St. Louis v. Florida International University

Citations: 60 So. 3d 455; 2011 Fla. App. LEXIS 4356; 111 Fair Empl. Prac. Cas. (BNA) 1800; 2011 WL 1135359Docket: Nos. 3D08-2316, 3D08-2326

Court: District Court of Appeal of Florida; March 30, 2011; Florida; State Appellate Court

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Sean St. Louis appealed a final judgment that awarded him $72,241 in lost wages and $2.5 million in compensatory damages based on claims of racial discrimination and retaliation against his former employer, Florida International University (FIU). The court found that St. Louis did not establish a prima facie case for either claim, leading to a reversal of the jury verdict and rendering other issues moot.

St. Louis, a Trinidadian man, was hired by FIU in 1997 and promoted to Associate Controller of the Contracts and Grants Department, where he managed compliance with federal accounting regulations for grants. While St. Louis contends he was a competent employee, FIU argued that his department was dysfunctional and that faculty members were dissatisfied with his service.

In 2002, a federal audit proposed a $25 million fine against FIU for accounting violations, which was eventually settled for $11.5 million. Following the audit, FIU announced a restructuring that led to St. Louis's position being abolished in 2004. He was informed that his role would be eliminated due to departmental reorganization under Dr. George Dambach, who was tasked with improving grant compliance.

St. Louis applied for the newly created Director Post-Award position but was selected only for a preliminary interview. Committee members noted that he failed to demonstrate a vision for the department's future or an understanding of the changes required in the new role, asserting no distinction between his previous and prospective responsibilities.

St. Louis sought support from FIU to enhance faculty cooperation for his initiatives but was not recommended for the Director Post-Award position, which remained vacant for 19 months. During this time, an Associate Vice President took on many of the role's responsibilities. Aida Reus, initially hired as a Grants Financial Manager in March 2005, was eventually promoted to Director Post-Award in May 2006. St. Louis raised concerns of racial discrimination in October 2004 when informed of his department's elimination, reporting his grievances to Paul Michaud and Harlan Sands; however, Michaud was not on the search committee, and Sands recused himself from discussions about St. Louis. After not being recommended for the new position, St. Louis resigned, alleging his termination stemmed from racial animus in his resignation letter, although no evidence supported claims of racially derogatory comments from FIU officials. He subsequently filed a lawsuit against FIU, claiming racial discrimination and retaliation, resulting in a jury verdict favoring St. Louis with a monetary award. FIU's attempts to challenge the verdict and limit the damages based on statutory caps were denied by the trial court. The Florida Civil Rights Act of 1992 prohibits racial discrimination in employment, establishing a framework for discrimination claims that requires plaintiffs to demonstrate a prima facie case, after which the burden shifts to the employer to provide a legitimate reason for the employment action.

The employer's burden in a discrimination case is to provide non-discriminatory reasons for its employment actions, after which the employee must demonstrate that these reasons are a pretext for discrimination. To establish a prima facie case of racial discrimination under the McDonnell Douglas framework, the employee must prove four elements: 1) belonging to a protected class, 2) being qualified for the position applied for, 3) being rejected despite qualifications, and 4) that similarly situated employees outside the protected class were treated more favorably. St. Louis failed to satisfy the fourth element, claiming Aida Reus, who is outside his protected class, was treated more favorably by assuming his former role. However, evidence shows Reus was hired as a Grants Financial Manager, not as Director Post-Award, and her responsibilities did not match those of the Director position. St. Louis argued that Reus's later promotion to Director Post-Award qualified her as a similarly situated employee; however, the timing of her promotion—nearly nineteen months after St. Louis applied—does not infer discriminatory intent. The court noted that not every organizational change indicates discrimination. Consequently, St. Louis did not establish a prima facie case of racial discrimination, and the verdict could not be based on mere speculation. As a result, the court should have granted FIU's Motion for Directed Verdict on this claim.

Regarding retaliation claims, it is unlawful for an employer to discriminate against anyone opposing unlawful employment practices. The framework for proving retaliation mirrors that of discrimination, requiring the employee to first establish a prima facie case, after which the burden shifts to the employer to provide a legitimate reason for the adverse action taken.

The employee bears the burden of demonstrating that the legitimate reason given for an adverse employment action was a pretext for prohibited retaliation. To establish a prima facie case of retaliation, the employee must prove: 1) engagement in a statutorily protected expression; 2) occurrence of an adverse employment action; and 3) a causal connection between the protected expression and the adverse action. In the case of St. Louis, he claimed he was not recommended for a Director Post-Award position due to racial animus linked to his termination as Associate Controller, which he communicated to FIU's HR Vice President and his supervisor prior to the committee's decision. Despite having engaged in a protected activity, St. Louis failed to provide evidence that the search committee was aware of his allegations, as the individuals he spoke to were either not part of the committee or did not participate in discussions about him. To satisfy the causal connection requirement, the employee must show the decision-makers knew of the protected expression at the time of the adverse action, which St. Louis did not do. Consequently, his retaliation claim was unsuccessful, and the trial court's jury verdict was reversed, directing that judgment be entered for FIU. All other issues raised became moot due to this decision.