Zaneta (Joi) Rainey Lightfoot v. Henry County School District
771 F.3d 764
| 11th Cir. | 2014Background
- Zaneta Lightfoot, a high-school teacher with sickle cell anemia, took intermittent FMLA leave (approved 2010–2011) and sought accommodations for reduced walking; she alleges disciplinary actions began after her leave requests.
- School administrators issued letters of redirection, an "unsatisfactory" evaluation, placed her on a Professional Development Plan (PDP), removed her as cheerleading coach, and later did not renew her contract (termination in 2013).
- Lightfoot sued Henry County School District asserting FMLA retaliation and ADA discrimination/retaliation; district court granted summary judgment to the District on ADA claims, denied on FMLA, then granted reconsideration and dismissed the FMLA claim on Eleventh Amendment immunity grounds.
- On appeal the central question was whether the School District is an "arm of the State" of Georgia (entitled to Eleventh Amendment immunity) or a local political subdivision (no immunity); the court applied the four-factor Manders test (definition, state control, funding, responsibility for judgments).
- The Eleventh Circuit panel held the District is not an arm of the State—finding Georgia law, local control/authority, local funding powers, and lack of state obligation to satisfy judgments weigh against immunity—and reversed dismissal of the FMLA claim; it affirmed summary judgment for the District on the ADA retaliation claim because plaintiff’s complaint and briefing did not provide notice that ADA retaliation was based on FMLA-leave facts.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Henry County School District is an "arm of the State" entitled to Eleventh Amendment immunity | Lightfoot: District is a local political subdivision with local control and fiscal autonomy; not an arm of the State | School District: State law creates and controls districts, provides significant funding and statewide education duties, so District is an arm of Georgia | Not an arm of the State; Eleventh Amendment immunity does not bar Lightfoot’s FMLA claim (reversed) |
| Whether the district court erred in granting summary judgment on Lightfoot's ADA retaliation claim | Lightfoot: ADA retaliation claim should be read to include retaliation for requesting FMLA leave (facts pled elsewhere) | School District: ADA count alleges different protected activity (complaint to admins); defendants lacked notice of an ADA claim based on FMLA leave | Affirmed: district court did not abuse discretion; plaintiff may not amend claim by argument at summary judgment |
Key Cases Cited
- United States ex rel. Lesinski v. S. Fla. Water Mgmt. Dist., 739 F.3d 598 (11th Cir.) (examining arm-of-state factors for state water district)
- Manders v. Lee, 338 F.3d 1304 (11th Cir. 2003) (en banc) (four-factor test for arm-of-state Eleventh Amendment analysis)
- Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 (U.S. 1977) (school boards treated as political subdivisions for Eleventh Amendment purposes)
- Port Authority Trans–Hudson Corp. v. Feeney, 495 U.S. 299 (U.S. 1990) (arm-of-state inquiry focuses on whether entity is the direct means by which the State acts)
- Stewart v. Baldwin County Bd. of Educ., 908 F.2d 1499 (11th Cir. 1990) (local school boards lack Eleventh Amendment immunity)
- Gilmour v. Gates, McDonald & Co., 382 F.3d 1312 (11th Cir. 2004) (plaintiff may not amend complaint via argument opposing summary judgment)