Wright v. Sandestin Investments, LLC
914 F. Supp. 2d 1273
N.D. Fla.2012Background
- Wright was an executive administrative assistant for Intrawest ULC at the Sandestin Resort.
- She took approved FMLA maternity leave starting Jan 11, 2010, with a scheduled return Apr 12, 2010.
- Intrawest sold the resort to Sandestin Investments on Mar 15, 2010 while she was on leave.
- Wright’s position was eliminated and she received an April 2, 2010 termination letter while on leave.
- Fowler testified Sandestin did not honor Intrawest’s FMLA leave and transition affected benefits and records.
- The court evaluates successor-in-interest liability, FMLA interference/retaliation issues, and FCRA pregnancy-discrimination claims; both motions are denied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is Sandestin a successor in interest liable under the FMLA? | Wright argues Sandestin is a successor; liable for FMLA interference. | Sandestin contends no successor liability or no material impact. | Denied partial summary judgment on successor liability; court finds factors weigh in favor of successor status. |
| Did Sandestin interfere with Wright’s FMLA rights by terminating during leave? | Wright asserts termination while on FMLA leave constitutes interference. | Sandestin contends any interference is not proven or overridden by defense. | Denied; genuine issues of material fact about interference remain. |
| Is Wright’s pregnancy discrimination claim actionable under the Florida Civil Rights Act (FCRA)? | Wright asserts pregnancy discrimination is prohibited under FCRA. | Sandestin argues FCRA does not protect pregnancy discrimination; conflict among Florida courts. | Denied summary judgment; court anticipates Florida Supreme Court would align with pregnancy-discrimination rationale. |
| Are Wright’s FMLA retaliation and related defenses provable as a matter of law? | Wright shows causation and pretext for retaliation. | Sandestin argues insufficient causal link and affirmative defense would defeat liability. | Denied; triable issues exist on causation and pretext. |
Key Cases Cited
- Strickland v. Water Works and Sewer Bd. of City of Birmingham, 239 F.3d 1199 (11th Cir. 2001) (FMLA interference/causation framework; pretext analysis)
- O’Connor v. PCA Family Health Plan, Inc., 200 F.3d 1349 (11th Cir. 2000) (Reinstatement standards under FMLA; safeharbor for no reinstatement in certain scenarios)
- Martin v. Brevard Cnty. Pub. Schs., 543 F.3d 1261 (11th Cir. 2008) (FMLA retaliation; strict liability not required; causation considerations)
- Krutzig v. Pulte Home Corp., 602 F.3d 1231 (11th Cir. 2010) (Prima facie FMLA retaliation framework; causation elements)
- Carsillo v. City of Lake Worth, 995 So.2d 1118 (Fla. 4th DCA 2008) (FCRA pregnancy discrimination interpretation; Florida Supreme Court anticipated alignment with Title VII)
- Newport News Shipbuilding and Dry Dock Co., 462 U.S. 669 (Supreme Court 1983) (Pregnancy Discrimination Act interpretation context for state law)
- Grace v. USCAR, 521 F.3d 655 (6th Cir. 2008) (Overarching three-part test for successor liability factors)
- Sullivan v. Dollar Tree Stores, Inc., 623 F.3d 770 (9th Cir. 2010) (Equitable considerations in successor liability)