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

Plaintiff filed suit against TitleMax for unpaid overtime under the Fair Labor Standards Act (FLSA), 29 U.S.C. 216(b). The court held that if an employer knew or had reason to know that its employee underreported his hours, it cannot escape FLSA liability by asserting equitable defenses based on that underreporting. To hold otherwise would allow an employer to wield its superior bargaining power to pressure or even compel its employees to underreport their work hours, thus neutering the FLSA's purposeful reallocation of that power. In this case, plaintiff has worked overtime without pay and TitleMax knew or should have known he worked overtime where plaintiff's supervisor both encouraged artificially low reporting and squelched truthful timekeeping. The district court erred in applying equitable defenses based on plaintiff's misconduct to totally and entirely bar his FLSA claim. When the district court did this, it went beyond what the Supreme Court approved in McKennon v. Nashville Banner Publishing Co., thereby interfering with the FLSA's statutory scheme. Accordingly, the court reversed the grant of summary judgment in favor of TitleMax and remanded. View "Bailey v. TitleMax of Georgia, Inc." on Justia Law

Plaintiff filed suit against Lilly, alleging that Lilly did not make certain incentive payments due to plaintiff and other similarly situated individuals who had been employed at the company. Lilly removed to district court under the Class Action Fairness Act (CAFA), 28 U.S.C. 1332(d), but the district court remanded to state court. The court concluded that the district court did not clearly err in finding that Lilly had not met its burden of establishing by a preponderance of the evidence that the amount in controversy exceeded $5,000,000, as required by federal subject matter jurisdiction under CAFA. Lilly failed to provide estimates of incentive payments that correspond to the categories of incentive payments identified in the complaint; failed to recognize and build into the calculus that not all of the Fixed Duration Employees were alleged to have been denied all of the incentive payments; and failed to provide any meaningful guidepost for the payment estimates it had provided. Accordingly, the court affirmed the judgment. View "Dudley v. Eli Lilly and Co." on Justia Law

Plaintiffs, fifty-four fire suppression lieutenants employed by the City, filed suit under the Fair Labor Standards Act (FLSA), 29 U.S.C. 207(a), contending that they are entitled to overtime compensation. The jury rejected plaintiffs' claims. The court found that, in light of the evidence presented during trial, the issues that the jury determined were properly before it and that the jury's conclusions on those issues were reasonable. The court also found that the district court sufficiently instructed the jury before the jury reached its verdict denying plaintiffs' claims. Accordingly, the court affirmed the judgment. View "Watkins v. Montgomery, AL" on Justia Law

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