Justia Civil Rights Opinion Summaries

Plaintiff appealed the district court's grant of summary judgment in a class action suit alleging that Broward County's employee wellness program violated the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq. Plaintiff alleged that the wellness program's biometric screening and online Health Risk Assessment questionnaire violated the ADA's prohibition on non-voluntary medical examinations and disability-related inquiries. The court held that the district court did not err in finding as a matter of law that the wellness program was a "term" of Broward County's group health insurance plan, such that the wellness program fell within the ADA's safe harbor provision.

The issue before the Eleventh Circuit centered on the grant of qualified immunity to two social workers who violated clearly established federal rights during an investigation of alleged child abuse. After Plaintiff-Appellant Stephen Loftus petitioned a Florida court to help him protect his two children from his allegedly abusive former wife, social worker and Defendant-Appellee Ester Clark-Moore, investigated the safety and welfare of Loftus's children, Savonna and Dylan. In the course of her investigation, Clark-Moore allegedly interviewed Savonna without Loftus's consent, and Clark-Moore's supervisor, Myra Ferguson, allegedly twice threatened to remove both children from Loftus's care. Loftus filed a civil complaint that the social workers had violated Savonna's right to be free from unreasonable seizures and the family's right to be free from governmental interference. Upon review, the Eleventh Circuit concluded that because the social workers did not violate any clearly established federal civil rights in the investigation that Loftus had invited, it affirmed the dismissal of Loftus's complaint against them.

Plaintiff Cristobal Ramirez brought a Title VII employment discrimination case and represented himself in district court. He survived summary judgment (in part) and proceeded to trial. At the conclusion of the presentation of his evidence, Defendant, Secretary of the U.S. Department of Transportation (DOT), orally moved for judgment as matter of law. The district court granted the motion on the sole ground that Plaintiff's claim was time-barred because he did not contact an Equal Employment Opportunity (EEO) Counselor within forty-five days of the alleged discrimination. Plaintiff, still appearing in the case pro se, appealed to the Eleventh Circuit where he was appointed counsel. Upon review, and with the benefit of counseled briefing and oral argument, the Eleventh Circuit reversed the district court. Because the EEOC found that there was a satisfactory reason for Plaintiff's delay in making initial contact with the EEO Counselor, and because the DOT did not challenge that finding, but, instead, undertook investigation and conciliation, the DOT and the district court were bound by the EEOC’s finding.

Appellants Charity Benton, Patricia A. Smith, and Gail Zucker appealed the district court's order remanding Appellee Orvel W. Lloyd's civil rights lawsuit to Florida state court. Appellants properly removed the case to the Middle District of Florida. Although the district court recognized Appellants' right to remove the action to federal court, the district court determined that allowing Lloyd to proceed in federal court would contravene the Prison Litigation Reform Act ("PLRA") which bars "three strikes" prisoner litigants like Lloyd from bringing civil suits in federal court as indigents. After reviewing the district court's order and the parties' briefs, and having had the benefit of oral argument, the Eleventh Circuit vacated the district court's order and remand this case for further proceedings.

Defendant-Appellee Dorothy Collier came home from work early one day to find Plaintiff-Appellant Larry Butler alone and naked with her teenaged daughter. He hid in a closed when he heard someone entering the house. As it happened, Defendant worked as a corrections officer for a described "boot camp facility for minors" run by Defendant-Appellee Palm Beach County Sheriff's Office. She wore her uniform and gun belt with pistol. When she entered the room, saw her naked daughter and demanded an explanation, she discovered Plaintiff hiding in the closet. Defendant drew her gun. Plaintiff tried to explain that the daughter invited her to the house, but Defendant insisted he broke in. Defendant handcuffed the still-naked Plaintiff, and forced him to his knees. Defendant allowed Plaintiff to get dressed (at all times, under gunpoint), and eventually Plaintiff was allowed to leave the house. But before he had time to leave Defendant "warned him about the consequences of filing charges or even 'thinking about' reporting the incident." She told Butler that if he reported what had happened, she "would submit a report to discredit him and would engage in some 'creative writing' if necessary to justify the filing of charges against him for trespassing on the property." Despite those threats, Plaintiff eventually reported the incident to law enforcement. Plaintiff filed suit in Florida against Defendant individually and in her official capacity as a corrections officer, and the Palm Beach County Sheriff for violation of his civil rights under 42 U.S.C. 1983. The case was removed from state to federal court. The district court concluded that the allegations in the amended complaint showed no more than Defendant acting as a private individual because nothing she allegedly did to Plaintiff relied on or invoked her authority as a law enforcement officer. For that reason, the court dismissed Plaintiff's 1983 claims. Upon review, the Eleventh Circuit affirmed: "If the allegations are true, [Defendant's] treatment of [Plaintiff] was badder than old King Kong and meaner than a junkyard dog. She might even have acted like the meanest hunk of woman anybody had ever seen. Still, the fact that the mistreatment was mean does not mean that the mistreatment was under color of law."

Plaintiffs appealed from the district court's dismissal of their amended complaint against Florida government defendants, SBHD, AHCA, and DCF. Plaintiffs alleged that defendants' billing practice violated both 42 U.S.C. 1396a(a)(25)(C), the "balance billing" provision of the federal Medicaid Act, and a similar Florida statute. The court concluded that section 1396a(a)(25)(C) did not confer upon plaintiffs a federal right enforceable under 42 U.S.C. 1983 and therefore, affirmed the district court's decision to dismiss the amended complaint.

Plaintiff, an African -American, brought this action against UPSF, his former employer, alleging that he had been subjected to a racially hostile work environment in violation of 42 U.S.C. 1981 and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2. The district court entered summary judgment in favor of UPSF and plaintiff timely appealed. The court concluded that a reasonable trier of fact could conclude that the events alleged by plaintiff created an objectively hostile work environment and therefore, the court vacated the judgment and remanded for further proceedings.

The Chapter 7 trustee for the bankruptcy estate of Stacey Williams appealed the district court's grant of summary judgment to Gate Gourmet on Williams' claim of pregnancy discrimination, race discrimination, retaliation, and state law negligence. The court held that the district court improperly granted summary judgment on Williams' Title VII, 42 U.S.C. 2000e et seq., claim for pregnancy discrimination because Williams had presented enough circumstantial evidence to allow a jury to reasonably infer that her supervisor's action in terminating her because of her pregnancy and his inaction in not attempting to find her a light-duty job were a violation of Title VII. The district court properly granted summary judgment to Gate Gourmet on Williams' Title VII and 42 U.S.C. 1981 race discrimination claims because she had not shown a genuine issue of material fact about whether Gate Gourmet intentionally discriminated against her based on her race. Summary judgment was improperly granted against Williams' Title VII and section 1981 retaliation claims because there was a reasonable inference that the statutorily protected filing of and refusal to settle the EEOC charge caused Gate Gourmet to deny Williams a light-duty position, which was a materially adverse action. The court affirmed in part, reversed in part, vacated in part, and remanded.

This appeal and cross-appeal arose from a jury verdict and award of damages and injunctive relief in favor of plaintiffs, Doctors Gowski and Zachariah, in their discrimination, retaliation, and hostile work environment suit against the Secretary of the Department of Veterans Affairs (VA). At issue was whether this circuit recognized a retaliatory hostile work environment claim and, if so, whether the evidence in this case was sufficient to support the jury's verdict and damages award. The court concluded that a retaliatory hostile work environment was a viable claim and, after a thorough review of the record and with the benefit of oral argument, the court affirmed the district court's denial of the motion for judgment as a matter of law and for a new trial, the remittur, the vacatur of the lost-wages award, and the award of attorneys' fees. The court also affirmed in part the grant of injunctive relief, but remanded in part the injunctive award with instructions for the district court to strike the award as it pertained to the removal of the doctors' disciplinary files and the prevention of their use in any further disciplinary action; the order that the doctors be appointed to additional hospital committees; the order that Dr. Gowski be placed back on the rotation for duty assignments and be permitted to obtain the necessary credentials and privileges to do so; and the order that Dr. Zachariah be permitted to continue her research.

Plaintiff, a teacher at a small Christian school, appealed the district court's grant of summary judgment in favor of the school on her pregnancy discrimination claim, under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., contending that she had established a prima facie case of unlawful discrimination. After admitting to the school's administrator and assistant administrator that she conceived the child before getting married, the school fired her, purportedly because she had sinned by engaging in premarital sex, and, as the administrator put it, "there are consequences for disobeying the word of God." Because the school did not raise any issue or make any argument in its brief about the ministerial exception, the court would not decide whether that exception might apply. The court found that plaintiff's testimony contradicted the administrator's testimony that he had never heard her say she was sorry for what she had done and that he would not have fired her if she had. For that and other reasons, plaintiff had established a genuine issue of material fact about the reason that the school fired her. Accordingly, the court reversed the grant of summary judgment on the pregnancy discrimination claim and remanded for further proceedings.