Andras Maholanyi v. SafeTouch of Tampa, Inc.
686 F. App'x 765
| 11th Cir. | 2017Background
- Plaintiff Andras Maholanyi, age 40+, sued SafeTouch of Tampa, Inc. for wrongful termination under the ADEA and Florida Civil Rights Act, alleging age discrimination.
- The district court granted summary judgment for SafeTouch; Maholanyi appealed only the pretext/discrimination holding.
- SafeTouch presented evidence that branch sales declined after Maholanyi became Tampa branch manager and that he was frequently unreachable, unprepared, late, and failed to run sales meetings.
- Supervisors and coworkers corroborated performance problems; management testified branch revenues (not individual bonuses) determined pay and that software showed low projected sales before the termination.
- Maholanyi pointed to raises/bonuses and one supervisor’s age-related remarks, and claimed he was fired before sales figures were received.
- The court found Maholanyi established a prima facie case but failed to show SafeTouch’s proffered nondiscriminatory reasons were pretextual, so summary judgment for SafeTouch was affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether termination was due to age discrimination under the ADEA/Florida law | Maholanyi: termination motivated by age; pointed to age-related remarks and timing | SafeTouch: fired for legitimate nondiscriminatory reasons — poor branch performance, unprofessional conduct, low sales projections | Court: No; SafeTouch’s reasons were credible and Maholanyi failed to show pretext |
| Whether evidence of raises/bonuses rebuts defendant’s reasons | Maholanyi: raises/bonuses and lack of write-ups show no performance problems | SafeTouch: remuneration tied to branch revenue; no formal write-up practice for managers | Court: Raises/bonuses and lack of documentation not sufficient to prove pretext |
| Admissibility/weight of disparaging remarks by a supervisor | Maholanyi: cited age-related remarks as evidence of discriminatory motive | SafeTouch: remarks were general/vulgar and not tied to the decisionmaker’s process | Court: Remarks by nondecisionmaker or unrelated to the decision do not prove pretext |
| Whether timing/availability of sales figures undermines defendant’s stated reason | Maholanyi: manager fired him before receiving sales figures | SafeTouch: manager used software to calculate projected low sales in advance | Court: Timing explained by pre-calculated projections; no genuine dispute of fact |
Key Cases Cited
- Mazzeo v. Color Resolutions Int’l, LLC, 746 F.3d 1264 (11th Cir. 2014) (federal and state age-discrimination claims analyzed under the same framework)
- Furcron v. Mail Ctrs. Plus, LLC, 843 F.3d 1295 (11th Cir. 2016) (standard for proving pretext at summary judgment)
- Vessels v. Atlanta Indep. Sch. Sys., 408 F.3d 763 (11th Cir. 2005) (factors showing employer’s reasons unworthy of credence)
- Wascura v. City of S. Miami, 257 F.3d 1238 (11th Cir. 2001) (lack of formal review process does not by itself show pretext)
- Steger v. Gen. Elec. Co., 318 F.3d 1066 (11th Cir. 2003) (statements by nondecisionmakers or unrelated statements generally insufficient to prove discrimination)