Sandra F. Addison v. Florida Department of Corrections, 683 F. App'x 770

Sandra F. Addison, an African‑American woman over 50, worked for the Florida Department of Corrections as a captain at Gulf Annex and was transferred in 2012 to Gulf Main as part of a reorganization.
At Gulf Main Addison faced insubordination from subordinates, filed incident reports, and complained about inmate and staff misconduct that the Department did not correct.
On Feb. 10, 2014, an inmate threw a food tray at subordinate officer April Faircloth; Faircloth’s written incident report stated she was hit, while she and others earlier told supervisors she had not been hit.
Management concluded Addison violated policy by failing to file a staff‑battery report for Faircloth; after a pre‑discipline conference Addison accepted a demotion in lieu of termination and signed a release. Kenneth Stephens, a younger white man, replaced her as captain.
Addison sued alleging race and age discrimination and retaliation under Title VII, the Florida Civil Rights Act, and Florida’s Whistle‑blower’s Act. The district court granted summary judgment for the Department; the Eleventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Addison’s transfer to Gulf Main was an adverse employment action for discrimination claims	Transfer was effectively punitive and motivated by race/age	Transfer did not change title, pay, duties, or hours and thus was not adverse	Transfer was not an adverse action; cannot support discrimination claim
Whether Addison’s demotion to sergeant was an adverse employment action and supports discrimination claims	Demotion reduced prestige/responsibility and she was replaced by a younger white male	Demotion resulted from legitimate disciplinary reason (failure to report staff battery)	Demotion was an adverse action and satisfied prima facie discrimination requirements
Whether the Department’s nondiscriminatory reason (failure to report) was pretext	Gossip about replacement and alleged disparate discipline of Faircloth and Sapp show pretext	Rumors do not reflect decisionmaker’s intent; claimed comparators were not similarly situated	Evidence insufficient to show pretext; summary judgment proper on discrimination claims
Whether Addison’s whistle‑blower/retaliation claim survives summary judgment	Complaints about misconduct were protected activity and demotion was retaliatory	Demotion was for legitimate non‑retaliatory reason (failure to report); no proof of pretext or causation	Even assuming protected activity, Addison failed to show pretext or causal link; summary judgment proper

Moton v. Cowart, 631 F.3d 1337 (11th Cir. 2011) (standard of review for summary judgment)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden‑shifting framework for circumstantial discrimination claims)
Texas Dep’t of Cmty. Affairs v. Burdine, 450 U.S. 248 (1981) (employer’s burden to articulate legitimate nondiscriminatory reason)
Combs v. Plantation Patterns, 106 F.3d 1519 (11th Cir. 1997) (standards for proving pretext)
Maniccia v. Brown, 171 F.3d 1364 (11th Cir. 1999) (elements of prima facie discrimination case)
Davis v. Town of Lake Park, Fla., 245 F.3d 1232 (11th Cir. 2001) (definition of adverse employment action)
Hinson v. Clinch County Bd. of Educ., 231 F.3d 821 (11th Cir. 2000) (when transfer constitutes adverse action)
Wilson v. B/E Aerospace, Inc., 376 F.3d 1079 (11th Cir. 2004) (requirement that comparators be similarly situated)
Sierminski v. Transouth Financial Corp., 216 F.3d 945 (11th Cir. 2000) (employer’s articulation of legitimate reason and plaintiff’s burden to prove pretext)
Jones v. United Space Alliances, L.L.C., 494 F.3d 1306 (11th Cir. 2007) (Florida Civil Rights Act claims analyzed under Title VII standards)