Eleventh Circuit Rejects School District’s Immunity Defense Under the Eleventh Amendment for Claims of Retaliation Under the FMLA and ADA

In Lightfoot v. Henry County School District, No. 13-14631 (Nov. 10, 2014), the Eleventh Circuit held that Henry County School District was not an “arm of the State” of Georgia and therefore was not entitled to immunity from suit in federal court under the Eleventh Amendment.

Zaneta Lightfoot was a high school teacher in Henry County. She suffers from sickle cell anemia and took leave under the FMLA during the 2010-2011 school year. Lightfoot received the most severe form of discipline apart from termination, was removed from her coaching position, and had her classroom moved to the other side of the building. After exhausting all administrative remedies with the Equal Employment Opportunity Commission, Lightfoot alleged discrimination and retaliation under the Americans with Disabilities Act (“ADA”), and retaliation under the Family Medical Leave Act (“FMLA”). She was terminated a few months after suit. The district court ultimately granted the school district’s motion for summary judgment on Lightfoot’s FMLA claim, based on Eleventh Amendment immunity. The court also denied Lightfoot’s motion for reconsideration on her ADA retaliation claim.

On appeal, the question at issue was whether the school district qualified for immunity under the Eleventh Amendment as an “arm of the state” or whether it was more akin to a “county or similar political subdivision.” Mt. Healthy City School District Board of Education v. Doyle, 429 U.S. 274, 280 (1977). The court noted that the Supreme Court and a majority of appellate courts, including the Eleventh Circuit, did not grant school districts immunity under the Eleventh Amendment. In determining whether or not the district was entitled to immunity, the court evaluated four factors: “1) how state law defines the entity; (2) what degree of control the State maintains over the entity; (3) where the entity derives its funds; (4) who is responsible for judgments against the city.” Manders v. Lee, 338 F.3d 1304, 1309 (11th Cir. 2003).

In regards to the first factor, Georgia’s Constitution and Code groups school districts with counties, municipalities, and political subdivisions, suggesting that the state considers school districts distinct from the State. The second factor also cut against a finding of immunity because Georgia school districts are not only under local control, but also maintain a substantial amount of autonomy over school affairs. Even though Georgia establishes control via certain requirements, the state only prescribed minimum requirements, which are not sufficient for Eleventh Amendment immunity. In addition, the final two factors favored Lightfoot. The school district has local fundraising capabilities and a judgment against the School District will not derive from state funds because of their fiscal autonomy from the state. Consequently, summary judgment in favor of the school district for Lightfoot’s FMLA claim was reversed and remanded for further proceedings

The court also addressed Lightfoot’s ADA retaliation claim. In her complaint, Lightfoot failed to include any evidence establishing a prima facie case of retaliation but argued on appeal that her allegations dealing with her request for FMLA leave also formed the basis of her ADA retaliation claim. The court, however, determined that the general allegations did not sufficiently place the school district on notice that the allegations also related to her ADA retaliation claim.

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