Tynes v. Florida Department of Juvenile Justice

Lawanna Tynes (plaintiff) worked for the Florida Department of Juvenile Justice (department) (defendant) as a superintendent for a juvenile-detention center. One day, while Tynes was on leave, a high number of incidents occurred at the center. Following the incidents, department secretary Dixie Fosler terminated Tynes, citing poor performance, negligence, and misconduct. Tynes, who had not previously received any reprimands, sued the department, alleging that her termination resulted from race and sex discrimination in violation of Title VII of the Civil Rights Act of 1964 (Title VII). To support her claim, Tynes pointed to two superintendents, a White male and a White female, as comparators. Both had had similar incidents at their centers but received only oral reprimands. Additionally, Tynes’s direct supervisor testified that Tynes’s termination resulted from Fosler’s personal bias. At trial, Fosler struggled to recall the basis for her findings and failed to show any other employees were terminated without receiving reprimands. The jury held in Tynes’s favor and awarded damages. The district court ordered the department to reinstate Tynes. The department moved for judgment as a matter of law, arguing that judgment in Tynes’s favor was improper because she had not presented comparators who were similarly situated in all material aspects and had therefore failed to make a prima facie case under the McDonnell Douglas framework. The district court denied the motion. The department appealed.