Maritza Reyes, a plaintiff-appellant, sued Florida A&M University Board of Trustees (FAMU) in the Middle District of Florida, alleging violations of Title VII through employment discrimination, a hostile work environment, and retaliation. The district court granted summary judgment in favor of FAMU and denied Reyes's motions to file a corrected response to the summary judgment motion and to reopen discovery. Reyes appealed, arguing that her eye condition prevented her from filing a complete response, that the evidence she presented created genuine issues of material fact on all three claims, and that the district court erred in refusing to reopen discovery after FAMU filed its answer post-deadline.
The Eleventh Circuit addressed three distinct issues. First, regarding the motion to file a corrected response, the court applied the standard for excusable neglect under Federal Rule of Civil Procedure 6(b)(1)(B). The court noted that a party must show good cause and diligence. Citing Young v. City of Palm Bay, the court found that Reyes failed to demonstrate diligence because she had already received three extensions and a total of 48 days to draft her response before filing an incomplete one due to an eye condition. The court held that her 44-day delay in moving to substitute the response did not constitute excusable neglect. Second, on the merits of the Title VII claims, the court applied the McDonnell Douglas framework and the 'convincing mosaic' standard. For the discrimination claim, Reyes failed to identify a similarly situated comparator and presented no evidence that the decision-maker, Provost Maurice Edington, acted with discriminatory intent; his affidavit and letter citing a lack of scholarship were not shown to be insincere. The court emphasized that the law concerns the employer's beliefs, not the employee's. For the retaliation claim, Reyes offered no evidence of a causal connection between her protected activity and the denial of promotion. For the hostile work environment claim, the court found that the alleged conduct was not severe or pervasive and that deposition testimony did not indicate race-based harassment by any university official. Third, regarding the motion to reopen discovery, the court held that the district court did not abuse its discretion. The parties had already conducted significant discovery, including four depositions and over 1,000 pages of evidence. The court reasoned that additional discovery would not resolve any dispositive issues because proving the contents of the Nunn Memo or the committee's composition would not alter the outcome given the lack of evidence regarding the decision-maker's intent.
The decision affirms the dismissal of Reyes's employment discrimination case, reinforcing the high bar for proving a convincing mosaic of discrimination when a decision-maker provides a non-discriminatory reason. It clarifies that illness does not automatically constitute excusable neglect for missing deadlines if a party has already been granted multiple extensions. The ruling also signals that courts will deny motions to reopen discovery when the record is already extensive and additional evidence is unlikely to change the legal outcome.