Sharon Wilson v. Palm Beach County Board of County Commissioners
The Fourth DCA affirmed that Florida's $200,000 sovereign immunity recovery cap in section 768.28(5) applies to an FCRA judgment against a county and is not preempted by Title VII's higher federal damages caps. Following the Eleventh Circuit's Bradshaw decision, the court held that Title VII permits states to enact anti-discrimination laws with whatever remedies they choose, so a lower state cap does not obstruct Congress's objectives.
Key facts
- Sharon Wilson sued Palm Beach County for employment discrimination under the Florida Civil Rights Act; a jury awarded $243,372 in economic damages and $500,000 in non-economic damages (later remitted to $60,000).
- The County stood ready to pay the $200,000 sovereign immunity cap under section 768.28(5) but Wilson sought recovery up to Title VII's higher federal damages caps.
- +1 more key fact with a free trial
Holdings
- Title VII does not preempt the FCRA's recovery cap (section 768.28(5)); a state may impose liability with any remedy it chooses so long as it does not require or permit conduct Title VII…
- +1 more holding with a free trial
Why it matters
This is an important damages decision for employment and civil-rights litigators suing Florida governmental entities: plaintiffs bringing FCRA claims are capped at the section 768.28(5) sovereign immunity limit (here… — full analysis with a trial
Read the full opinion, holdings & search — free for 30 days
The full opinion PDF, the rules the court applied, our significance analysis, the background facts, and full-text search across every tracked Florida decision — in your hands.
- Search every tracked Florida decision in seconds
- Save, tag & file the cases that matter into your own library
- Read the full plain-English analysis and holdings
Not ready to sign up? Get the free Friday digest — the week's key Florida decisions by email, no login required.
Florida Court Tracker provides summaries of publicly available court opinions for informational and research purposes only. This is not legal advice and does not create an attorney–client relationship. Always verify holdings against the official opinion.