Eaves v. Work Force Central Florida, 2015 WL 4279200 (11th Cir. July 16, 2015)
Edward Eaves (“Eaves”) began working for Workforce Central Florida (“WCF”) in October 2011. In December of 2011, Eaves filed a Charge of Discrimination with the Equal Employment Opportunity Commission (the “EEOC”). Eaves alleged that he had been discriminated against because of his gender. In support of his gender discrimination claims, Eaves alleged the following: (1) he was denied the opportunity to apply for a re-employment specialist position; (2) he was denied the opportunity to work in the computer lab after his training period; (3) he was not provided certain job resources or amenities that were given to female employees; (4) he was treated differently than female employees in terms of leave and attendance policies; and (5) he was not informed of available positions and opportunities that were communicated to female employees.
On December 21, 2011, Eaves was fired. He amended his Charge of Discrimination to include a claim for retaliation and then filed a lawsuit against WCF for gender discrimination and retaliation in violation of Title VII. The trial court found that the discrimination claims failed because Eaves had not shown that he was qualified for the re-employment specialist position or that his remaining allegations about various disparities in the workplace constituted a material change in the terms and conditions of employment. The trial court found that Eaves’ retaliation claim failed because he could not demonstrate that WCF’s reasons for firing him were pretextual. Eaves appealed.
On appeal, the Eleventh Circuit focused primarily on Eaves' retaliation claim. To make out a case of retaliation under Title VII, a plaintiff must show the following: (1) he engaged in a protected activity; (2) he suffered a materially adverse action; and (3) there was a causal connection between the protected activity and the adverse action. If the plaintiff establishes a case, the burden shifts to the employer to articulate a legitimate, non-discriminatory reason for its adverse action. Once the employer does so, the plaintiff has the opportunity to show that the employer’s stated reason was pretext for retaliation.
WCF claimed that Eaves was fired because of angry, hostile, and unprofessional behavior toward his supervisors. Eaves' claimed that he was told he was fired because he filed a Charge of Discrimination with the EEOC. The Eleventh Circuit concluded that Eaves' statements were sufficient to allow a reasonable jury to conclude that Eaves was fired in retaliation for filing a Charge of Discrimination with the EEOC.
The Eleventh Circuit vacated the trial court's grant of summary judgment to WCF as to Eaves' Title VII retaliation claim and sent the case back to the trial court for further proceedings.