Case Explained: Non-Argument Calendar WANDA JEAN-BAPTISTE v. CITY OF MIAMI

Court: United States Court of Appeals for the Eleventh Circuit

Filed: 2026-07-02

Docket: 1:23-cv-22670-MD

The eleventh-circuit affirmed the district court’s grant of summary judgment to the City of Miami on Wanda Jean-Baptiste’s claims of retaliation under the Florida Whistleblower’s Act and Title VII, as well as her claim of race discrimination in violation of Title VII. The court held that Jean-Baptiste failed to present sufficient evidence for a reasonable jury to find in her favor regarding any of the three claims. Regarding the retaliation claims, the court applied the standard requiring proof of protected conduct, an adverse employment action, and a causal connection between the two. The court found that Jean-Baptiste abandoned her arguments on appeal by failing to cite specific record evidence to support her assertions of pretext or suspicious timing. Furthermore, regarding her Title VII retaliation claim, the court determined that causation was lacking because the disciplinary actions (a 40-hour suspension and permanent transfer) had already been recommended by a panel three months prior to the email she alleged constituted protected activity; under Eleventh Circuit precedent, temporal proximity is insufficient to establish causation when the employer contemplated the adverse action before the protected conduct occurred. Regarding the race discrimination claim, the court applied the standard that a plaintiff must produce evidence showing that the reason for an adverse employment action was illegal discrimination. The court found Jean-Baptiste failed to establish a prima facie case because her proposed comparators were not similarly situated; she provided no record evidence regarding their disciplinary records or the specific discipline they received, and the record indicated only her misconduct resulted in a wrongful termination. Additionally, the court declined to consider portions of the appellate record that had been stricken by the district court, noting Jean-Baptiste did not challenge those striking orders on appeal. The practical consequence is that the judgment in favor of the City of Miami stands, and Jean-Baptiste’s lawsuit is dismissed without a trial on the merits.

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