St. Louis v. Florida International University
60 So. 3d 455
Fla. Dist. Ct. App.2011Background
- St. Louis, a Trinidadian, was hired by FIU in 1997 as Assistant/Associate Controller of the Contracts and Grants Department (C&G).
- FIU faced a federal audit related to HCET grants; FIU settled for an $11.5 million liability, down from $25 million.
- FIU restructured research grant management in 2004, merging C&G into Post-Award and requiring C&G staff to apply for new posts with open competition.
- St. Louis applied for the Director Post-Award role in Oct. 2004; the search committee did not recommend him, citing lack of vision and willingness to embrace changes.
- The Director Post-Award position was eventually filled by Aida Reus in May 2006 after a prolonged vacancy; St. Louis resigned in Dec. 2004 asserting racial animus.
- St. Louis sued FIU alleging racial discrimination and retaliation; a jury awarded $72,241 in lost wages and $2.5 million in compensatory damages, which FIU challenged.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie case of racial discrimination | St. Louis asserts he showed disparate treatment after applying for Director Post-Award. | St. Louis failed to show similarly situated non-protected employees were treated more favorably. | Prima facie not proven; reversal required. |
| Prima facie case of retaliation | St. Louis claims protected complaints led to adverse action by the search process. | No evidence the committee knew of protected activity; no causation proven. | Prima facie not proven; directed-verdict warranted. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes the three-step burden-shifting framework)
- Valenzuela v. GlobeGround N. Am., LLC, 18 So.3d 17 (Fla. 3d DCA 2009) (disparate-treatment prima facie framework applied in Florida)
- Scholz v. RDV Sports, Inc., 710 So.2d 618 (Fla. 5th DCA 1998) (discrimination framework applied in Florida)
- Holifield v. Reno, 115 F.3d 1555 (11th Cir.1997) (prima facie standard for discrimination by inference)
- Russell v. KSL Hotel Corp., 887 So.2d 372 (Fla. 3d DCA 2004) (awareness and causal connection required in retaliation)
- Blizzard v. Appliance Direct, Inc., 16 So.3d 922 (Fla. 5th DCA 2009) (causal connection requires actual knowledge of protected activity)
- Food Fair Stores of Fla. v. Sommer, 111 So.2d 743 (Fla. 3d DCA 1959) (verdict must have rational predicate in evidence)
- Golden v. Morris, 55 So.2d 714 (Fla.1951) (caution against speculative inferences in discrimination cases)
- Jacksonville Coach Co. v. Early, 78 So.2d 369 (Fla.1955) (limits on inference-based discrimination findings)