Lin v. Demings
219 So. 3d 124
| Fla. Dist. Ct. App. | 2017Background
- Deputy Thomas Lin, an Orange County deputy since 1988 and marine unit member since 1993, turned 50 in 2009 and alleged age-based adverse actions by the Sheriff.
- Lin claims he was suspended for ten hours without pay and transferred out of the marine unit back to road patrol because of his age.
- Lin sued under the Florida Civil Rights Act (FCRA), alleging age discrimination; the Sheriff moved for summary judgment.
- The trial court granted summary judgment for the Sheriff; Lin appealed to the Fifth District Court of Appeal.
- The appellate court reviewed whether genuine issues of material fact existed—especially whether the Sheriff’s proffered nondiscriminatory reasons were pretextual—and whether the trial court improperly weighed evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether summary judgment was appropriate | Lin argued disputed facts exist showing the Sheriff’s reasons were pretext for age discrimination | Sheriff argued he offered legitimate, nondiscriminatory reasons for suspension and transfer | Reversed — genuine factual disputes precluded summary judgment |
| Burden-shifting framework under FCRA | Lin satisfied prima facie showing; burden shifts to employer to articulate reason | Sheriff met production burden with nondiscriminatory explanations | Court applied McDonnell Douglas framework; after employer’s showing, issue became pretext |
| Whether Lin showed pretext | Lin pointed to conflicting evidence (e.g., replacement by younger deputy) and statements suggesting age bias | Sheriff asserted permissible reasons for discipline and reassignment | Court found Lin produced evidence susceptible to inference of pretext; summary judgment inappropriate |
| Whether trial court improperly weighed evidence / applied stray comment doctrine | Lin argued the court improperly discounted evidence and stray remarks at summary judgment stage | Sheriff relied on court’s assessment to justify summary disposition | Court held trial court erred by weighing credibility and dismissing evidence as "too tenuous" and misapplying stray comment doctrine |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (establishes burden-shifting framework for discrimination claims)
- Texas Dep't of Cmty. Affairs v. Burdine, 450 U.S. 248 (explains employer production burden and rebuttable presumption)
- Reeves v. Sanderson Plumbing Prods. Inc., 530 U.S. 133 (pretext and inference standards in discrimination cases)
- St. Mary's Honor Ctr. v. Hicks, 509 U.S. 502 (employee must show employer’s reasons are false and discrimination was real reason)
- Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (clarifies causation standards in age discrimination context)
- Valenzuela v. GlobeGround N. Am., LLC, 18 So. 3d 17 (applies McDonnell Douglas under FCRA)
- Estate of Githens ex rel. Seaman v. Bon Secours-Maria Manor Nursing Care Ctr., 928 So. 2d 1272 (summary judgment standard)
- Feizi v. Dep't of Mgmt. Servs., 988 So. 2d 1192 (reversing summary judgment where factual disputes on pretext existed)
- Jones v. Stoutenburgh, 91 So. 2d 299 (courts may not weigh evidence or decide credibility at summary judgment)