Koren v. Schl. Bd. of Miami-Dade County, et al.

Petitioner sought review of the Third District's summary dismissals of his unfair labor practice (ULP) claim. The court concluded that because it found that the actions alleged in petitioner's claim were sufficient to establish a prima facie violation of Florida Statute 447.501, the court concluded that the Third District incorrectly affirmed the Public Employees Relations Commission's dismissal of petitioner's charges; the totality of the circumstances alleged in petitioner's charge were sufficient to demonstrate prima facie evidence that he suffered from an adverse employment action; petitioner's allegations regarding his transfer provided sufficient evidence of adverse employment action to survive summary dismissal; and petitioner sufficiently alleged a causal link between the protected activity and the adverse employment action.