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

Plaintiffs, worker who helped build the new Marlins ballpark, filed suit alleging that the contractor who employed them failed to pay them the wages and overtime that they were entitled to receive under the Fair Labor Standards Act (FLSA), 29 U.S.C. 206. The district court dismissed the complaint for lack of subject matter jurisdiction. The court concluded that plaintiffs' failure to reiterate their unpaid-overtime-hours claim in the statement of claim document is not controlling where that document does not have the status of a pleading and is not an amendment under Federal Rule of Civil Procedure 15. The existence of federal jurisdiction at the pleading stage is to be determined based on the contents of the complaint, applying the well-pleaded complaint rule. In this case, the unpaid-overtime-hours claim in Count I alleges that plaintiffs were not always paid time-and-a-half for hours beyond forty worked in a workweek but were instead paid their regular rate for some overtime hours and nothing at all for others. The court concluded that plaintiffs alleged a claim on the face of the complaint and reversed the judgment of the district court, remanding for further proceedings. View "Calderon, et al. v. Form Works/Baker JV, LLC" on Justia Law

After his termination, plaintiff, a tenured university professor at Georgia Tech, filed suit under 42 U.S.C. 1983 against Georgia Tech's President and others. On appeal, defendant challenged the district court's grant of defendants' motion to dismiss pursuant to Rule 12(b)(6). The court concluded that plaintiff was afforded adequate procedural due process prior to revocation of his tenure and termination of his employment with Georgia Tech where the pre-termination procedures afforded plaintiff satisfied the established guidelines for minimum procedural due process. Plaintiff received prior, written notice of the charges against him, he presented argument and evidence on his own behalf, he had a right to appeal his termination to the Board of Regents, and he submitted a written appeal to the Board of Regents. The court affirmed the judgment of the district court. View "Laskar, Ph.D. v. Peterson, et al." on Justia Law

Plaintiff filed suit against the School District, her former employer, for violations of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., and the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq. The court held that the School District is not an "arm of the State," and instead operates more like a county or similar political subdivision to which Eleventh Amendment immunity does not extend. Therefore, the court reversed the district court's finding that the School District was entitled to Eleventh Amendment immunity. In regards to plaintiff's ADA retaliation claim, the court affirmed the district court's grant of summary judgment to the School District where the district court did not abuse its discretion by declining to construe plaintiff's ADA retaliation claim as being based on different facts than the ones actually pled in her ADA count. Even when construed liberally, plaintiff's complaint did not give the School District notice that her ADA retaliation claim was based on her request for FMLA leave. View "Lightfoot v. Henry Cnty. Sch. Dist." on Justia Law

Jose Morabito, an Argentinian national, filed a charge of discrimination with the EEOC, alleging that RCCL violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12112, when RCCL refused to renew his employment contract after he was diagnosed with HIV and Kaposi Sarcoma, even though he had been declared fit for duty. In this appeal, the EEOC challenged the district court's denial of its application for enforcement of an administrative subpoena issued to RCCL. The court concluded that the disputed portions of the subpoena are aimed at discovering members of a potential class of employees or applicants who suffered from a pattern or practice of discrimination, rather than fleshing out Mr. Morabito's charge. Even if the information sought has some tenuous relevance to the charge filed by Mr. Morabito, the court found no error in the district court's holding that compliance with the subpoena would be unduly burdensome to RCCL. The district court's weighing of the burden to RCCL and the likely irrelevance of the information to Mr. Morabito's charge was not an abuse of discretion, especially in light of the jurisdictional issues raised by RCCL. Accordingly, the court affirmed the judgment. View "Equal Employment Opportunity Commission v. Royal Caribbean Cruises, LTD." on Justia Law

Plaintiff appealed a judgment in favor of his former employer and against his complaint of racial discrimination and retaliation. At issue was whether the district court erred when it entered a judgment as a matter of law based on inconsistent jury verdicts. The court held that, to determine whether to grant a judgment as a matter of law, the district court should have considered only the sufficiency of the evidence in support of the verdict, not the consistency of that verdict with another. Accordingly, the court vacated and remanded for the district court to reinstate the jury verdict against the employer for retaliation. The court affirmed summary judgment against plaintiff's claim of discrimination against plaintiff's supervisor.View "Connelly v. Metropolitan Atlanta Rapid Trans., et al." on Justia Law

Plaintiffs filed suit under general maritime law against their maritime employment agencies, asserting a claim for wages. The district court granted defendants summary judgment on plaintiffs' claims and plaintiffs appealed. After reviewing the record, reading the parties' briefs, and hearing oral argument, the court affirmed the judgment of the district court for the reasons set out in its two well-reasoned and well-written orders, which were filed on November 4, 2013, and November 7, 2013. The court adopted these orders as the court's opinion with the same effect as if the court had written it. Accordingly, the court affirmed the judgment of the district court.View "Jurich, et al. v. Compass Marine, Inc." on Justia Law

Plaintiff filed suit against her employer, alleging violations of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601; the Equal Pay Act, 29 U.S.C. 206; Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq.; and the Consolidated Omnibus Budget Reconciliation Act (COBRA), 29 U.S.C. 1161 et seq. Plaintiff's claims stemmed from her employer's denial of her request to take FMLA leave after the birth of her child. The court held that the district court correctly awarded summary judgment to the employer with respect to plaintiffs' claims under Title VII and the Equal Pay Act, and did not abuse its discretion by assessing a statutory COBRA penalty against the employer; the district court erred by dismissing plaintiff's FMLA claim and by refusing to consider her additional litigation-related expenses as part of an attorney's fee award; and, therefore, the court affirmed in part, vacated in part, and remanded in part.View "Evans v. Books-A-Million" on Justia Law

Plaintiffs filed suit against the County and Union, alleging violations of federal and state civil rights statutes. The jury found that the County subjected plaintiffs to fitness-for-duty examinations because of their grievances and charges against the County. The district court held that there was insufficient evidence to support this finding. The court disagreed, concluding that the jury was permitted to find that the desire to retaliate was a "but-for" cause of the County's decision; the district court did not abuse its discretion in rejecting plaintiffs' proposed jury instructions; and, even assuming that the restriction on the Union's speech was content-based, the court nevertheless rejected the Union's argument that the First Amendment immunizes it under the facts of this case. The court reversed the entry of judgment in favor of the County and ordered that judgment be entered against the County on the verdicts as returned. The court affirmed the judgment in all other respects.View "Booth, et al. v. Pasco Cty., FL, et al." on Justia Law

Plaintiff filed suit against the school district, claiming that he was retaliated against by the school district because he made public statements to the press regarding the accreditation investigation of the school district. Because plaintiff was not speaking pursuant to any official duties for the school district, bur rather was speaking in his capacity as president of the Georgia Association of Educators, the district court erred when it held that plaintiff's speech fell under the rule announced in Garcetti v. Ceballos. Accordingly, the court vacated the district court's order granting summary judgment in favor of the school district and remanded for further proceedings.View "Hubbard v. Clayton Co. Sch. Dist., et al." on Justia Law

Plaintiff filed suit against his employer, alleging that the employer violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601, by terminating him based on his diagnoses of alcoholism. The court agreed with the employer that plaintiff was not qualified under DOT regulations to drive a commercial truck because he had a current clinical diagnosis of alcoholism. Because the court determined that plaintiff was not entitled to drive a commercial truck under the DOT regulations, the court need not address whether the employer's company policy also supported that determination. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the employer on the ADA claim. In regards to the FMLA claims, the court agreed with the district court's determination that plaintiff's interference claim failed because the employer would have discharged plaintiff regardless of his FMLA leave, and plaintiff's retaliation claim failed because he could not show that the employer's decision to terminate him was causally related to his FMLA leave. Accordingly, the court affirmed the district court's grant of summary judgment as to the FMLA claims. View "Jarvela v. Crete Carrier Corp." on Justia Law