Justia Labor & Employment Law Opinion SummariesArticles Posted in U.S. 11th Circuit Court of Appeals
Jurich, et al. v. Compass Marine, Inc.
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
Evans v. Books-A-Million
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
Booth, et al. v. Pasco Cty., FL, et al.
Plaintiffs filed suit against the County and Union, alleging violations of federal and state civil rights statutes. The jury found that the County subjected plaintiffs to fitness-for-duty examinations because of their grievances and charges against the County. The district court held that there was insufficient evidence to support this finding. The court disagreed, concluding that the jury was permitted to find that the desire to retaliate was a "but-for" cause of the County's decision; the district court did not abuse its discretion in rejecting plaintiffs' proposed jury instructions; and, even assuming that the restriction on the Union's speech was content-based, the court nevertheless rejected the Union's argument that the First Amendment immunizes it under the facts of this case. The court reversed the entry of judgment in favor of the County and ordered that judgment be entered against the County on the verdicts as returned. The court affirmed the judgment in all other respects. View "Booth, et al. v. Pasco Cty., FL, et al." on Justia Law
Hubbard v. Clayton Co. Sch. Dist., et al.
Plaintiff filed suit against the school district, claiming that he was retaliated against by the school district because he made public statements to the press regarding the accreditation investigation of the school district. Because plaintiff was not speaking pursuant to any official duties for the school district, bur rather was speaking in his capacity as president of the Georgia Association of Educators, the district court erred when it held that plaintiff's speech fell under the rule announced in Garcetti v. Ceballos. Accordingly, the court vacated the district court's order granting summary judgment in favor of the school district and remanded for further proceedings. View "Hubbard v. Clayton Co. Sch. Dist., et al." on Justia Law
Jarvela v. Crete Carrier Corp.
Plaintiff filed suit against his employer, alleging that the employer violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601, by terminating him based on his diagnoses of alcoholism. The court agreed with the employer that plaintiff was not qualified under DOT regulations to drive a commercial truck because he had a current clinical diagnosis of alcoholism. Because the court determined that plaintiff was not entitled to drive a commercial truck under the DOT regulations, the court need not address whether the employer's company policy also supported that determination. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the employer on the ADA claim. In regards to the FMLA claims, the court agreed with the district court's determination that plaintiff's interference claim failed because the employer would have discharged plaintiff regardless of his FMLA leave, and plaintiff's retaliation claim failed because he could not show that the employer's decision to terminate him was causally related to his FMLA leave. Accordingly, the court affirmed the district court's grant of summary judgment as to the FMLA claims. View "Jarvela v. Crete Carrier Corp." on Justia Law
Brannon, et al. v. Finklestein
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
Medical Assoc. of GA, et al. v. Wellpoint, Inc.
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
Adams, et al. v. Austal, U.S.A., L.L.C.
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
Wetherbee v. Southern Nuclear Operating Co.
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
Barthelus v. G4S Government Solutions, Inc.
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