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4th DCAJuly 1, 2026Affirmed⭐ Notable

Sharon Wilson v. Palm Beach County Board of County Commissioners

Case No. 2024-3347

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

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