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

Plaintiff sued the Union for damages caused by a work stoppage conducted by the Union in alleged violation of the collective bargaining agreement. The district court entered summary judgment without reaching the merits holding that the dispute was subject to arbitration under the contract. Plaintiff appealed. The court held that, in this case, the employee oriented grievance machinery in the parties' contract qualified and limited the universe of claims and grievances subject to arbitration, and the language negated the intention that the employer's claim for damages must be submitted to arbitration. Accordingly, the district court's grant of summary judgment was reversed and the case remanded for further proceedings.

Plaintiff filed a complaint seeking declaratory and injunctive relief pursuant to 42 U.S.C. 1983 for alleged violations of her rights under the Equal Protection Clause of the Fourteenth Amendment, claiming that defendant fired her from her job as an editor because of sex discrimination. Plaintiff also claimed that her constitutional rights were violated because defendant terminated her employment due to her medical condition, known as Gender Identity Disorder. The district court granted summary judgment to plaintiff on her sex discrimination claim and granted summary judgment to defendant on plaintiff's medical discrimination claim. Both parties timely appealed. The court held that a government agent violated the Equal Protection Clause's prohibition of sex-based discrimination when he or she fired a transgender or transsexual employee because of his or her gender non-conformity. The court also held that defendant had advanced no reason that could qualify as a governmental purpose, much less an "important" governmental purpose, and even less than that, a "sufficiently important government purpose" that was achieved by firing plaintiff because of her gender non-conformity. Therefore, the court affirmed the judgment of the district court granting summary judgment in favor of plaintiff on her sex-discrimination claim. In light of this decision, which provided plaintiff with all the relief she sought, there was no need to address plaintiff's cross-appeal.

Plaintiff sued his former employer for unpaid overtime and back wages pursuant to the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. 201 et seq., its implementing regulations, and Florida law for unpaid overtime and back wages. Plaintiff subsequently appealed the grant of summary judgment to the employer on plaintiff's FLSA claim and dismissal of his state law claim without prejudice, contending that material issues of fact precluded judgment and, alternatively, that, had the district court not limited his discovery as it did, he would have uncovered evidence that would have created material issues of fact. Plaintiff also appealed the district court's sanctions order against his attorney. Having found no error in the district court's discovery decisions, imposition of sanctions, or its order granting summary judgment in favor of the employer, the court affirmed the judgment of the district court.

Migrant workers who worked for defendant appealed a summary judgment in favor of defendant and against their complaint that defendant violated the Fair Labor Standards Act (Act), 29 U.S.C. 203(m). At issue was whether an employer that hired migrant farm workers through the H-2A visa program was entitled to wage credits under the Act for housing and meals that federal law required the employer to provide the workers. The court deferred to the Secretary of Labor's interpretation that defendant could not credit the cost of housing in the wages paid to the workers and agreed with defendant that it was entitled to wage credits for the costs of meals for the workers. The court also concluded that defendant was not liable under principles of agency law for the fees that third parties charged the workers related to their efforts to obtain employment with defendant. Accordingly, the court affirmed in part, reversed in part, and remanded.

This case arose when plaintiff, who was exposed to various chemicals during his employment with defendant and subsequently became legally blind in both eyes, sought workers compensation benefits under the Longshore and Harbor Workers' Compensation Act (LHWCA), 33 U.S.C. 901-950. At issue was which date - the date on which disability occurred, or the date one which the injured employee was awarded benefits for such disability - determined the maximum weekly rate of compensation for a permanently totally disabled employee who was "newly awarded compensation." The court applied long-standing principles of statutory construction and found that the maximum weekly rate of compensation was governed by the rate in effect at the time of the award. Therefore, the court reversed the decision of the district court and remanded for calculation of the sum to be paid.

This case stemmed from plaintiff's allegations that, while she was employed with defendant on one of its cruise ships, she was drugged by other employees, raped, and physically injured while she was unconscious, and when she reported to officials of the cruise line what had happened to her, they treated her with indifference and even hostility, failed to provide her with proper medical treatment on board, and interfered with her attempts to obtain medical treatment and counseling ashore. Plaintiff subsequently asserted five claims against defendant involving violations of the Jones Act, 46 U.S.C. 30104, or the general maritime law applicable to the Seaman's Wage Act, 46 U.S.C. 10313. Plaintiff's remaining five claims involved common law tort claims. At issue was whether plaintiff's claims fell within the scope of the arbitration clause in the crew agreement. The court held that the district court did not err in holding that Counts VI, VII, VIII, IX, and X of plaintiff's complaint did not fall within the scope of the arbitration provision where all five of these claims involved factual allegations about how the cruise line and its officials treated plaintiff after learning that she had been raped, including allegations that she was kept on the ship against her will, that she was prevented from getting medical attention off the ship, that her rape kit was destroyed in the incinerator, and that her confidentiality as a rape victim was intentionally violated. The court held, however, that the remaining five counts arose directly from her undisputed status as a "seaman" employed by defendant and fell within the scope of the arbitration provision. Therefore, the district court erred in denying defendant's motion to compel arbitration for Counts I, II, III, IV, and V.

Plaintiff appealed the district court's enforcement of the arbitration agreement in his employment contract with defendant. Plaintiff sued defendant on a single count of Jones Act negligence, pursuant to 46 U.S.C. 30104, claiming that defendant breached its duty to supply him with a safe place to work. The court held that, given the United Nations Convention on Recognition and Enforcement of Foreign Arbitral Awards (New York Convention) and governing Supreme Court and Circuit Court precedent, the court must enforce the arbitration clause in plaintiff's employment contract, at least at this initial arbitration-enforcement stage. Therefore, after review and oral argument, the court affirmed the district court's order compelling arbitration of plaintiff's Jones Act negligence claim.

Appellant appealed the district court's judgment denying it sovereign immunity protection as an arm of the state of Alabama. Appellee contended that appellant was sufficiently independent from the state of Alabama, that it was not entitled to Eleventh Amendment immunity, and that her claim under the Fair Labor Standards Act, 29 U.S.C. 201 et seq., should be allowed to continue. At issue was whether appellant was an arm of the state. The court held that at this time, appellant was not entitled to sovereign immunity protection as an arm of the state of Alabama where the state court found that an entity was not an arm of the state. Accordingly, the court affirmed the judgment of the district court.

This case concerned the termination of an employee, plaintiff, in the wake of an investigation into the disappearance of approximately $58,000 from a branch of Washington Mutual Bank (defendant). Plaintiff asserted that defendant unlawfully asked him to submit to a polygraph test and unlawfully failed to notify plaintiff of his right to continue his employer-provided health insurance for a period after his termination. The court held that because defendant requested plaintiff to submit to a polygraph test in connection with an "ongoing investigation" of a specific incident in which defendant had a "reasonable suspicion" that plaintiff was involved, the district court did not err in granting summary judgment for defendant on plaintiff's Employee Polygraph Protection Act (EPPA), 29 U.S.C. 2002(1), claim. The court held, however, that the district court erred in granting summary judgment for defendant on plaintiff's improper notice claim under the Consolidated Omnibus Budget Reconciliation Act (COBRA) 29 U.S.C. 1163(2), 1166, where the court should have considered the claims on the merits because it was timely filed. Accordingly, the court affirmed in part, vacated in part, and remanded for further proceedings.

This negligence suit under Georgia law stemmed from an injury plaintiff suffered as he unloaded freight from a railcar in July 2005. On appeal, plaintiff asserted that the district court erred by granting summary judgment to defendants because there were triable issues as to whether defendants were negligent in failing to regularly inspect or maintain the bulkhead door. The court held that the district court was correct in granting defendants summary judgment where plaintiff presented no evidence from which a jury could infer that defendants' omissions, even if negligent, were a proximate cause of his injury, an essential element of his negligence claim under Georgia law. Accordingly, the judgment of the district court was affirmed.