Rhenals v. Federal Express Corporation
1:25-cv-20442
S.D. Fla.May 19, 2025Background
- Plaintiff Alonso Rhenals, a former FedEx employee, sued FedEx for hostile work environment, retaliation, and age discrimination under the Florida Civil Rights Act (FCRA).
- Plaintiff filed a discrimination charge with the EEOC on February 28, 2023, and received a Right to Sue letter on April 22, 2024.
- An initial action (Rhenals I) in state court was removed to federal court and dismissed without prejudice in November 2024.
- Plaintiff refiled his complaint (Rhenals II) in January 2025, based on the same allegations.
- FedEx moved to dismiss the new complaint, arguing untimeliness due to failure to file within 90 days of the EEOC notice.
- The court considered whether the federal 90-day or state four-year statute of limitations controlled, given the type and timing of the notice Rhenals received.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Statute of limitations | Four-year limit applies under FCRA if no cause finding | EEOC right-to-sue triggers 90-day period for all claims | Four-year limitation applies; complaint is timely |
| Nature of EEOC notice | Notice wasn’t a cause determination under FCRA | EEOC notice suffices as a determination/cuts period to 1 yr | EEOC notice was insufficient; no FCRA reasonable cause |
| Tolling by prior suit | Prior suit should not bar refiling within proper limit | Dismissal without prejudice resets clock, no tolling applies | FCRA claim timely because four-year period still open |
| Application to federal/state claims | Federal 90-day rule doesn’t apply to FCRA claims | 90-day EEOC period applies to all claims | 90-day rule applies only to federal, not to FCRA claims |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading requirements for a complaint's sufficiency)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (standard for plausibility in pleadings)
- Joshua v. City of Gainesville, 768 So. 2d 432 (Fla. 2000) (four-year statute applies if no timely cause determination)
- Woodham v. Blue Cross & Blue Shield, 829 So. 2d 891 (Fla. 2002) (requirements for timely FCRA filings)
- Ellsworth v. Polk Cnty. Bd. of Cnty. Comm’rs, 780 So. 2d 903 (Fla. 2001) (four-year statute governs when agency fails to determine cause)
- White v. City of Pompano Beach, 813 So. 2d 1003 (Fla. 4th DCA 2002) (EEOC right-to-sue not equivalent to FCHR reasonable cause determination)