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

Plaintiff filed suit under the Fair Labor Standards Act (FLSA), 29 U.S.C. 207(a)(1), against her employer and subsequently settled the action without an attorney. Applying Lynn's Food Stores, Inc. v. United States, the court concluded that the agreement between the parties was not made under the supervision of the Secretary of Labor, so it was valid only if the district court entered a "stipulated judgment" approving it. In this case, the district court did enter a judgment but it was not a stipulated one. Accordingly, the district court should not have granted the opposed motion to approve and enforce the settlement agreement and dismissed the complaint. Accordingly, the court vacated and remanded for further proceedings. View "Nall v. Mal-Motels, Inc., et al." on Justia Law

ComTran petitioned for review of the Commission's final decision holding that ComTran violated standards under the Occupational Safety and Health Act (OSHA), 29 U.S.C. 651 et seq., when one of its supervisors was caught digging in a six-feet deep trench with an unprotected five-feet high "spoil pile" at the edge of the excavation. The court concluded that it was not appropriate to impute a supervisor's knowledge of his own violative conduct to his employer under the Act, thereby relieving the Secretary of her burden to prove the "knowledge" element of her prima facie case. Therefore, the Commission acted arbitrarily, capriciously, and otherwise not in accordance with the law. Accordingly, the court granted the petition, reversed the decision, and remanded for further proceedings. View "ComTran Group, Inc. v. U.S. Dept. of Labor" on Justia Law

Plaintiff sued her employer, the Alabama Board of Pardons and Paroles, originally alleging federal civil rights and state age discrimination claims. The Board then removed the case to federal court, invoking the district court's subject-matter jurisdiction under 28 U.S.C. 1331. After removal, plaintiff amended her complaint alleging various federal and state law claims. The district court dismissed all of plaintiff's federal claims other than the Age Discrimination in Employment Act, 29 U.S.C. 621-634, claim for failure to state a claim. The court concluded that the Board waived its defense of immunity from litigation in federal court when it removed to federal court, but the Board did not waive its immunity from ADEA liability. Accordingly, the court affirmed the district court's judgment. View "Stroud v. McIntosh, et al." on Justia Law

Plaintiffs appealed the district court's order on summary judgment holding that they were "independent contractors," instead of "employees," and were not entitled to overtime and minimum wage protections under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq. The court concluded that, viewing the facts most favorably towards plaintiffs and with all justifiable inferences drawn in their favor, plaintiffs were "employees" under the FLSA. Because there were genuine issues of material fact, and because plaintiffs were "employees," the district court erred in granting summary judgment to Knight. Accordingly, the court reversed the district court's summary judgment order and remanded for further proceedings. The court affirmed, however, the district court's denial of plaintiffs' motions to reopen the opt-in period, for protective order, for corrective notice, and for sanctions. View "Scantland, et al. v. Knight, Inc., et al." on Justia Law

Plaintiffs, the superintendent of education and her assistant superintendent, filed suit claiming that the board and its members in both their official and individual capacities terminated the superintendent and demoted the assistant superintendent in retaliation for public comments plaintiffs made about local tax policy. The court concluded that it had jurisdiction over the appeal of the denial of qualified immunity, but lacked jurisdiction over the appeal of the board and its officials. Accordingly, the court dismissed the appeal of the board and its officials for lack of jurisdiction and reversed the denial of qualified immunity for the individual members of the board. View "Leslie, et al. v. Hancock County Board of Education, et al." on Justia Law

U.S. Steel appealed the award of benefits to plaintiff, the widow of a deceased miner, under the black lung benefits program. The Benefits Review Board affirmed the award, concluding that plaintiff did not need to show the cause of her husband's death. The court concluded that 30 U.S.C. 932(l), as amended by section 1556(b) of the Patient Protection and Affordable Care Act, Pub. L. No. 111-148, 1556(b), 124 Stat. 119, 260, eliminated the need for survivors who could meet its requirements to prove that their associated miners died due to black lung disease; it applied retroactively to survivors' claims filed in the specified period; and this retroactive application did not violate the Due Process Clause of the Fifth Amendment. Accordingly, the court denied U.S. Steel's petition to review the Board's ruling. View "U.S. Steel Mining Co., LLC v. Director, OWCP, et al." on Justia Law

Plaintiff claimed that defendants failed to pay her the minimum wage under federal and state law while she worked as a nanny for them. On appeal, plaintiff challenged the district court's judgment concluding that defendants did not willfully violate federal minimum wage laws, 28 U.S.C. 206(a), and the minimum wage laws of Florida, Fla. Const. Art. 10, section 24(e), and that plaintiff was not entitled to liquidated damages under the Fair Labor Standards Act, 29 U.S.C. 216. The court vacated and remanded, concluding that plaintiff introduced sufficient evidence for a reasonable jury to find that defendants willfully violated the minimum wage laws and the district court could not rule on plaintiff's motion for liquidated damages before the jury decided whether defendants willfully violated the minimum wage laws. View "Davila v. Menendez, et al." on Justia Law

This case involved Executive Order 11-58 (EO), which mandated two types of suspicionless drug testing: random testing of all employees at state agencies within the Governor of Florida's control, and pre-employment testing of all applicants to those agencies. In this case, the district court declared the EO unconstitutional as to all current state employees. This relief swept too broadly, enjoined both constitutional and unconstitutional applications of the EO, and did so without examining the specific job categories to be tested. What the Supreme Court's case law required, in contrast, was that the trial court balance the governmental interests in a suspicionless search against each particular job category's expectation of privacy. Accordingly, the court vacated the district court's order granting summary judgment to the Union and denying summary judgment to the State. On remand, the State must meet its burden of demonstrating important special needs on a job-category-by-category basis. View "American Federation of State, County, and Municipal Emp'ees Council 79 v. Scott" on Justia Law

Plaintiff sued Coca-Cola, his employer, alleging that the psychiatric/psychological fitness-for-duty evaluation he was required to undergo violated 42 U.S.C. 12112(d)(4)(A), a provision of the Americans with Disabilities Act (ADA). The court affirmed the district court's grant of summary judgment for Coca-Cola, concluding that the evaluation was both job-related and consistent with business necessity and, therefore, permissible under the ADA. View "Owusu-Ansah v. The Coca-Cola Co." on Justia Law

This case stemmed from a dispute involving an administrative complaint filed by the Board against Mardi Gras, claiming that Mardi Gras unlawfully discharged employees who were involved in a union organizing campaign on behalf of the Union. The Board appealed from the district court's decision to deny the Board temporary injunctive relief pending a final order from the Board in administrative proceedings. The court held that the district court did not abuse its discretion in concluding that the temporary reinstatement of six discharged employees was not a "just and proper" form of relief requested by the Board under section 10(j) of the National Labor Relations Act, 29 U.S.C. 160(j). Accordingly, the court affirmed the judgment. View "National Labor Relations Board v. Hartman and Tyner, Inc., et al" on Justia Law