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

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

Plaintiff filed suit against his former employers, alleging that the cars that he parks in his job as a valet parker are the interstate "materials" that bring his employer within the definition of an enterprise engaged in commerce such as to provide Fair Labor Standards Act (FLSA) coverage. The district court granted summary judgment for defendants and subsequently denied plaintiff's motion for reconsideration. The Eleventh Circuit held that because the cars plaintiff parks are "goods," not "materials," the ultimate consumer exception operates to exclude from the category of covered "goods" the handling of the cars at issue here. Accordingly, the court affirmed the judgment. View "Rodriguez v. Gold Star, Inc." on Justia Law

Plaintiff filed suit against the Georgia district attorney and others under 42 U.S.C. 1983, alleging that defendants conspired to violate his First Amendment rights. Plaintiff, employed as the director of the police department's crime lab, was terminated from his position after the district attorney contacted the police chief to express his concerns that plaintiff had written an expert report for and planned to testify on behalf of the defense in a criminal case. The Eleventh Circuit held that prosecutors were not entitled to absolute immunity for their alleged actions in this case because those actions were not taken in their role as advocates. However, the prosecutors were entitled to qualified immunity because they were acting within the outer perimeter of their discretionary skills in expressing concerns about plaintiff's outside work, and the law was not clearly established at the time. Accordingly, the court reversed the denial of the prosecutors' motion for judgment on the pleadings based on qualified immunity and remanded. View "Mikko v. Howard" on Justia Law

Defendant filed suit against his former employer under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601-2654, alleging that the employer interfered with the exercise of his FMLA rights and later retaliated against him for asserting those rights. The district court granted summary judgment for the employer. Because plaintiff likely waived his FMLA right to reinstatement by taking an additional 30 days of medical leave, because he failed to submit a fitness-for-duty certification by the end of his FMLA leave, and because the record was devoid of proof challenging the employer's contention that its fitness-for-duty certification policy was implemented in a uniform fashion, plaintiff lost the right to be reinstated after failing to comply with this policy. Therefore, the court concluded that plaintiff failed to show that he was denied a benefit to which he was entitled under the FMLA, and the district court properly granted summary judgment as to the interference claim. The court affirmed as to this claim. The court held that temporal proximity, for the purpose of establishing the causation prong of a prima facie case of FMLA retaliation, should be measured from the last day of an employee's FMLA leave until the adverse employment action at issue occurs. In this case, plaintiff has met his burden of raising a genuine dispute as to whether his taking of FMLA leave and his termination were casually related. Therefore, the court reversed the judgment as to the retaliation claim and remanded for further proceedings. View "Jones v. Gulf Coast Health Care of Delaware, LLC" on Justia Law