U.S. Court of Appeals for the Eleventh Circuit, 1994

The court held that the district court correctly treated Cooper-Houston’s Title VII claim as a circumstantial-evidence case, but exceeded its reviewing role by resolving whether racial animus motivated her termination.

The court held that when a plaintiff’s state-court complaint specifically seeks less than the diversity-jurisdiction threshold, a removing defendant must prove to a legal certainty that the plaintiff’s claim necessarily exceeds that threshold.

The court held that evidence submitted to the Appeals Council becomes part of the administrative record for judicial review whether the Council grants or denies review. Because the district court excluded the treating physician’s testimony from its review, the court reversed and remanded for the district court to…

The Eleventh Circuit reversed summary judgment on Hairston’s retaliation claims because the record could permit a jury to find both a causal connection between his protected activity and the adverse actions and that the employer’s stated reasons were pretextual.