Steak N Shake, Inc. v. Wilfred Ramos, Jr.
The Florida Supreme Court resolved a certified conflict between the Second and Fourth District Courts of Appeal, holding that a claimant exhausts the FCRA's administrative remedy requirement by filing an EEOC charge dual-filed with the Florida Commission on Human Relations even when the charge references only federal law (such as the ADA) and never specifically mentions the FCRA. Analyzing the text of section 760.11(1), the Court found that the statute's 'short and plain statement' requirement does not demand identification of the specific law allegedly violated, and that 'relief sought' means the remedy requested, not citation to the enabling statute.
Key facts
- Ramos was employed as a grill operator at Steak N Shake and suffered an off-the-job back injury; Steak N Shake allegedly reduced his work schedule and ultimately terminated him, which Ramos claims was retaliation for his disability and requests for reasonable accommodation.
- Ramos filed an EEOC charge in 2017 marking 'Disability' and 'Retaliation,' described his ADA claims, and checked the prepared statement requesting dual filing with both the EEOC and the state agency.
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Holdings
- An EEOC charge dual-filed with the Florida Commission on Human Relations satisfies the FCRA's administrative exhaustion requirement even if it references only federal anti-discrimination…
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