Reginald D. Lee v. United States Steel Corporation
450 F. App'x 834
11th Cir.2012Background
- Lee, African-American male, sued U.S. Steel for FMLA interference, FMLA retaliation, and race discrimination under Title VII and 42 U.S.C. § 1981; district court granted summary judgment for U.S. Steel.
- Lee argued he provided notice suggesting potential FMLA-qualifying leave and that timing of his termination reflected retaliation.
- Court held Lee did not establish FMLA interference because his leave did not involve a serious health condition or adequate notice.
- Lee also failed to show protected activity or causation for FMLA retaliation, and thus lacked prima facie evidence.
- On Title VII/§1981, Lee could not show a similarly situated white comparator engaged in nearly identical conduct without different discipline; district court’s ruling was affirmed.
- The appellate court affirmed the district court’s summary judgment decision on all claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| FMLA interference viability | Lee argues U.S. Steel knew of potential FMLA leave. | Lee failed to show a serious condition or proper notice. | Affirmed: no FMLA interference due to lack of serious condition/notice. |
| FMLA retaliation prima facie | Lee asserts retaliation due to protected activity. | No protected activity proven; causation not shown. | Affirmed: no prima facie case established. |
| Race discrimination proof | Lee contends comparator Snell shows disparate treatment. | Snell not similarly situated; not nearly identical misconduct. | Affirmed: no valid prima facie case of discrimination. |
Key Cases Cited
- Russell v. North Broward Hosp., 346 F.3d 1335 (11th Cir. 2003) (defines continuing-treatment standard under FMLA)
- Cruz v. Publix Super Markets, Inc., 428 F.3d 1379 (11th Cir. 2005) (unforeseeable leave requires notice as soon as practicable)
- Gay v. Gilman Paper Co., 125 F.3d 1432 (11th Cir. 1997) (requires notice for potentially FMLA-qualifying leave)
- Martin v. Brevard Cnty. Pub. Sch., 543 F.3d 1261 (11th Cir. 2008) (McDonnell Douglas framework for retaliation claims)
- St. Mary’s Hosp. Ctr. v. Hicks, 509 U.S. 502 (1993) (pretext framework in discrimination cases)
- Holifield v. Reno, 115 F.3d 1555 (11th Cir. 1997) (Prima facie showing of discrimination require similarly situated comparators)
- Maniccia v. Brown, 171 F.3d 1364 (11th Cir. 1999) (similarly situated analysis in discipline cases)
- Alvarez v. Royal Atl. Developers, Inc., 610 F.3d 1253 (11th Cir. 2010) (circumstantial discrimination proof under McDonnell Douglas)
- Damon v. Fleming Supermarkets of Fla., Inc., 196 F.3d 1354 (11th Cir. 1999) (pretext and comparator evidence in discrimination)