In Adams ex rel. Kasper v. School Board of St. Johns County, the United States Court of Appeals for the Eleventh Circuit considered a challenge to a Florida high school’s policy prohibiting transgender students from using the bathroom of the gender with which they identify. The plaintiff, a transgender male, challenged the policy under the Fourteenth Amendment’s Equal Protection clause and Title IX of the Education Amendments Act of 1972. The court affirmed the district court’s judgment on both grounds, with one judge dissenting, holding that the School Board’s policy violated both the Fourteenth Amendment’s Equal Protection Clause and Title IX’s prohibition of sex discrimination in education. Although not specifically decided, the case tees up a potential challenge to sex-separated bathrooms.
In Mama Jo’s Inc. v. Sparta Insurance Co., the United States Court of Appeals for the Eleventh Circuit held that an insurer properly denied coverage for a restaurant’s cleaning and business interruption claims because neither claim satisfied the policy’s “direct physical loss” requirement. The Mama Jo’s decision may be used by insurance companies arguing that denial of claims was proper based on the lack of any “direct physical loss,” as required by many policies. Though pandemic-related case law is still developing, Mama Jo’s may have major impacts on the outcome of such litigation.
In Susan Monaghan v. Worldpay US, Inc., the Eleventh Circuit reversed a district court’s grant of summary judgment in a Title VII retaliation complaint. This decision clarifies the requirements needed for successful Title VII retaliation claims.
In a case of first impression, Boatman v. Berreto, the Eleventh Circuit Court of Appeals considered whether a civilly committed person could utilize the prison mailbox rule. The original mailbox rule, stemming from contract law, is the principle that filing or service of a document occurs on the date of mailing. Similarly, the Federal Rule of Appellate Procedure 4(c)(1), sometimes called the prison mailbox rule, allows an inmate’s notice of appeal to be considered timely if it was “deposited in the institution’s internal mail system on or before the last day for filing.” In the Eleventh Circuit, a pro se inmate’s notice of appeal is presumed submitted on the day he signed it, absent contrary evidence.