Orlando v. Williams v. Alabama Department of Industrial Relations
684 F. App'x 888
| 11th Cir. | 2017Background
- Pro se plaintiff Orlando V. Williams resigned from the Alabama Department of Corrections in 2011, applied for unemployment, and was denied; he appealed to the ADOL Board of Appeals and filed a complaint with the federal Civil Rights Center (CRC).
- Williams sued Alabama Department of Labor (ADOL) under the Rehabilitation Act for disability discrimination (Count I) and retaliation (Count II), and sued ADOL officials Surtees and McCormick under § 1983 for First Amendment retaliation (Count III).
- District court dismissed Count I for failure to plead a disability and that he was otherwise qualified for unemployment benefits, gave leave to amend, and later dismissed Count I with prejudice after multiple unsuccessful amendments and a Social Security decision submitted post-dismissal did not cure the pleading deficiency.
- On summary judgment the district court dismissed Counts II and III, finding Williams failed to show an adverse action or a causal link between his CRC complaint and the Board’s denial of leave to appeal; defendants provided declarations denying knowledge of the CRC filing.
- Williams pursued multiple discovery- and procedure-related motions (sanctions under Rule 37, Rule 26 requests, Rule 56(d) relief, motion to amend under Rule 15); the district court denied them and the Eleventh Circuit affirmed those denials.
- The Eleventh Circuit affirmed in full: dismissal of Count I, summary judgment on Counts II and III, and all discovery- and amendment-related rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of pleading disability-discrimination claim (Rehabilitation Act) | Williams contended he alleged disability (PTSD) and that his resignation was involuntary, making him otherwise qualified for benefits | ADOL argued Williams failed to identify/describe a disability sufficiently and failed to plead he met eligibility requirements for unemployment | Affirmed: dismissal upheld for failure to plead that he was "otherwise qualified" for benefits |
| Proper characterization of post-judgment motion (Rule 59(e) v. Rule 60(b)) | Williams argued his Rule 60(b) motion should not have been treated as Rule 59(e) | Defendants supported district court construction; court treated it as 59(e) and denied relief | Affirmed: any error harmless because motion failed to address eligibility deficiency |
| Retaliation (Rehabilitation Act and § 1983/First Amendment) — adverse action and causation | Williams argued Board’s denial of leave (no written findings; no consideration of doctor’s note) was adverse and causally linked to his CRC complaint | Defendants produced declarations that ADOL officials were unaware of the CRC complaint before denial; argued no causal link or adverse action | Affirmed: summary judgment for defendants — Williams failed to show ADOL knew of CRC complaint, so no causal link; First Amendment claim abandoned on appeal |
| Discovery / sanctions / procedural relief (Rule 37, Rule 26(a), Rule 56(d), motion to amend Rule 15) | Williams sought sanctions/default for discovery failures, more discovery time, relief under Rule 56(d), and leave to amend beyond deadline | Defendants argued no order existed to support Rule 37(b) sanctions, discovery had been ample and deadlines passed, and amendment would be prejudicial/futile | Affirmed: district court did not abuse discretion in denying sanctions, additional discovery, Rule 56(d) relief, or belated leave to amend |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading must include factual content to state plausible claim)
- Higdon v. Jackson, 393 F.3d 1211 (prima facie retaliation elements and causal-link standard)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (summary judgment standard; genuine issue requirement)
- Cash v. Smith, 231 F.3d 1301 (Rehabilitation Act prima facie framework)
- Speaker v. U.S. Dep’t of Health & Human Servs., 623 F.3d 1371 (standard of review for dismissal)
- Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (abandonment of issues not challenged on appeal)
- Iraola & CIA, S.A. v. Kimberly-Clark Corp., 325 F.3d 1274 (denial of additional discovery affirmed where ample opportunity existed)
- Barfield v. Brierton, 883 F.2d 923 (Rule 56(d) denial affirmed where party had ample discovery time)
- Foman v. Davis, 371 U.S. 178 (standards for leave to amend under Rule 15)