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Deshazior v. School Board of Miami-Dade County, Florida

Citations: 217 So. 3d 151; 2017 WL 1177594; 2017 Fla. App. LEXIS 4190Docket: 16-1926

Court: District Court of Appeal of Florida; March 29, 2017; Florida; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, an employee of the School Board of Miami-Dade County filed a complaint alleging breach of a collective bargaining agreement. The School Board moved for summary judgment, contending that the employee failed to timely initiate and exhaust the grievance process as required by the agreement, and did not establish a prima facie case for breach of contract. The trial court granted summary judgment in favor of the School Board. On appeal, the appellate court affirmed the trial court's decision, finding that the affidavits submitted by the School Board were sufficient to demonstrate no genuine issue of material fact. The appellate court also upheld the trial court's exclusion of the employee's untimely evidence, finding no abuse of discretion. The court emphasized the necessity of exhausting administrative remedies when bound by a collective bargaining agreement. The employee's additional arguments were found to be without merit, and the trial court's ruling was upheld, effectively dismissing the employee's breach of contract claim.

Legal Issues Addressed

Exhaustion of Administrative Remedies

Application: The court determined that Deshazior's failure to exhaust the grievance process as outlined in the collective bargaining agreement barred his breach of contract claim against the School Board.

Reasoning: The appellate court affirmed the trial court's decision...that it is established law that a party must exhaust administrative remedies before pursuing litigation if bound by a collective bargaining agreement.

Summary Judgment Standards

Application: The court found the School Board's affidavits to be competent and legally sufficient, demonstrating no genuine issue of material fact, justifying the trial court's grant of summary judgment.

Reasoning: The appellate court affirmed the trial court's decision, finding the affidavits submitted by the School Board to be competent evidence and legally sufficient to demonstrate no genuine issue of material fact existed.

Timeliness of Evidence Submission

Application: The appellate court upheld the trial court's decision to exclude Deshazior's untimely submitted evidence opposing summary judgment, finding no abuse of discretion.

Reasoning: The court ruled that Deshazior’s notice of evidence opposing the summary judgment was untimely, and the trial court's exclusion of this evidence was not an abuse of discretion.