Ziyadat v. Diamondrock Hospitality Co., No. 20-10485 (11th Cir. 2021)
Annotate this Case
Plaintiff filed suit against the hotel alleging a violation of 42 U.S.C. 1981, which prohibits racial discrimination in contracting. Plaintiff claimed that one of the hotel's employees falsely accused him of engaging in inappropriate behavior at the pool, that the employee did so because she harbored animus against Arabs, and that employee's accusation led to his eviction.
The Eleventh Circuit vacated the district court's dismissal of the complaint, concluding that, at this preliminary stage, plaintiff's allegations plausibly allege a circumstantial case of racial discrimination. The court explained that plaintiff adequately alleged that he was treated differently from comparators who were similarly situated to him in all material respects. In this case, he and his fiancée were hotel guests, sat by the pool, and behaved entirely appropriately; other, non-Arab hotel guests sat by the pool and acted similarly; and the towel attendant singled out him and his fiancée, fabricated a story about them, and caused them to be evicted. Furthermore, plaintiff has sufficiently alleged that the towel attendant intended to cause him a contractual injury based on the attendant's racial animus. The court noted that a cat's-paw theory of liability under section 1981 is not inconsistent with the stricter causal standard. The court remanded for further proceedings.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.