Tynes v. Florida Department of Juvenile Justice, No. 21-13245 (11th Cir. 2023)
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This case concerns an appeal by the Florida Department of Juvenile Justice (the "Department") against a jury's verdict in favor of Lawanna Tynes, a former employee. Tynes had sued the Department for race and sex discrimination under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981, after she was terminated from her position as the superintendent of the Broward Regional Juvenile Detention Center. The Department argued on appeal that Tynes failed to establish a prima facie case of discrimination, as required under the evidentiary framework set by the McDonnell Douglas Corp. v. Green case, because the comparator employees she presented were not similarly situated in all material respects.
However, the United States Court of Appeals for the Eleventh Circuit affirmed the district court's judgment. The appellate court ruled that the Department's focus on the McDonnell Douglas framework and the adequacy of Tynes's comparators missed the ultimate question in a discrimination case, which is whether there is enough evidence to show that the reason for an adverse employment action was illegal discrimination. The jury found that the Department had intentionally discriminated against Tynes, and the Department did not challenge the sufficiency of the evidence for that conclusion on appeal. Therefore, the Department's arguments regarding the adequacy of Tynes's comparators and the insufficiency of her prima facie case were irrelevant and did not disturb the jury's verdict.
The Department also challenged the jury's verdict on Tynes's § 1981 claim, arguing that her complaint did not adequately plead the § 1981 claim and that she did not prove that race was a but-for cause of her termination. However, the appellate court found that the Department had forfeited both arguments because it failed to challenge the district court's authority to allow an amendment to the pleadings during the trial under Rule 15(b)(1) of the Federal Rules of Civil Procedure and did not argue that Tynes failed to prove that race was a but-for cause in its post-trial motion.
Therefore, the appellate court affirmed the district court's judgment in favor of Tynes on both her Title VII and § 1981 claims.
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