisdiction over the action after plaintiff voluntarily dismissed her lone remaining claim. The Eleventh Circuit reversed, holding that the parties' joint stipulation of dismissal was invalid where Rule 41(a)(1) permitted voluntary dismissals only of entire actions, not claims. Therefore, the court held that the invalid joint stipulation did not divest the district court of jurisdiction over the case. View "Pamela M. Perry, M.D. v. The Schumacher Group of Louisiana" on Justia Law

As a matter of first impression, the Eleventh Circuit held that it was sufficient for an opt-in plaintiff to file a written consent pursuant to the Fair Labor Standards Act (FLSA), 29 U.S.C. 216(b), to confer party-plaintiff status. In this case, appellants were parties to the litigation upon filing consents and, absent a dismissal from the case, remained parties in the litigation. The court affirmed the district court's denial of conditional certification and vacated the district court's clarification order, remanding with instructions for the district court to either dismiss appellants from the case without prejudice to refile, or to go forward with appellants' individual cases since discovery has been completed. The court also held that appellants were entitled to statutory tolling of their claims beginning on the dates they filed their written consents. View "Houston v. Country Club, Inc." on Justia Law

The Union notified TCI, a Martha’s Vineyard bus company, that a majority of its drivers had signed Union authorization cards. The parties agreed to an election. TCI was required to provide a list of eligible voters and their addresses. TCI identified 39 drivers and delivered 37 residential addresses, one P.O. Box address, and combination of a residential address and a P.O. Box. The Union mailed voting information but only seven drivers attended a meeting. In the first election, the drivers voted 21 to 18 against unionization. Subsequently, 22 envelopes the Union had mailed were returned as undeliverable. A hearing officer determined that the list was deficient. The NLRB ordered a new election, in which the drivers voted in favor of representation, 17 to 14. TCI asserted that, before the election, two drivers had threatened another driver that they would “kill him” if he did not vote for the Union. A hearing officer concluded that the statements “were made in jest.” The NLRB certified the Union. The NLRB found that TCI had engaged in unfair labor practices under the National Labor Relations Act, 29 U.S.C. 158 (a)(1)(5), when it refused to bargain with the Union. The Eleventh Circuit granted the NLRB’s application for enforcement of its order. The record supported the decision to order a new election and that the drivers were not acting as Union agents engaging in intimidation. View "Transit Connection, Inc. v. National Labor Relations Board" on Justia Law

A jury awarded to the EEOC and an employee back pay, compensatory damages, and punitive damages after finding that the employer, Exel, discriminated against her because of her sex. The district court denied Exel's motion for a renewed motion for judgment as a matter of law as to liability, but granted the motion as to the jury's punitive damages award. The Eleventh Circuit affirmed, holding that the employee's evidence was sufficient for a reasonable jury to find that she suffered discrimination because of her sex. The court also held that, under prior precedent, the district court properly vacated the jury's punitive damages award. View "EEOC v. Exel, Inc." on Justia Law

A jury awarded to the EEOC and an employee back pay, compensatory damages, and punitive damages after finding that the employer, Exel, discriminated against her because of her sex. The district court denied Exel's motion for a renewed motion for judgment as a matter of law as to liability, but granted the motion as to the jury's punitive damages award. The Eleventh Circuit affirmed, holding that the employee's evidence was sufficient for a reasonable jury to find that she suffered discrimination because of her sex. The court also held that, under prior precedent, the district court properly vacated the jury's punitive damages award. View "EEOC v. Exel, Inc." on Justia Law

The Eleventh Circuit reversed and remanded the district court's summary judgment dismissal of plaintiff's discrimination claims against Manheim, her employer. Plaintiff alleged that the employer discriminated against her by paying her less than her male predecessor. The court held that, taking the evidence in the light most favorable to plaintiff, she was entitled to proceed to trial on her Equal Pay Act and Title VII claims. In this case, a jury could conclude that plaintiff was entitled to relief under the Equal Pay Act because the evidence supported a finding that she has made a prima facie case and that Manheim failed to establish an affirmative defense in response, and that plaintiff was entitled to relief under Title VII because the evidence supported a finding that her sex "was a motivating factor for" the pay disparity between her and her male predecessor. View "Bowen v. Manheim Remarketing, Inc." on Justia Law

The Eleventh Circuit reversed the district court's grant of summary judgment to defendants in an action alleging that plaintiff was unlawfully discharged from the police department based on disability and/or racial or gender discrimination. The court held that plaintiff's evidence was insufficient to meet her prima facie burden that she was actually disabled, but was sufficient on whether she was regarded as disabled. The court also held that the district court erred in holding that plaintiff failed to produce sufficient evidence that she was a qualified individual. The court reasoned that, in this case, there was significant evidence that cuts against Union City's contention that exposure to OC spray and Taser shocks were essential functions of the job of police detective. The court also held that plaintiff met her prima facie burden of demonstrating that the City discriminated against her because of her perceived disability. Plaintiff had produced sufficient evidence that she was not a direct threat, the differing treatment of plaintiff's white colleagues, in combination with the rest of the evidence, was part of a mosaic of circumstantial evidence sufficient 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 claim of municipal liability. View "Lewis v. Union City, Georgia" on Justia Law

The Eleventh Circuit affirmed the dismissal of plaintiff's claims under state law and the Fair Labor Standards Act (FLSA), 29 U.S.C. 201-219, as well as the grant of summary judgment for the City as to claims under Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. 794. The court held that plaintiff failed to plead facts sufficient on their face to state a plausible claim for a violation of the FLSA; the district court properly dismissed plaintiff's state law claims based on his failure to comply with Ala. Code 11–47–23; and the district court did not err in granting summary judgment in favor of the City as to plaintiff's Rehabilitation Act claims where plaintiff failed to make a prima facie showing that the City unlawfully failed to accommodate him or that he suffered an adverse employment action, plaintiff did not meet his burden of identifying a reasonable accommodation, and he did not show that he was constructively discharged. View "Boyle v. City of Pell City" on Justia Law

Plaintiff, employed as a police officer with the city, filed suit under 42 U.S.C. 1983, alleging violation of his First Amendment rights when the city and the mayor arranged for plaintiff's termination based on plaintiff's support of a purported political enemy. The Eleventh Circuit reversed summary judgment for defendants and held that plaintiff did not voluntarily leave his employment with the city but rather was effectively terminated. Because a reasonable jury could conclude that plaintiff's resignation was not a product of his free will, plaintiff presented sufficient evidence to establish that he suffered an adverse employment action when his employment with the city ended abruptly. The court remanded for further proceedings. View "Rodriguez v. City of Doral" on Justia Law

In 2007, plaintiff filed with the EEOC a charge of race and disability discrimination against her employer, the school board. In 2009, the Commission dismissed the charge and provided her notice of her right to sue within 90 days, but plaintiff failed to file within that period. Instead, in 2011, plaintiff filed a request for reconsideration with the Commission, which then vacated the dismissal of her first charge. The DOJ then granted plaintiff's request for a new notice of her right to sue about the same allegations of discrimination, and she filed suit within 90 days of the second notice. The district court then dismissed the complaint as untimely. The Fourth Circuit affirmed, holding that the Commission lacked the authority to issue the second notice of the right to sue and thus plaintiff failed to establish she was entitled to equitable tolling. View "Stamper v. Duval County School Board" on Justia Law