AUGUSTINE LOUIS, APPELLANT,
v.
THE CHRYSALIS CENTER, INC., APPELLEE
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Louis, an employee of Chrysalis Center, reported sexual harassment by her supervisor and was subsequently terminated. The court reversed summary judgment for the employer, finding that circumstantial evidence of temporal proximity and pretextual justifications created material factual disputes regarding retaliation under the Florida Civil Rights Act.
The court held that Louis established a prima facie case of retaliation by showing: (1) engagement in protected activity (reporting sexual harassment); (2) adverse employment action (written warnings and termination); and (3) a causal relationship supported by circumstantial evidence, including temporal proximity and pretext, precluding summary judgment.
[1] An appellate court reviews a summary judgment de novo, examining the record in a light most favorable to the non-moving party.
[2] To prove retaliation under the Florida Civil Rights Act of 1992, a plaintiff must show engagement in a protected activity, an adverse employment action, and a causal rela…
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Join FLexlaw to unlock all legal intelligence“To prove retaliation, appellant must show that: 1) she was engaged in a protected activity; 2) she suffered an adverse employment action; and 3) there was causal relationship between the two.”
Establishes the three-part test for FCRA retaliation claims.
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Join FLexlaw to unlock all legal intelligenceLouis reported allegations of sexual harassment by her supervisor to her employer, Chrysalis Center, Inc. Following this report, Louis received writte…
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We reverse the final summary judgment in favor of appellant’s employer in this action for retaliation under the Florida Civil Rights Act of 1992 (“FCRA”).
The appellate court reviews de novo a summary judgment, examining the record in a light most favorable to the non-moving party. Shirey v. State Farm Mut. Auto. Ins. Co., 94 So.3d 619, 620-21 (Fla. 4th DCA 2012). In her complaint, appellant claimed that appellee, her employer, retaliated against her because she reported sexual harassment by her supervisor. To prove retaliation, appellant must show that: 1) she was engaged in a protected activity; 2) she suffered an adverse employment action; and 3) there was causal relationship between the two. Blizzard v. Appliance Direct, Inc., 16 So.3d 922, 926 (Fla. 5th DCA 2009).
It was undisputed that appellant reported allegations of sexual harassment *634to the employer. Evidence was presented that, after reporting these allegations, she suffered adverse employment action by being written up for various employment matters, as well as ultimately being fired. The real issue was whether there was a causal relationship between the two. In this case, there was circumstantial evidence, at the least, to support a causal relationship, including but not limited to the temporal proximity of the adverse employment actions to the report of the sexual harassment. Further, circumstantial evidence was also presented that the reasons advanced by the employer which were offered to justify the adverse employment action were pretextual. Because there remain material issues of fact, the trial court erred in granting summary judgment.
Reversed.
WARNER, CONNER, JJ., and LEVENSON, JEFFREY R„ Associate Judge, concur.
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Gafoor Jaffer and Nina Jaffer v. Chase Home Fin., LLC, 155 So. 3d 1199 (Fla. 4th DCA 2015)…size the legal principle stated by the majority concerning the standard of review that “[t]he appellate court reviews de novo a summary judgment, examining the record in a light most favorable to the non-moving party.” Louis v. Chrysalis Ctr., Inc., 121 So. 3d 633, 633 (Fla. 4th DCA 2013) (citing Shirey v. State Farm Mut. Auto. Ins. Co., 94 So. 3d 619, 620-21 (Fla. 4th DCA 2012)). Summary Judgment Must Be Grounded Upon the Pleadings “Although no thoroughly satisfactory definition of a cause of action has bee…
Authorities Cited
- Neina Blizzard v. Appliance Direct, Inc., 16 So. 3d 922 (Fla. 5th DCA 2009)
- Luanna Shirey and Michael Shirey v. State Farm Mut. Auto. Ins. Co., 94 So. 3d 619 (Fla. 4th DCA 2012)