Spakes v. Broward County Sheriff's Office
631 F.3d 1307
| 11th Cir. | 2011Background
- Spakes, a Broward County Sheriff's Office employee, sought FMLA leave after an infection.
- After two sick days, Spakes informed her supervisor she would need regular treatments and miss work, then submitted an FMLA leave request on Friday.
- BSO terminated Spakes on the following Monday for alleged performance deficiencies.
- A jury found Spakes gave proper notice, that BSO terminated due to her FMLA request, and that the termination would not have occurred but for the request.
- The district court awarded back pay, prejudgment interest, liquidated damages, five years of front pay, and attorneys’ fees to Spakes.
- BSO appealed, challenging the DOL complaint bar and the jury instructions on interference.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does a DOL complaint bar Spakes’ FMLA lawsuit? | Spakes: agency complaint does not bar private suit. | BSO: DOL process limits remedies should bar suit. | No bar; agency complaint does not foreclose civil action. |
| Did the jury instructions misstate the interference elements by requiring a causal nexus? | Spakes: causal nexus not required for interference claim. | BSO: nexus should be considered in determining liability. | Causal nexus not required; interference lacks nexus element, but defense on motives may be raised. |
| May an employer raise legitimate, non-FMLA reasons as an affirmative defense to liability? | Spakes: not relevant to liability for interference. | BSO: could defeat liability if would have discharged for unrelated reason. | Yes; such defense is valid and, although instructed for retaliation claim, harmless as the jury rejected it on the facts. |
Key Cases Cited
- Martin v. Brevard Cnty. Pub. Sch., 543 F.3d 1261 (11th Cir. 2008) (interference relief requires denial of a benefit under FMLA; motive irrelevant)
- Strickland v. Water Works & Sewer Bd. of Birmingham, 239 F.3d 1199 (11th Cir. 2001) (causation not required for interference; burden shift for retaliation)
- Goldsmith v. Bagby Elevator Co., 513 F.3d 1261 (11th Cir. 2008) (standard for reviewing jury instructions; prejudice analysis)