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

Plaintiff filed suit alleging that defendant reduced and ultimately terminated plaintiff's consulting work as a forensic psychologist for the Broward County Public Defender's office in retaliation for plaintiff's constitutionally protected testimony about a Florida state court judge. The court vacated the judgment of the district court granting summary judgment to defendant where a reasonable fact-finder could find that defendant was subjectively motivated to reduce and did reduce plaintiff's work because of his testimony and plaintiff's testimony was also a motivating factor behind defendant removing him from the wheel rotation system; affirmed the judgment of the district court granting qualified immunity to defendant in his individual capacity where there was evidence of both lawful and unlawful motivations for defendant's actions and preexisting law did not dictate that the merits of the case must be decided in plaintiff's favor; and remanded for further proceedings. View "Brannon, et al. v. Finklestein" on Justia Law

In 2000, physicians and physician associations imitated a group of class actions against various providers of health plans, which were consolidated into a multidistrict litigation. This appeal involves this complex, twelve-year-old multidistrict litigation, a related multidistrict litigation pending in another federal district, and whether the district court reasonably interpreted the Settlement Agreement in the first action. The court affirmed the Injunction as to plaintiffs' Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961, and antitrust claims and as to the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1001 et seq., claims based on the denial or underpayment of benefits following the Settlement Agreement's Effective Date. On remand, the district court will need to determine which of plaintiffs' ERISA claims fall on the permissible side of the line, and reconsider the assessment of sanctions. View "Medical Assoc. of GA, et al. v. Wellpoint, Inc." on Justia Law

This appeal involved complaints of a racially hostile work environment at a shipyard in Mobile, Alabama, owned by Austal. At issue on appeal was whether an employee may rely on evidence of racial harassment of which he is not personally aware to prove that his work environment was objectively hostile. The court held that an employee alleging a hostile work environment cannot complain about conduct of which he was oblivious for the purpose of proving that his work environment was objectively hostile. In this instance, the court concluded that seven of the employees presented sufficient evidence that their work environments were objectively hostile, and vacated the summary judgment against them. The court affirmed the summary judgment against the remaining six employees and affirmed the two jury verdicts. View "Adams, et al. v. Austal, U.S.A., L.L.C." on Justia Law

Plaintiff appealed the district court's grant of Southern Nuclear's motion for summary judgment as to his claim of discrimination based on the misuse of information obtained during a required medical evaluation, in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(d)(3)(C). The court joined the Seventh and Tenth Circuits in holding that an individual seeking relief under section 12112(d)(3)(C) must demonstrate that he is a qualified individual with a disability. Here, plaintiff admitted at oral argument that he could not demonstrate that he is an individual with a disability. Accordingly, the court affirmed the judgment of the district court. View "Wetherbee v. Southern Nuclear Operating Co." on Justia Law

Plaintiff appealed pro se the district court's grant of summary judgment in favor of his former employer, G4S, on his claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2(a)(1) and 2000e-3(a), and 42 U.S.C. 1981. Count I of the complaint alleged that G4S discriminated against plaintiff based on his national origin and Count III alleged that G4S discriminated against him because of his race. Counts II and IV alleged that G4S terminated plaintiff's employment because he filed a complaint of discrimination with its Human Resources department. The court affirmed the district court's judgment on Counts II and IV but vacated its judgment on Counts I and III. The court remanded for the district court to consider whether Counts I and III presented claims sufficient to withstand summary judgment where the district court should bear in mind that those counts asserted the "status-based" category of discrimination prohibited by Title VII. Accordingly, the court affirmed in part, vacated in part, and remanded in part. View "Barthelus v. G4S Government Solutions, Inc." on Justia Law

Plaintiff, chief mate of the "Sealand Pride," filed suit under the Jones Act, 46 U.S.C. 30104, alleging that his employer, Maersk, negligently saddled him with excessive duties and duty time such that he was overworked to the point of fatigue. The court concluded that the Jones Act does not allow seaman to recover for injuries caused by work-related stress because work-related stress is not a physical peril. Therefore, the district court erred when it denied the motion of Maersk for a judgment in its favor as a matter of law. Under Consolidated Rail Corp. v. Gottshall, plaintiff's complaint of an injury induced by overwork was not cognizable under the Jones Act. Accordingly, the court vacated the judgment awarding plaintiff damages. The court reversed the denial of the motion of Maersk for a judgment as a matter of law and rendered the judgment in favor of Maersk. View "Skye v. Maersk Line" on Justia Law

Plaintiff filed suit against her former employer, Hartford, alleging claims of interference and retaliation under the Family Medical Leave Act of 1993 (FMLA), 29 U.S.C. 2601, et seq. The court rejected plaintiff's interpretation of "prospective" FMLA rights and concluded that section 825.220(d)'s prohibition of "prospective" waiver means only that an employee may not waive FMLA rights, in advance, for violations of the statute that have yet to occur. Here, the conduct plaintiff complained about all happened before she signed the Severance Agreement. In signing the agreement and accepting her severance benefits, plaintiff settled claims based on past employer conduct, and so the district court did not err in concluding that the agreement was valid and that it entitled Hartford to judgment as a matter of law. The court also concluded that the district court did not err in concluding that plaintiff executed the Severance Agreement knowingly and voluntarily. Accordingly, the court affirmed the judgment of the district court. View "Paylor v. Hartford Fire Ins. Co." on Justia Law

Plaintiff filed suit against his former employer, CRI, claiming discrimination under the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq., the Age Discrimination and Employment Act of 1967 (ADEA), 29 U.S.C. 621, and the Florida Civil Rights Act (FCRA), Fla. Stat. 760.10. Congress made significant changes to the ADA by enacting the ADA Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553. The court concluded that, in light of these recent amendments to the ADA, plaintiff submitted sufficient evidence on his ADA and FCRA disability claims to make out a prima facie case; the district court erroneously applied the prima facie standard created for reduction-in-force cases to plaintiff's age discrimination claims; and, therefore, the court vacated the district court's grant of summary judgment in favor of CRI, remanding for further proceedings. View "Mazzeo v. Color Resolutions Int'l, LLC" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of FedEx on his disability discrimination claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Florida Civil Rights Act (FCRA), Fla. Stat. 760.01 et seq. When plaintiff failed his Department of Transportation (DOT) medical examination due to his diabetes, FedEx withdrew plaintiff's job offer since he did not qualify for a Technician position. FedEx claimed that the Federal Motor Carrier Safety Regulations (FMCSRs) required it to do so. Plaintiff argued that by imposing a requirement that he must obtain a DOT medical card even though he would be a mechanic and not a commercial truck driver, FedEx violated the ADA and the FCRA, which prohibited an employer from using qualification standards that screen out people with disabilities. The court concluded that reasonable jurors could differ as to whether test-driving FedEx trucks was an essential function of the Technician position. The court also concluded that, the occasional test-driving of empty FedEx trucks in the Fort Myers area did not constitute transporting property or passengers in interstate commerce. Therefore, the FMCRs did not oblige FedEx to require plaintiff to obtain DOT medical certification to be "qualified" for the Technician position. The FMCRs did not afford FedEx a defense to plaintiff's disability discrimination claims. Accordingly, the court reversed and remanded for further proceedings. View "Samson v. Federal Express Corp." on Justia Law

Plaintiffs appealed the district court's order compelling arbitration and dismissing their complaint filed against defendants. At issue was whether the arbitration agreement, which waived an employee's ability to bring a collective action under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., was enforceable under the Federal Arbitration Act, 9 U.S.C. 1 et seq. The court concluded that, after examining the FLSA's text, legislative history, purposes, and Supreme Court precedent, it discerned no "contrary congressional command" that precluded the enforcement of plaintiffs' Arbitration Agreements and their collective action waivers. The court concluded that plaintiffs' reliance on the Supreme Court's 1945 decision in Brooklyn Savings Bank v. O'Neil was materially distinguishable from this case. Accordingly, the court affirmed the judgment of the district court. View "Walthour, et al. v. Chipio Windshield Repair, LLC, et al." on Justia Law