Title VII claim (Florida) · Go Syfert
← Florida issues

Title VII claim in Florida

7 Florida opinions name it 1 courts 2006–2024 1 in the last five years

The cases below were cited by Florida courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
Little v. United Technologiesgreen
ca11 · 1997 · cited in 2 Florida opinions naming this issue, 2015–2024
2 sentences

2024In Standard, the Eleventh Circuit recognized that under a Title VII claim the employee claiming retaliation for opposing the employer’s conduct must have a good faith, objectively reasonable belief that the employer’s conduct was unlawful under Title VII. 161 F.3d at 1328; see also Little v. United Techs., Carrier Transicold Div., 103 F.3d 956, 960 (11th Cir.1997).

2015In Standard, the Eleventh Circuit recognized that under *464 a Title VII claim the employee claiming retaliation for opposing the employer’s conduct must have a good faith, objectively reasonable belief that the employer’s conduct was unlawful under Title VII 161 F.3d at 1328; see also Little v. United Techs., Carrier Transicold Div., 103 F.3d 956, 960 (11th Cir.1997).

22
Arrow Air, Inc. v. Walshgreen
fla · 1994 · cited in 2 Florida opinions naming this issue, 2015–2024
2 sentences

2024The White court noted that the Florida Supreme Court has stated that the FWA “prohibits private sector employers from retaliating against ‘employees who “blow the whistle” on employers who violate the law or against employees who refuse to participate in violations of the law.’ ” Id. at 1337 (quoting Arrow Air, Inc. v. Walsh, 645 So.2d 422, 423 (Fla.1994)); see also Golf Channel v. Jenkins, 752 So.2d 561, 562 (Fla.2000) (stating that the FWA is “designed ‘to protect private employees who report or refuse to assist employers who violate laws enacted to protect the public’” (quoting Arrow Air, 6

2024The White court noted that the Florida Supreme Court has stated that the FWA “prohibits private sector employers from retaliating against ‘employees who “blow the whistle” on employers who violate the law or against employees who refuse to participate in violations of the law.’ ” Id. at 1337 (quoting Arrow Air, Inc. v. Walsh, 645 So.2d 422, 423 (Fla.1994)); see also Golf Channel v. Jenkins, 752 So.2d 561, 562 (Fla.2000) (stating that the FWA is “designed ‘to protect private employees who report or refuse to assist employers who violate laws enacted to protect the public’” (quoting Arrow Air, 6

22
Golf Channel v. Jenkinsgreen
fla · 2000 · cited in 2 Florida opinions naming this issue, 2015–2024
2 sentences

2024The White court noted that the Florida Supreme Court has stated that the FWA “prohibits private sector employers from retaliating against ‘employees who “blow the whistle” on employers who violate the law or against employees who refuse to participate in violations of the law.’ ” Id. at 1337 (quoting Arrow Air, Inc. v. Walsh, 645 So.2d 422, 423 (Fla.1994)); see also Golf Channel v. Jenkins, 752 So.2d 561, 562 (Fla.2000) (stating that the FWA is “designed ‘to protect private employees who report or refuse to assist employers who violate laws enacted to protect the public’” (quoting Arrow Air, 6

2015The White court noted that the Florida Supreme Court has stated that the FWA “prohibits private sector employers from retaliating against ‘employees who “blow the whistle” on employers who violate the law or against employees who refuse to participate in violations of the law.’ ” Id. at 1337 (quoting Arrow Air, Inc. v. Walsh, 645 So.2d 422, 423 (Fla.1994)); see also Golf Channel v. Jenkins, 752 So.2d 561, 562 (Fla.2000) (stating that the FWA is “designed ‘to protect private employees who report or refuse to assist employers who violate laws enacted to protect the public’ ” (quoting Arrow Air,

22
Barbara Rustowicz v. North Broward Hospital District n/k/a Broward Healthgreen
fladistctapp · 2015 · cited in 1 Florida opinions naming this issue, 2017–2017
1 sentence

2017See Rustowicz, 174 So.3d at 419 (explaining that Florida courts apply Title VII analysis to Whistle-blower's Act cases). .

11
Standard v. A.B.E.L. Services, Inc.green
ca11 · 1998 · cited in 1 Florida opinions naming this issue, 2015–2015
1 sentence

2015In Standard, the Eleventh Circuit recognized that under *464 a Title VII claim the employee claiming retaliation for opposing the employer’s conduct must have a good faith, objectively reasonable belief that the employer’s conduct was unlawful under Title VII 161 F.3d at 1328; see also Little v. United Techs., Carrier Transicold Div., 103 F.3d 956, 960 (11th Cir.1997).

11
Rachells v. Cingular Wireless Employee Services, LLCgreen
ca6 · 2013 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Coll., 719 F.3d 356, 363-64 (5th Cir.2013); Rachells v. Cingular Wireless Employee Servs., LLC, 732 F.3d 652, 661 (6th Cir.2013); Holmes v. Trinity Health, 729 F.3d 817, 821 (8th Cir.2013); Tabor v. Hilti, Inc., 703 F.3d 1206, 1216 (10th Cir.2013); Cruz v. Bristol-Myers Squibb Co., PR, Inc., 699 F.3d 563, 571 (1st Cir.2012); Schechner v. KPIX-TV, 686 F.3d 1018, 1023 (9th Cir.2012); and Weathers v. Univ. of N. Carolina at Chapel Hill, 447 Fed.Appx. 508, 510 (4th Cir.2011) (all utilizing some form of the traditional McDonnell Douglas test as the only circumstantial method of proof in a Title VII

11
Haire v. Board of Supervisors of Louisiana State University Agricultural & Mechanical Collegegreen
ca5 · 2013 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Coll., 719 F.3d 356, 363-64 (5th Cir.2013); Rachells v. Cingular Wireless Employee Servs., LLC, 732 F.3d 652, 661 (6th Cir.2013); Holmes v. Trinity Health, 729 F.3d 817, 821 (8th Cir.2013); Tabor v. Hilti, Inc., 703 F.3d 1206, 1216 (10th Cir.2013); Cruz v. Bristol-Myers Squibb Co., PR, Inc., 699 F.3d 563, 571 (1st Cir.2012); Schechner v. KPIX-TV, 686 F.3d 1018, 1023 (9th Cir.2012); and Weathers v. Univ. of N. Carolina at Chapel Hill, 447 Fed.Appx. 508, 510 (4th Cir.2011) (all utilizing some form of the traditional McDonnell Douglas test as the only circumstantial method of proof in a Title VII

11
Andrea Weathers v. University of North Carolinagreen
ca4 · 2011 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Coll., 719 F.3d 356, 363-64 (5th Cir.2013); Rachells v. Cingular Wireless Employee Servs., LLC, 732 F.3d 652, 661 (6th Cir.2013); Holmes v. Trinity Health, 729 F.3d 817, 821 (8th Cir.2013); Tabor v. Hilti, Inc., 703 F.3d 1206, 1216 (10th Cir.2013); Cruz v. Bristol-Myers Squibb Co., PR, Inc., 699 F.3d 563, 571 (1st Cir.2012); Schechner v. KPIX-TV, 686 F.3d 1018, 1023 (9th Cir.2012); and Weathers v. Univ. of N. Carolina at Chapel Hill, 447 Fed.Appx. 508, 510 (4th Cir.2011) (all utilizing some form of the traditional McDonnell Douglas test as the only circumstantial method of proof in a Title VII

11
William Schechner v. Kpix-Tvgreen
ca9 · 2012 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Coll., 719 F.3d 356, 363-64 (5th Cir.2013); Rachells v. Cingular Wireless Employee Servs., LLC, 732 F.3d 652, 661 (6th Cir.2013); Holmes v. Trinity Health, 729 F.3d 817, 821 (8th Cir.2013); Tabor v. Hilti, Inc., 703 F.3d 1206, 1216 (10th Cir.2013); Cruz v. Bristol-Myers Squibb Co., PR, Inc., 699 F.3d 563, 571 (1st Cir.2012); Schechner v. KPIX-TV, 686 F.3d 1018, 1023 (9th Cir.2012); and Weathers v. Univ. of N. Carolina at Chapel Hill, 447 Fed.Appx. 508, 510 (4th Cir.2011) (all utilizing some form of the traditional McDonnell Douglas test as the only circumstantial method of proof in a Title VII

11
Cruz v. Bristol-Myers Squibb Co., PR, Inc.green
ca1 · 2012 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Coll., 719 F.3d 356, 363-64 (5th Cir.2013); Rachells v. Cingular Wireless Employee Servs., LLC, 732 F.3d 652, 661 (6th Cir.2013); Holmes v. Trinity Health, 729 F.3d 817, 821 (8th Cir.2013); Tabor v. Hilti, Inc., 703 F.3d 1206, 1216 (10th Cir.2013); Cruz v. Bristol-Myers Squibb Co., PR, Inc., 699 F.3d 563, 571 (1st Cir.2012); Schechner v. KPIX-TV, 686 F.3d 1018, 1023 (9th Cir.2012); and Weathers v. Univ. of N. Carolina at Chapel Hill, 447 Fed.Appx. 508, 510 (4th Cir.2011) (all utilizing some form of the traditional McDonnell Douglas test as the only circumstantial method of proof in a Title VII

11
Tabor v. Hilti, Inc.green
ca10 · 2013 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Coll., 719 F.3d 356, 363-64 (5th Cir.2013); Rachells v. Cingular Wireless Employee Servs., LLC, 732 F.3d 652, 661 (6th Cir.2013); Holmes v. Trinity Health, 729 F.3d 817, 821 (8th Cir.2013); Tabor v. Hilti, Inc., 703 F.3d 1206, 1216 (10th Cir.2013); Cruz v. Bristol-Myers Squibb Co., PR, Inc., 699 F.3d 563, 571 (1st Cir.2012); Schechner v. KPIX-TV, 686 F.3d 1018, 1023 (9th Cir.2012); and Weathers v. Univ. of N. Carolina at Chapel Hill, 447 Fed.Appx. 508, 510 (4th Cir.2011) (all utilizing some form of the traditional McDonnell Douglas test as the only circumstantial method of proof in a Title VII

11
Nancy G. Holmes v. Trinity Healthgreen
ca8 · 2013 · cited in 1 Florida opinions naming this issue, 2014–2014
1 sentence

2014Coll., 719 F.3d 356, 363-64 (5th Cir.2013); Rachells v. Cingular Wireless Employee Servs., LLC, 732 F.3d 652, 661 (6th Cir.2013); Holmes v. Trinity Health, 729 F.3d 817, 821 (8th Cir.2013); Tabor v. Hilti, Inc., 703 F.3d 1206, 1216 (10th Cir.2013); Cruz v. Bristol-Myers Squibb Co., PR, Inc., 699 F.3d 563, 571 (1st Cir.2012); Schechner v. KPIX-TV, 686 F.3d 1018, 1023 (9th Cir.2012); and Weathers v. Univ. of N. Carolina at Chapel Hill, 447 Fed.Appx. 508, 510 (4th Cir.2011) (all utilizing some form of the traditional McDonnell Douglas test as the only circumstantial method of proof in a Title VII

11
Mrs. Billie B. McCLURE, Plaintiff-Appellant, v. the SALVATION ARMY, Defendant-Appelleegreen
ca5 · 1972 · cited in 1 Florida opinions naming this issue, 2006–2006
1 sentence

2006Matters touching this relationship must necessarily be recognized as of prime ecclesiastical concern." McClure v. Salvation Army, 460 F.2d 553, 558-59 (5th Cir.1972) (holding that the "ministerial exception" doctrine precludes judicial review of a minister's Title VII claim).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Florida. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Burlington Industries, Inc. v. Ellerth green
scotus · 1998
2 sentences

2017The Court held that an employer may be vicariously liable for an employee’s unlawful harassment only when the employer has empowered that employee to take tangible employment actions against the victim, i.e., to effect a “significant change in employment status, such as hiring, firing, failing to promote, reassignment with significantly different responsibilities, or a decision causing a significant change in benefits.” Id. at 2443 (quoting Ellerth, 524 U.S. at 761 , 118 S.Ct. 2257 ).

2017The Court held that an employer may be vicariously liable for an employee’s unlawful harassment only when the employer has empowered that employee to take tangible employment actions against the victim, i.e., to effect a “significant change in employment status, such as hiring, firing, failing to promote, reassignment with significantly different responsibilities, or a decision causing a significant change in benefits.” Id. at 2443 (quoting Ellerth, 524 U.S. at 761 , 118 S.Ct. 2257 ).

12017–2017
Valenzuela v. Globeground North America, LLC green
fladistctapp · 2009
1 sentence

2017Although Valenzuela, 18 So.3d at 25 , was an age discrimination case, it employed a Title VII analysis.

12017–2017
Vance v. Ball State Univ. green
scotus · 2013
2 sentences

2017Subsequently, in Vance v. Ball State University, the Court answered the question left unresolved by Ellerth : “who qualifies as a ‘supervisor’ in a case in which an employee asserts a Title VII claim for workplace harassment?” — U.S. —, 133 S.Ct. 2434, 2439 , 186 L.Ed.2d 565 (2013).

2017Subsequently, in Vance v. Ball State University, the Court answered the question left unresolved by Ellerth : “who qualifies as a ‘supervisor’ in a case in which an employee asserts a Title VII claim for workplace harassment?” — U.S. —, 133 S.Ct. 2434, 2439 , 186 L.Ed.2d 565 (2013).

12017–2017
White v. Purdue Pharma, Inc. green
flmd · 2005
2 sentences

2015In contrast to Luna, in White, 369 F.Supp.2d at 1338 , the Middle District stated that it would not apply the Title VII standard to the FWA.

2015In contrast to Luna, in White, 369 F.Supp.2d at 1338 , the Middle District stated that it would not apply the Title VII standard to the FWA.

12015–2015
McDonnell Douglas Corp. v. Green green
scotus · 1973
2 sentences

2015Because Florida applies the Title VII analysis to retaliatory discharge under the Whistleblower Act, the burden shifting analysis of McDonnell Douglas Corp. v. Green, 411 U.S. 792 , 93 S.Ct. 1817 , 36 L.Ed.2d 668 (1973), applies.

2015Because Florida applies the Title VII analysis to retaliatory discharge under the Whistleblower Act, the burden shifting analysis of McDonnell Douglas Corp. v. Green, 411 U.S. 792 , 93 S.Ct. 1817 , 36 L.Ed.2d 668 (1973), applies.

12015–2015

Statutes the citing opinions construe

FL § 112.3187 (5) FL § 448.102 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 32 (1996–2026) CA 24 (1982–2025) OH 17 (1975–2024) IA 14 (1990–2021) NJ 11 (1990–2025) WA 10 (2005–2025) NM 9 (2002–2014) CO 8 (1989–2020) NY 8 (1993–2017) FL 7 (2006–2024) WI 7 (1987–2000) MN 6 (1986–2004) MD 6 (1989–2025) OR 5 (1989–2013) IN 5 (1993–2016) CT 5 (1986–2022) IL 5 (2003–2025) DC 5 (1984–2024) PA 5 (1985–2014) AL 5 (1984–2011) LA 5 (1992–2006) WV 4 (1987–2022) MO 4 (1991–2001) NE 4 (1996–2018) MA 4 (1995–2022) AR 3 (1996–2026) HI 3 (2001–2017) NC 3 (2004–2022) AZ 3 (1982–2026) OK 2 (1991–2002) VT 2 (2005–2024) UT 2 (2013–2025) MS 2 (2012–2017) MI 2 (1994–1996) ND 2 (1999–2013) TN 2 (2000–2006)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check