Federal Appellate Court for Florida, Georgia, and Alabama Affirms Dismissal of Worker’s Employment-Related Claims

There are many ways in which an employer can violate an employee’s rights under state, federal, or constitutional laws. However, not every disagreement about matters in the workplace is actionable in court.

Most Atlanta employment law cases go through a lengthy pre-trial phase, in which an employer may seek dismissal of all or some of the employee’s claims if the employer believes that the employee’s claim(s) is not viable. The trial court makes the initial decision in such situations, but an appellate court may eventually weigh in if one or both parties seeks further review. If you feel your rights may have been violated by your employer, it is important to discuss the matter with an Atlanta employment law attorney.

Facts of the Case

In a recent case decided by the United States Court of Appeals for the Eleventh Circuit (the circuit court that hears appeals from federal district courts located in Georgia, Florida, and Alabama), the plaintiff was a man who brought multiple claims against the defendant employer in federal court. These claims included retaliation claims under the Civil Rights Act of 1964, 42 U.S.C. ยง 2000e-3(a), (Title VII); defamation claims; alleged violations of the Federal Privacy Act; and claims that the defendant violated the plaintiff’s rights under the First Amendment, the Fourth Amendment, the Fourteenth Amendment, and Equal Protection Clause of the United States Constitution.

The federal district court dismissed the plaintiff’s complaint (as well as his amended complaint and his second amended complaint) with prejudice. The plaintiff appealed, seeking the review of the appellate court.

Decision of the Eleventh Circuit Court of Appeals

The federal circuit court affirmed the lower tribunal’s decision to dismiss the plaintiff’s case. According to the court, the plaintiff’s equal protection claim consisted of unsupported legal conclusions, which were insufficient to survive a motion to dismiss. He could not state a claim for a substantive due process violation because such claims were not available in the employment law context. With regard to his allegations regarding the defendant’s alleged procedural due process violations, the plaintiff’s claim was not viable because he could show that he had a protected property interest in his continued employment; because the plaintiff was an at-will employee, the district court was correct in dismissing his procedural due process claim.

The circuit court also found no error in the dismissal of the plaintiff’s remaining constitutional law claims, noting that the plaintiff’s speech regarding the defendant’s alleged dissemination of his social security number and his pay raise were not
matters of public concern such that a First Amendment claim would be appropriate; rather, these were matters of personal interests, which did not implicate social, political, or other issues of importance to the community.

The court also rejected the plaintiff’s argument that the district court had abused its discretion in denying him an opportunity to further amend his complaint prior to dismissing it with prejudice. In the court’s opinion, this would have been futile in light of the plaintiff’s three prior complaints.

Talk to an Atlanta Employment Lawyer

Atlanta employment law attorney John L. Mays at Parks, Chesin & Walbert handles many different types of employment-related claims. To schedule an appointment to learn more about how we can help you assert your legal rights in a court of law, call us now at 404-873-8048.

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