Lawanna Tynes v. Florida Department of Juvenile Justice, 88 F.4th 939

Lawanna Tynes, a Black female, worked for 16 years as superintendent of a Florida juvenile detention center, with no prior negative reviews, before being terminated by the Florida Department of Juvenile Justice (the Department).
The Department cited various reasons for her termination, including poor performance and misconduct, after an unusual number of incidents occurred while she was on medical leave.
Tynes sued for race and sex discrimination under Title VII and, implicitly, under 42 U.S.C. § 1981, alleging similarly situated white and male superintendents were treated more favorably.
At trial, evidence was presented suggesting pretext and personal bias by Tynes's supervisor; the jury found for Tynes on both Title VII and § 1981 claims.
The Department appealed, arguing (1) inadequacy of Tynes’s comparator evidence to establish a prima facie case under McDonnell Douglas, and (2) that Tynes had not properly pleaded or proven her § 1981 claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must a plaintiff establish a McDonnell Douglas prima facie case to survive post-trial motions under Title VII?	Tynes presented enough evidence of discrimination, including disparate treatment and pretext, regardless of strict comparator analysis.	Department argued Tynes lacked adequate comparator evidence, so failed to establish a prima facie McDonnell Douglas case.	Plaintiff need not prove prima facie case post-trial; sufficiency of overall evidence controls.
Was the jury’s verdict supported by sufficient evidence of intentional discrimination?	Tynes presented substantial circumstantial evidence, including differential treatment and biased conduct.	Department focused only on alleged comparator inadequacy.	Verdict affirmed; sufficiency of evidence was not disputed on appeal.
Did Tynes sufficiently plead a § 1981 claim?	Claim was supported by facts and referenced in the complaint.	Department argued § 1981 claim was not properly pleaded as a separate count.	Complaint could be amended at trial under Rule 15(b)(1); challenge deemed forfeited.
Did Tynes prove that race was a "but-for" cause under § 1981?	Race was found by jury to be a but-for cause of her termination.	Department claimed insufficient proof, but argued the issue on pleading grounds.	Argument forfeited; not preserved properly on appeal.

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (evidentiary burden-shifting framework for discrimination claims)
Texas Dep't of Cmty. Affs. v. Burdine, 450 U.S. 248 (clarifying McDonnell Douglas framework and burden shifts)
St. Mary’s Honor Ctr. v. Hicks, 509 U.S. 502 (defendant’s burden of production and evidentiary framework)
U.S. Postal Serv. Bd. of Governors v. Aikens, 460 U.S. 711 (focus on ultimate question of discrimination after trial)
Smith v. Lockheed-Martin Corp., 644 F.3d 1321 (explaining "convincing mosaic" of circumstantial evidence)
Lewis v. City of Union City, 918 F.3d 1213 (en banc) (standard for comparator evidence in intentional discrimination cases)