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

An athletic trainer employed by a rehabilitation services provider was assigned to work at a local high school under a contract between her employer and the school. Over several years, she reported concerns about the conduct and performance of other athletic trainers at the school, which led to personnel changes. In 2020, after a new head football coach was hired, the trainer was briefly given additional responsibilities but was soon told to return to her original role. Shortly thereafter, the school’s principal requested her removal, citing workplace issues unrelated to her sex. The trainer was then removed from her assignment at the school and offered several alternative positions by her employer, some with reduced pay or less desirable conditions. She ultimately accepted a new assignment but later resigned, alleging that her removal and reassignment were due to sex discrimination and retaliation for her complaints.The United States District Court for the Northern District of Alabama granted summary judgment in favor of the employer, finding that although there was a factual dispute about the employer’s control over the removal, the trainer failed to show that the employer discriminated or retaliated against her in violation of Title VII. The court concluded there was insufficient evidence that the employer knew or should have known the school’s removal request was based on sex, or that the reassignment options were offered for discriminatory reasons.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the trainer’s discrimination claim failed because there was no evidence the employer knew or should have known the school’s request was sex-based, and no evidence that the reassignment was motivated by sex. The retaliation claim also failed, as there was no evidence the employer removed or reassigned her because she engaged in protected activity. The court affirmed summary judgment for the employer. View "Vincent v. ATI Holdings LLC" on Justia Law

NCR Corporation established five “top hat” retirement plans to provide supplemental life annuity benefits to senior executives. Each plan promised participants a fixed monthly payment for life, with language allowing NCR to terminate the plans so long as no action “adversely affected” any participant’s accrued benefits. In 2013, NCR terminated the plans and paid participants lump sums it claimed were actuarially equivalent to the promised annuities, using mortality tables, actuarial calculations, and a 5% discount rate. NCR knew that, statistically, about half of the participants would outlive the lump sums if they continued to withdraw the same monthly benefit, resulting in some participants receiving less than they would have under the original annuity.Participants filed a class-action lawsuit in the United States District Court for the Northern District of Georgia, alleging breach of contract and seeking either replacement annuities or sufficient cash to purchase equivalent annuities. The district court certified the class and granted summary judgment for the participants, finding that NCR’s lump-sum payments adversely affected the accrued benefits of at least some participants, in violation of the plan language. The court ordered NCR to pay the difference between the lump sums and the cost of replacement annuities, plus prejudgment and postjudgment interest.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s summary judgment order de novo. The Eleventh Circuit held that the plan language was unambiguous and did not permit NCR to unilaterally replace life annuities with lump sums that reduced the value of accrued benefits for any participant. The court affirmed the district court’s judgment, including the remedy of requiring NCR to pay the cost of replacement annuities and awarding prejudgment interest. View "Hoak v. NCR Corp." on Justia Law

An employee of the Department of Veterans Affairs began experiencing respiratory issues at work, which she attributed to the building environment. Over several years, she requested various accommodations, including changes to her work schedule, relocation of her workstation, and the use of air purifiers. The Department provided some accommodations, but the employee found them ineffective. In 2012, she was diagnosed with breast cancer and submitted a Family and Medical Leave Act (FMLA) form to request leave for treatment. Later, she learned that a union steward had been informed of her cancer diagnosis by a human resources manager, which she had not expected. After returning to work, she continued to request further accommodations, eventually being allowed to work from home full-time.The United States District Court for the Middle District of Florida granted summary judgment in favor of the Department on all claims, including disability discrimination, failure to accommodate, unlawful disclosure of medical information, and retaliation or hostile work environment. The court found that the Department had provided reasonable accommodations, that there was no evidence of discrimination or retaliation, and that the employee had not shown a tangible injury from the alleged disclosure of her medical information.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s summary judgment on the claims of disability discrimination, failure to accommodate, retaliation, and hostile work environment. The appellate court agreed that the Department had made reasonable efforts to accommodate the employee and that her dissatisfaction with the accommodations did not amount to a legal violation. However, the Eleventh Circuit reversed the summary judgment on the unlawful disclosure claim, holding that requiring medical information for FMLA leave constituted an employer inquiry under the Rehabilitation Act, and that there were genuine issues of fact as to whether confidential medical information was improperly disclosed and whether the employee suffered a tangible injury as a result. The case was remanded for further proceedings on the unlawful disclosure claim. View "Mullin v. Secretary, Department of Veterans Affairs" on Justia Law

Perfection Bakeries Inc. paid into the Retail, Wholesale and Department Store International Union’s Industry Pension Fund for its employees in Michigan and Indiana. The company later ceased contributions, first in Michigan and then in Indiana, incurring "withdrawal liability" under the Multiemployer Pension Plan Amendments Act of 1980. The Fund calculated this liability using a four-step formula outlined in 29 U.S.C. § 1381. Perfection Bakeries challenged the Fund's calculation, arguing that a specific calculation was performed at the wrong step.The United States District Court for the Northern District of Alabama reviewed the case. The district court granted summary judgment in favor of the Fund, holding that the statutory text unambiguously required the credit to be applied as part of the second adjustment step.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's judgment, agreeing that the Fund correctly applied the partial-withdrawal credit at step two of the four-step formula. The court concluded that the statute's language and structure supported the Fund's interpretation, which incorporated all of section 1386, including the credit for previous partial withdrawals, at step two. The court found that this interpretation was consistent with the statutory context and the repeated cross-references to section 1386 throughout the four-step formula. The court rejected Perfection Bakeries' arguments, including the contention that the partial-withdrawal credit should be applied after all four steps, and upheld the Fund's calculation method. View "Perfection Bakeries Inc v. Retail Wholesale & Dept Store International Union" on Justia Law

Jeanne Weinstein, a former server at The Ridge Great Steaks & Seafood, filed a collective action complaint alleging that the restaurant and its operator, Stephen Campbell, violated the Fair Labor Standards Act (FLSA) by not meeting the federal minimum wage requirement. The Ridge paid servers and bartenders $2.15 per hour, supplementing their income with tips to meet the $7.25 minimum wage. The Ridge also required servers and bartenders to contribute 3% of their gross food sales to a tip pool, which was used to pay support staff. Any excess tips were supposed to be distributed to bartenders, but there were inconsistencies in the record-keeping and distribution process.The United States District Court for the Northern District of Georgia granted unopposed motions to voluntarily dismiss five opt-in plaintiffs. The court also ruled partially in favor of the defendants on summary judgment, finding that the tip pool funds were not distributed to non-tipped employees. The remaining issue for trial was whether the defendants retained any portion of the tip pool funds.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's judgment, holding that Rule 41(a) permits the dismissal of a single plaintiff in a multiple-plaintiff case if all claims brought by that plaintiff are dismissed. The court also found no error in the district court's conclusion that the defendants did not retain any of the extra tips and operated a lawful tip pool within the parameters of the FLSA. Consequently, the defendants successfully asserted the tip credit defense, and the plaintiffs could not prevail on their minimum wage claim. View "Weinstein v. 440 Corp." on Justia Law

Dr. Joseph Jimenez, a former medical officer for the Federal Bureau of Prisons (BOP), alleged race and national origin discrimination, retaliation under Title VII of the Civil Rights Act of 1964, and disability discrimination under the Rehabilitation Act. Dr. Jimenez, who identifies as Hispanic, claimed that his employer required him to work as a correctional officer while non-Hispanic doctors were exempt. He also alleged that the BOP denied him a reasonable accommodation for his mental health conditions.The district court dismissed Dr. Jimenez’s Title VII claims related to certain adverse employment actions for failure to exhaust administrative remedies. The court granted summary judgment to the BOP on the remaining Title VII claims, finding no evidence of discriminatory or retaliatory motives. The court later dismissed Dr. Jimenez’s Rehabilitation Act claim for lack of subject-matter jurisdiction, rejecting his attempt to correct a citation error in his complaint.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decisions. The appellate court held that Dr. Jimenez failed to exhaust administrative remedies for his claims related to the denial of bonuses and failure to promote. The court also found that Dr. Jimenez did not present sufficient evidence to show that his race, national origin, or protected activity influenced the BOP’s actions. Additionally, the court upheld the dismissal of the Rehabilitation Act claim, agreeing that the citation error was not a mere scrivener’s error and that Dr. Jimenez did not demonstrate good cause to amend his complaint after the scheduling order deadline. View "Jimenez v. Acting United States Attorney General" on Justia Law

Ka’Toria Gray filed a lawsuit against her former employer, Koch Foods of Alabama, LLC (Ala-Koch), its parent company Koch Foods, Inc., and former Ala-Koch employees Melissa McDickinson and David Birchfield, alleging harassment. The jury found in favor of Koch Foods and Ala-Koch on all claims, in favor of Birchfield and McDickinson on Gray’s claims of invasion of privacy and outrage, and in favor of Gray on her claims for assault and battery, awarding her $50,000 in total damages.The United States District Court for the Middle District of Alabama denied all parties' motions for judgment as a matter of law (JMOL) and entered a final judgment consistent with the jury verdict. The court also awarded costs to Gray against Birchfield and McDickinson and to Koch Foods and Ala-Koch against Gray.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court’s denial of Birchfield and McDickinson’s renewed motion for JMOL on the assault and battery claims, finding sufficient evidence to support the jury’s verdict. The court also upheld the punitive damages awarded to Gray, concluding that the evidence met the clear and convincing standard required under Alabama law.The court rejected Gray’s argument for a new trial on her Title VII sexual harassment claim, noting that she waived her right to contest the verdicts as inconsistent by not objecting before the jury was discharged. The court also affirmed the district court’s grant of summary judgment on Gray’s constructive discharge claim, as the jury’s verdict on the hostile work environment claim precluded her constructive discharge claim.Finally, the court affirmed the district court’s prevailing party determinations, awarding costs to Gray against Birchfield and McDickinson and to Koch Foods and Ala-Koch against Gray. The court found no abuse of discretion in these awards. View "Gray v. Birchfield" on Justia Law

Laurence Bonday, a former employee of Nalco Company LLC, filed an arbitration demand against Nalco, alleging that the company violated its severance plan by demoting him without offering severance pay. Nalco argued that a court needed to determine the scope of the arbitration agreement before proceeding. However, the arbitrator concluded that Bonday’s severance claim fell outside the scope of the arbitration agreement and awarded him nothing on that claim. Instead, the arbitrator awarded Bonday $129,465.50 on an ERISA discrimination claim that he never raised.Nalco moved to vacate the arbitration award, arguing that the arbitrator exceeded her powers by deciding the scope of the arbitration agreement and awarding relief on a claim Bonday never made. The United States District Court for the Middle District of Florida granted Nalco's motion, concluding that the arbitrator exceeded her powers by interpreting the scope of the arbitration agreement and awarding relief on an unraised ERISA discrimination claim.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the arbitrator exceeded her powers by granting relief on an ERISA discrimination claim that Bonday did not submit for arbitration. The court emphasized that an arbitrator can only bind the parties on issues they have agreed to submit and that the arbitrator's decision to award relief on an unsubmitted claim was beyond her authority. The court did not address the district court's first reason for vacating the award, as the second reason was sufficient to affirm the decision. View "Nalco Company LLC v. Bonday" on Justia Law

Katie Wood, a transgender woman teaching at a public high school in Florida, challenged the enforcement of Fla. Stat. § 1000.071(3), which prohibits her from using the honorific “Ms.” and the gendered pronouns “she,” “her,” and “hers” in exchanges with students during class time. Wood argued that this statute violated her First Amendment right to free speech and sought a preliminary injunction to prevent its enforcement.The United States District Court for the Northern District of Florida granted Wood a preliminary injunction, finding that she had shown a substantial likelihood of success on the merits of her First Amendment claim. The district court reasoned that Wood’s use of her preferred honorific and pronouns constituted speech as a private citizen on a matter of public concern, and that her interest in expressing her gender identity outweighed the state’s interest in promoting workplace efficiency.The United States Court of Appeals for the Eleventh Circuit reviewed the case and disagreed with the district court’s findings. The appellate court held that Wood had not demonstrated a substantial likelihood that Fla. Stat. § 1000.071(3) infringed her free speech rights. The court concluded that when Wood used her preferred honorific and pronouns in the classroom, she was speaking as a government employee, not as a private citizen. Consequently, her speech was not protected under the First Amendment in this context. The Eleventh Circuit vacated the preliminary injunction and remanded the case to the district court for further proceedings consistent with its opinion. View "Wood v. Florida Department of Education" on Justia Law

Richard Hicks and his wife, Jocelyn Hicks, filed a lawsuit seeking monetary damages after Richard was injured by a vehicle driven by Gregory Middleton, an employee of Marine Terminals Corporation - East, d.b.a. Ports America. The incident occurred at the Port of Savannah, where both Hicks and Middleton worked as longshoremen. Middleton struck Hicks with his personal vehicle while allegedly on his way to retrieve work-related documents called "game plans."The United States District Court for the Southern District of Georgia granted summary judgment in favor of Ports America. The court ruled that Ports America could not be held vicariously liable for Middleton's actions because Middleton was not acting within the scope of his employment when the incident occurred. The court determined that Middleton was engaged in a personal activity, specifically commuting, and had not yet begun his work duties for Ports America.The United States Court of Appeals for the Eleventh Circuit reviewed the case and vacated the district court's grant of summary judgment. The appellate court found that there were genuine issues of material fact regarding whether Middleton was acting in furtherance of Ports America's business and within the scope of his employment when the incident occurred. The court noted that a jury could reasonably infer that Middleton's actions, including driving to retrieve the game plans, were part of his job responsibilities and thus within the scope of his employment. The case was remanded for further proceedings to allow a jury to determine these factual issues. View "Hicks v. Middleton" on Justia Law