Carolina Rose Matamoros v. Broward Sheriffs Office
2 F.4th 1329
| 11th Cir. | 2021Background
- Matamoros worked for the Broward Sheriff’s Office as a communications operator; her son has severe asthma and she took FMLA leave to care for him.
- She applied for a part-time position, was passed over, filed an internal grievance, and was denied additional FMLA leave.
- An internal investigation revealed she had outside employment and had often called in sick to the Sheriff’s Office while working her other job; she was suspended multiple times and ultimately terminated.
- Matamoros sued under the Florida Civil Rights Act (FCRA) alleging associational discrimination and retaliation, and under the FMLA for interference and retaliation.
- The district court dismissed the FCRA associational-discrimination claim and granted summary judgment to the Sheriff’s Office on the remaining claims; Matamoros appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the FCRA forbids associational discrimination (discrimination because of another’s disability) | FCRA should be read to cover associational claims (analogous to the ADA), and FCRA should be liberally construed | FCRA’s text prohibits discrimination because of an individual’s own handicap; it contains no associational-discrimination provision and Florida courts have not recognized such claims | FCRA does not provide for associational-discrimination claims; dismissal affirmed |
| FCRA retaliation (for filing EEOC charge) | Filing EEOC charge was protected; adverse actions followed, so retaliation | Decisionmakers were unaware of EEOC charge; no causal link or cat’s-paw evidence | Summary judgment affirmed — no proof decisionmakers knew of charge or that biased non‑decisionmakers caused termination |
| FMLA retaliation | Adverse actions followed protected FMLA leave requests/usage; employer’s reasons pretextual | Employer acted for legitimate reasons (attendance, false oath about outside employment, hiring decision for part-time slot) | Summary judgment affirmed — Matamoros failed to show employer’s reasons were pretextual |
| FMLA interference (denial of later FMLA leave) | Employer denied entitled FMLA leave | Matamoros did not meet statutory eligibility (1,250 hours in prior 12 months) | Summary judgment affirmed — Matamoros was not entitled to FMLA leave and thus cannot show interference |
Key Cases Cited
- Mullaney v. Wilbur, 421 U.S. 684 (U.S. 1975) (state courts are ultimate expositors of state law)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (burden-shifting framework for circumstantial discrimination claims)
- Delva v. Continental Group, Inc., 137 So. 3d 371 (Fla. 2014) (Florida Supreme Court construed pregnancy discrimination as discrimination "because of . . . sex" under FCRA)
- Dimmitt v. City of Clearwater, 985 F.2d 1565 (11th Cir. 1993) (federal courts should be reluctant to rewrite state statutes)
- Parr v. Woodmen of the World Life Insurance Co., 791 F.2d 888 (11th Cir. 1986) (discussion of associational discrimination in interracial association context)
- Shotz v. City of Plantation, 344 F.3d 1161 (11th Cir. 2003) (causation requires decisionmaker awareness or close temporal proximity)
- Stimpson v. City of Tuscaloosa, 186 F.3d 1328 (11th Cir. 1999) ("cat’s paw" theory where biased non-decisionmaker influences decisionmaker)
- Krutzig v. Pulte Home Corp., 602 F.3d 1231 (11th Cir. 2010) (employee must be entitled to FMLA benefit to state interference claim)