Chandra Fields v. Department of Juvenile Justice
712 F. App'x 934
| 11th Cir. | 2017Background
- Chandra Fields, an African American DJJ employee, alleged racial discrimination by supervisor Michele Lewis and that she was terminated in retaliation for reporting the discrimination.
- Fields testified she complained to Sylvia Baker (HR) in mid‑April 2014 and later filed an EEOC charge on June 14, 2014; DJJ’s EEO officer Derrick Elias investigated after the EEOC notice.
- At a charge conference, the district court proposed a retaliation instruction requiring the jury to find Fields "complained in good faith to an appropriate person" (defined as anyone above her in the chain of command or HR).
- Fields’ counsel objected, arguing the instruction could be read to require reporting to a particular person, but conceded the instruction covered the facts as presented.
- Trial evidence showed Baker could not recall that Fields’ complaint was based on race and testified that race complaints were handled by Elias. The jury asked whether an EEOC complaint filed after termination could count; the court answered no.
- The jury returned verdicts for DJJ on discrimination and retaliation. Fields appealed, arguing the jury instruction/verdict form misstated law on protected conduct and misled the jury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the instruction/verdict form misstated law by requiring complaint to an "appropriate person" | Instruction improperly limited protected activity and could mislead jury | Instruction accurately described protected activity as complaints to supervisors or HR and matched the evidence | Court held instruction accurately reflected Title VII law and case facts; no error |
| Whether the instruction confused the jury and prejudiced Fields | Phrase "appropriate person" and prosecutor argument misled jurors | Jury question showed concern about timing, not identity; closing argument addressed complaint content | Court held no tendency to confuse or mislead; no prejudice |
| Whether instruction conflicted with Eleventh Circuit pattern instructions | Pattern instructions do not require reporting to an "appropriate person" | Pattern requires description of the protected activity; district court complied by defining the activity | Court held instruction consistent with pattern instructions and law |
| Whether instruction impermissibly grafted a Faragher defense element onto protected expression | Instruction functionally imposed employer‑defense requirement | Instruction did not permit a Faragher defense to avoid liability | Court rejected this argument; no Faragher‑style error |
Key Cases Cited
- Gowski v. Peake, 682 F.3d 1299 (11th Cir. 2012) (standard for reviewing jury instructions for abuse of discretion)
- Samples v. City of Atlanta, 916 F.2d 1548 (11th Cir. 1990) (instructions should not confuse or mislead jury on legal principles)
- McNely v. Ocala Star‑Banner Corp., 99 F.3d 1068 (11th Cir. 1996) (same deferential review applied to verdict forms)
- Pipkins v. City of Temple Terrace, Fla., 267 F.3d 1197 (11th Cir. 2001) (internal complaints to supervisors and EEOC charges constitute protected activity)
- Rollins v. State of Fla. Dep’t of Law Enf’t, 868 F.2d 397 (11th Cir. 1989) (protected activity includes informal complaints and internal grievance use)
- Holifield v. Reno, 115 F.3d 1555 (11th Cir. 1997) (causal link requires decisionmaker’s actual awareness of protected activity)
- Faragher v. City of Boca Raton, 524 U.S. 775 (1998) (employer defense for supervisor harassment; discussed and distinguished)
- Walton v. Johnson & Johnson Servs., 347 F.3d 1272 (11th Cir. 2003) (application of Faragher defense in Eleventh Circuit)
Disposition: Affirmed.
