Eleventh Circuit

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Monaghan v. Wordplay U.S., Inc.; Eleventh Circuit Clarifies the Standard for Title VII Retaliation Claims

Taylor A. Johnson

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.



Boatman v. Berreto: Prison Mailbox Rule Applies to Civilly Committed People

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Carson Smith*

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.