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Jeremy Ellis v. Sheriff, Hillsborough County Florida

2026-08-25

Summary

Holding. The Court of Appeals affirmed the district court's judgment, holding that the jury instruction based on binding circuit precedent was proper and that sufficient evidence supported the jury's finding that Ellis's EEOC filing was the but-for cause of his termination.

Jeremy Ellis worked for the Hillsborough County Sheriff's Office for fifteen years until his termination in August 2022. Ellis filed charges with the EEOC and Florida Commission on Human Relations in December 2021, alleging discrimination and retaliation based on disability and religion. The charges contained some factual inaccuracies, including an error about when Ellis became a sworn officer. After filing his charges, the Sheriff's Office initiated an internal investigation and ultimately terminated Ellis, citing his false statements in the EEOC charge, public disparagement of the agency, and falsification of official documents as grounds for dismissal.

Ellis sued under Title VII and Florida law, asserting that the Sheriff's Office retaliated against him for filing protected charges. At trial, the jury found the termination was retaliatory and awarded Ellis $125,000 for lost wages and $125,000 for emotional distress. The Sheriff appealed, challenging two aspects of the district court's decision: the jury instruction that employers cannot terminate employees based on statements in EEOC charges regardless of truthfulness, and the sufficiency of evidence supporting the jury's finding of retaliation.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether an employer may terminate an employee for false statements contained in an EEOC charge
  • Whether Supreme Court precedent on but-for causation in Title VII retaliation cases abrogated prior circuit precedent protecting EEOC charge filers
  • Whether sufficient evidence established that the protected activity of filing an EEOC charge was the but-for cause of termination despite employer's articulated non-retaliatory reasons

Procedural posture

The case proceeded to trial on Title VII and Florida law retaliation claims following summary judgment on other claims, resulting in a jury verdict for Ellis, after which the Sheriff appealed the district court's denial of his post-trial motions.

Authorities cited

Opinion

majority opinion

USCA11 Case: 25-13267 Document: 37-1 Date Filed: 08/25/2026 Page: 1 of 25

FOR PUBLICATION

In the

United States Court of Appeals

For the Eleventh Circuit

No. 25-13267

Non-Argument Calendar

JEREMY ELLIS,

Plaintiff-Appellee,

versus

HILLSBOROUGH COUNTY SHERIFF'S OFFICE,

Defendant,

SHERIFF, HILLSBOROUGH COUNTY FLORIDA,

Defendant-Appellant.

Appeal from the United States District Court

for the Middle District of Florida

D.C. Docket No. 8:22-cv-02508-KKM-CPT

Before NEWSOM, BRASHER, and HULL, Circuit Judges.

PER CURIAM:

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2 Opinion of the Court 25-13267

After his termination from the Hillsborough County,

Florida, Sheriff’s Office, plaintiff Jeremy Ellis brought many

employment-related claims against the Sheriff of Hillsborough

County (the “Sheriff”) in his official capacity. Ultimately, only two

claims went to trial—Ellis’s retaliation claims brought under

(1) Title VII of the Civil Rights Act of 1964 (“Title VII”) and

(2) Florida law. The jury rendered a verdict in favor of Ellis and

awarded him damages. The Sheriff appealed.

On appeal, the Sheriff argues that the district court

(1) abused its discretion in denying his motion for a new trial

because the district court erred in instructing the jury that an

employer may not terminate an employee for statements written

in an EEOC charge even if they are false; and (2) erred in denying

his renewed motion for judgment as a matter of law because Ellis

presented insufficient evidence of causation. After careful review,

we affirm.

I. BACKGROUND

This case has a lengthy history. In 2007, the Hillsborough

County Sheriff’s Office (“HCSO”) hired Ellis as a community

service officer. In 2010, the HCSO promoted Ellis to detention

deputy. Ellis held that position until his termination in

August 2022.

In November 2022, Ellis filed his initial complaint. The

procedural history includes (1) multiple amended complaints;

(2) the district court’s summary judgment order; (3) Ellis dropping

and renumbering certain claims; and (4) the parties’ agreement

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about how to dispose of other claims. In March 2025, the case

proceeded to trial on only Ellis’s two retaliation claims against the

Sheriff in his official capacity.

Both claims at trial alleged that the HCSO terminated Ellis

in retaliation for filing his charges with the Equal Employment

Opportunity Commission (“EEOC”) and the Florida Commission

on Human Relations (“FCHR”). Ellis’s EEOC and FCHR charges

are contained in the same document, so we refer to them as the

EEOC charge. Ellis’s first claim asserted that the HCSO’s actions

violated Title VII, and his second claim asserted the HCSO’s

actions violated the Florida Civil Rights Act (“FCRA”), Fla.

Stat. § 760.10.

We recite the trial evidence. Then we analyze the claims

together because the same legal framework governs retaliation

claims under both Title VII and the FCRA. See Howard v. Walgreen

Co., 605 F.3d 1239, 1244 n.4 (11th Cir. 2010) (“Because retaliation

claims under the FCRA are substantively similar to Title VII

retaliation claims, we use the same analysis for both claims.” (citing

Harper v. Blockbuster Entm’t Corp., 139 F.3d 1385, 1387 (11th Cir.

1998))); see also Johnson v. Miami-Dade Cnty., 948 F.3d 1318, 1325

(11th Cir. 2020) (“[B]ecause the FCRA is based on Title VII,

decisions construing Title VII apply to the analysis of FCRA

claims.” (citing Harper, 139 F.3d at 1387, 1389-90)).

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II. TRIAL EVIDENCE

A. Plaintiff Jeremy Ellis

Ellis testified first. In 2007, Ellis began working for the

HCSO in a civilian position. In 2010, he became a detention officer

after completing academy training.

1. December 2021 EEOC Charge

In December 2021, Ellis filed his EEOC charge. Ellis’s

charge stated that the HCSO: (1) “discriminated against [him] and

retaliated against [him] because of [his] disability and need for a

reasonable accommodation”; and (2) “discriminated against [him]

because of [his] religion and need for an accommodation” to wear

a beard.

Ellis’s EEOC charge further stated that he had “never had

any issues at work until [he] received word that [he] was going to

receive a substandard performance evaluation.” Upon hearing

this, Ellis told superiors that he had a “debilitated state of mind,”

causing him to struggle at work.

At trial, Ellis explained these statements in his EEOC charge

by (1) clarifying that he meant he was distracted and could not

complete goals due to a lack of focus; (2) acknowledging that he

received feedback from supervisors; and (3) emphasizing that he

had not been formally disciplined or investigated when he filed the

December 2021 EEOC charge.

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Ellis acknowledged that his EEOC charge mistakenly stated

he started in 2007 as a detention officer (as opposed to 2010). Ellis

attributed his mistake to a typographical error.

On February 7, 2022, Ellis received a notice of his right to

sue from the EEOC. Because his work conditions had improved,

Ellis did not file a lawsuit in the 90-day window.

2. May 2022 Notice of Investigation and Pay Suspension

Then, on May 10, 2022, the HCSO notified Ellis in writing

that it had initiated an internal investigation and suspended him

without pay in connection with his EEOC charge. The HCSO said

that in his EEOC charge Ellis (1) falsified an official document (the

EEOC charge); and (2) publicly disparaged the HCSO.

The HCSO’s internal investigation revealed, inter alia, that

Ellis had a drinking problem. Ellis attended a pre-disciplinary

hearing in which he described his drinking and that it contributed

to his error as to his 2007 start date as a detention officer. However,

Ellis testified that (1) he never recalled going to work while under

the influence of alcohol; and (2) he attended rehab for his drinking.

Embarrassed about being an alcoholic, Ellis was not

forthcoming about his drinking problem. For example, during an

interview with Detective Denbigh as part of the HCSO’s 2022

internal investigation, Ellis did not tell Denbigh that his

misstatement on the EEOC charge—regarding his 2007 start date

as a detention officer—was likely also caused by his drinking. Ellis

did not think he was being untruthful by not telling Denbigh about

his drinking. Additionally, earlier in January 2022 (before the

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internal investigation), Ellis had completed an HCSO health form

because the HCSO ordered him to undergo a medical evaluation

after filing his EEOC charge. On that HCSO form, Ellis

untruthfully stated he had one alcoholic drink per month.

3. August 2022 Termination

In a written “Notice of Discipline Form,” the HCSO

terminated Ellis with an effective date of August 16, 2022. That

Notice did not mention Ellis’s drinking or alcoholism. Rather, the

Notice explicitly stated that Ellis’s false statements in his EEOC

charge motivated the termination, along with his failure to give

notice of a change of address. Because of the HCSO’s focus on

Ellis’s EEOC charge, we quote its termination reasons in full, as

follows:

The REASON for the action is:

On December 21, 2021, Detention Deputy Jeremy

Ellis submitted under oath a Charge of

Discrimination with the Equal Employment

Opportunity Commission (EEOC) alleging he was

discriminated against and retaliated against by [the

HCSO] because of his disability, religion, and his need

for a reasonable accommodation. The EEOC Charge

of Discrimination publicly criticized [the HCSO] in

writing, and Deputy Ellis knowingly utilized false

information to make the claim. Deputy Ellis’

administrative investigation revealed his date of hire

as a detention deputy was falsely notated within the

EEOC Charge of Discrimination. Deputy Ellis had

seven performance appraisals and evaluations

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documenting issues at work, refuting his claim of

never having issues at work. Deputy Ellis admitted

those statements to the EEOC were not true. No

evidence was found that Deputy Ellis informed [the

HCSO] about a disability or requested an

accommodation for a disability. Additionally, there

was no evidence that Deputy Ellis was discriminated

against or retaliated against due to a disability.

During Deputy Ellis’ administrative interview, he

advised that he considered his ADHD a disability but

did not request a reasonable accommodation for his

disability other than “needing to go home” when he

requested and being allowed to do so. The

administrative investigation also revealed Deputy

Ellis failed to notify [the HCSO] of a change of address

from his listed residential address. Deputy Ellis’

actions caused him to violate HCSO Rules and

Regulations 3.1.06 (Notification of Correct Address

and Phone Number), 4.1.09 (Public Disparagement),

and 4.8.04 (Falsification of Official Documents). As a

result of Deputy Ellis’ administrative investigation,

he was dismissed from [the HCSO] effective August

16, 2022.

Ellis appealed his termination to the Sheriff’s Complaint

Review Board, which consisted of two individuals selected by Ellis,

two individuals selected by the HCSO, and one individual selected

by the four other board members. The Complaint Review Board

agreed to terminate Ellis.

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After the Complaint Review Board’s decision, Ellis’s

termination was reviewed by the Sheriff’s Disciplinary Review

Board, consisting of two colonels in the HCSO. Ellis gave a

statement to the Disciplinary Review Board, in which he stated he

was “inebriated” when he wrote his EEOC charge. By

“inebriated,” Ellis said he meant “[t]ipsy, alcohol in my

system . . . [i]nebriated, drunk, tipsy, they’re all the same.”

Ellis then appealed his termination to the Sheriff or, in the

Sheriff’s absence or by his designation, the Chief Deputy. Ellis met

with then-Chief Deputy Donna Lusczynski, who sustained Ellis’s

termination.

Ellis rested, presenting no other witnesses.

B. Chief Deputy Joseph Maurer

The defendant Sheriff first presented testimony from Joseph

Maurer, the current Chief Deputy of Enforcement Operations in

the HCSO. At the time of the relevant events, Chief Deputy

Maurer was a colonel serving under then-Chief Deputy

Lusczynski.

Chief Deputy Maurer testified that Ellis violated the HCSO’s

rules (1) against publicly disparaging the HCSO by including three

false statements of fact in his EEOC charge; and (2) that employees

needed to provide their correct address, which Ellis had not done.

The first rule violation was the most serious. Chief Deputy

Maurer explained that integrity and honesty were important values

for the HCSO, and untruthfulness in any form was a serious

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matter. Maurer testified that he cared whether Ellis was truthful,

not that he had filed an EEOC charge.

The investigatory and disciplinary process raised further

concerns. Chief Deputy Maurer was concerned by Ellis’s

comments at the pre-disciplinary hearing regarding his drinking,

depression, and trouble remembering dates. During that hearing,

Ellis had an aggressive demeanor and was not remorseful or

apologetic. Moreover, Maurer testified that Ellis lied multiple

times throughout the internal investigation, causing Maurer to lose

trust in him. Maurer added: “there’s no recovering from that.”

That said, Chief Deputy Maurer testified about issues

relating to the integrity of the investigation and disciplinary process

itself. First, HCSO policy requires a detective to “interview all

identifiable witnesses before they interview the accused.” To that

end, Detective Denbigh signed her report confirming she had not

violated anyone’s rights guaranteed under Florida law, including

that she had interviewed every identifiable witness. But that

confirmation was not true because Denbigh did not interview the

two HCSO employees identified as problematic in Ellis’s EEOC

charge.

Second, Chief Deputy Maurer did not initiate an

investigation into Denbigh for making false statements because he

had not felt that Denbigh had been untruthful. Third, Denbigh did

not investigate whether the individuals Ellis complained of in his

EEOC charge were acting in a discriminatory manner and focused

on only Ellis’s inaccuracies in his EEOC charge. Fourth, as to the

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second rule violation, Maurer testified he never recommended

terminating anyone else for not updating their address.

C. Chief Deputy Donna Lusczynski

The Sheriff next presented this testimony from former Chief

Deputy Donna Lusczynski, who sustained Ellis’s termination from

the HCSO.

After reviewing the internal investigation, Chief Deputy

Lusczynski was not concerned that Ellis had filed an EEOC charge,

as that was “an employee’s right.” She believed that Ellis had

violated HCSO policy by lying in the EEOC charge.

Particularly, Chief Deputy Lusczynski was concerned that

Ellis lied about three material facts: (1) when he became a sworn

detention officer (in 2010, not 2007); (2) that he had no

performance issues; and (3) that he had a disability. Lusczynski

thought Ellis lied about when he became a sworn officer to

lengthen his tenure and did not believe it was a simple mistake

because the significance of being sworn-in was memorable.

Chief Deputy Lusczynski also testified that Ellis made

inconsistent statements during the HCSO’s internal investigation,

such as not telling Detective Denbigh that his drinking may have

caused his mistaken date in the EEOC charge.

Chief Deputy Lusczynski was bothered by Ellis not

acknowledging his untruthfulness and by his lack of remorse or

apology at the Disciplinary Review Board hearing. Lusczynski was

also concerned that Ellis stated he was intoxicated the day he filed

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the EEOC charge and that he worked the same day. On the other

hand, none of Ellis’s supervisors ever told Lusczynski that Ellis had

reported to work inebriated.

Chief Deputy Lusczynski also gave testimony that

corroborated Chief Deputy Maurer’s testimony about the issues

with the investigation. First, Lusczynski was identified in Ellis’s

EEOC charge but was never interviewed by Detective Denbigh.

Second, Denbigh was never investigated for making untruthful

statements. Third, Lusczynski never recommended an HCSO

employee for termination because they failed to update their

address.

Chief Deputy Lusczynski did not think that Ellis’s conduct

was curable such that he could work for the HCSO again because

Ellis’s credibility would be questionable going forward.

The Sheriff rested his defense. Ellis presented no further

evidence.

D. Rule 50 Motions for Judgment as a Matter of Law

After the Sheriff rested, plaintiff Ellis made a Rule 50 motion

for judgment in his favor as a matter of law. See Fed. R. Civ. P. 50.

Ellis argued that he established that his termination was unlawful

retaliation because the HCSO’s Notice admitted the HCSO

terminated Ellis because of statements in his EEOC charge. The

district court reserved ruling on Ellis’s motion. Later, after the jury

found in Ellis’s favor, the district court denied Ellis’s Rule 50

motion as moot.

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The Sheriff also made his own Rule 50 motion for judgment

in his favor. The Sheriff argued that Ellis had not established

but-for causation between his EEOC charge and termination

because the HCSO also terminated Ellis due to (1) inconsistent and

false statements he made during the HCSO’s own internal

investigation; and (2) Ellis’s drinking.1 The district court denied the

Sheriff’s Rule 50 motion, finding that there was sufficient evidence

for the jury to find but-for causation.

E. Jury Instructions

In discussing the jury instructions, the Sheriff objected to the

district court’s proposed instruction that the law does not permit

an employer to consider the contents of an employee’s EEOC

charge in deciding to terminate the employee. Ellis agreed with

the district court’s characterization that this was a correct

statement of law under our binding precedent in Pettway v. Am. Cast

Iron Pipe Co., 411 F.2d 998 (5th Cir. 1969). 2 Subsequently, the

district court gave this jury instruction as to causation, stating an

employer may not terminate an employee for false statements in

an EEOC charge, as follows:

For the third element, you must decide whether [the

HCSO] terminated Mr. Ellis because of Mr. Ellis’

1 The Sheriff made these arguments when opposing Ellis’s Rule 50 motion,

then readopted them to make his own Rule 50 motion.

2 This Court adopted as binding precedent all Fifth Circuit decisions prior to

October 1, 1981. Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981)

(en banc).

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protected activity. Put another way, you must decide

whether Mr. Ellis’ protected activity was the main

reason for [the HCSO]’s decision.

To determine that [the HCSO] took an adverse

employment action because of Mr. Ellis’ protected

activity, you must first find that, all the things

remaining the same, [the HCSO] would not have

taken the action had Mr. Ellis not engaged in the

protected activity.

[The Sheriff] claims that [the HCSO] did not

terminate Mr. Ellis because of Mr. Ellis’ EEOC charge

and that it terminated Mr. Ellis for violating [HCSO]

policies based on statements by Mr. Ellis in his Charge

and statements and conduct by Mr. Ellis during [the

HCSO]’s internal review process.

An employer may not terminate an employee because of

anything written in an EEOC charge, regardless of whether

an employer believes the content of the EEOC charge is true

or false. But an employer may terminate an employee

for any other reason, good or bad, fair or unfair, and

you may not substitute your own judgment for [the

HCSO]’s judgment, even if you do not agree with it.

(Emphasis added).

F. Verdict

The jury (1) found that the Sheriff terminated and retaliated

against Ellis because of his EEOC charge; and (2) awarded him

$125,000 for lost wages and $125,000 for mental and emotional

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14 Opinion of the Court 25-13267

anguish. The district court entered final judgment for these sums

against the Sheriff in his official capacity.

After the jury’s verdict, the Sheriff renewed his Rule 50

motion for judgment as a matter of law. In the alternative, the

Sheriff moved for a new trial or remittitur under Rule 59. See Fed.

R. Civ. P. 59. The district court denied both motions. The Sheriff

timely appealed.

III. SHERIFF’S RULE 59 MOTION BASED ON PETTWAY

JURY INSTRUCTION

On appeal, the Sheriff contends that the district court

erroneously relied on Pettway to instruct the jury as follows: “An

employer may not terminate an employee because of anything

written in an EEOC charge, regardless of whether an employer

believes the content of the EEOC charge is true or false.” The

Sheriff argues the district court erred in denying his Rule 59 motion

because of this erroneous jury instruction. The Sheriff asserts that

subsequent Supreme Court precedent abrogated Pettway and

its progeny.

After review, we conclude that Pettway remains binding

Circuit precedent. Therefore, the district court properly relied on

Pettway to instruct the jury. 3 We review our prior-panel precedent

rule and then Pettway.

3 We review a district court’s jury instructions for an abuse of discretion as to

the wording employed, but review jury instructions de novo to decide whether USCA11 Case: 25-13267 Document: 37-1 Date Filed: 08/25/2026 Page: 15 of 25

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A. The Prior-Panel Precedent Rule

Under this Court’s prior-panel precedent rule, a prior panel’s

holding is binding unless it has been overruled or abrogated by the

Supreme Court or this Court sitting en banc. Sabal Trail

Transmission, LLC v. 18.27 Acres of Land in Levy Cnty., 59 F.4th 1158,

1164 (11th Cir. 2023). As such, “[w]e are bound to apply the

precedent of a prior panel even if we are convinced that the prior

panel is mistaken about the proper analysis.” United States v.

Emmanuel, 565 F.3d 1324, 1332 (11th Cir. 2009). This includes

overlooking or misinterpreting Supreme Court precedent. Sabal

Trail Transmission, LLC, 59 F.4th at 1174 (“[U]nder our

prior-precedent rule, even if our Court ‘overlooked’ a

reason—including a Supreme Court case—we remain bound by

our prior precedent.”); United States v. Fritts, 841 F.3d 937, 942 (11th

Cir. 2016) (“[T]here is never an exception carved out for

overlooked or misinterpreted Supreme Court precedent.”).

Accordingly, this Court has “categorically reject[ed] any

exception to the prior panel precedent rule based upon a perceived

defect in the prior panel’s reasoning or analysis as it relates to the

law in existence at that time.” Smith v. GTE Corp., 236 F.3d 1292,

1303 (11th Cir. 2001).

To abrogate a prior-panel precedent, a subsequent Supreme

Court decision must “be clearly on point and clearly contrary” to

the instructions misstated the law or misled the jury. Caradigm USA LLC v.

PruittHealth, Inc., 964 F.3d 1259, 1277 n.12 (11th Cir. 2020).

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16 Opinion of the Court 25-13267

that precedent. TL90108 LLC v. Ford, 147 F.4th 1351, 1359 (11th Cir.

2025) (quoting Edwards v. U.S. Att’y Gen., 97 F.4th 725, 743 (11th

Cir. 2024)). This Court’s prior precedent remains binding “[i]f the

Supreme Court ‘never discussed our precedent and did not

otherwise comment on the precise issue before the prior panel.’”

Id. at 1359-60 (quoting Jennings v. Sec’y, Fla. Dep’t of Corr., 108 F.4th

1299, 1304 (11th Cir. 2024)). “[T]he Supreme Court decision ‘must

demolish and eviscerate each of’” the prior decision’s rationales,

and “merely weaken[ing] the holding of an earlier panel is not

sufficient to abrogate that holding.” Id. at 1360 (quoting Jennings,

108 F.4th at 1304).

With this background, we turn to Pettway and the Supreme

Court’s decision in Univ. of Tex. Sw. Med. Ctr. v. Nassar, 570 U.S. 338

(2013), on which the Sheriff relies.

B. Pettway and Nassar

In the 1969 Pettway decision, the former Fifth Circuit held

that an employer could not terminate an employee for allegedly

false statements made in an EEOC charge. Pettway, 411 F.2d

at 1007. The Court specifically concluded that an “[e]mployee can

suffer no detriment by virtue of having filed charges with EEOC

which also contain false or malicious statements. By utilizing

EEOC machinery he is exercising a protected right.” Id. In Pettway,

the employer candidly admitted to discharging its employee

because the employee made “false and malicious accusations”

about the employer in a letter to the EEOC, which the Court

considered an EEOC charge. Id. at 1002, 1007-08. Causation was

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not an issue in Pettway. The Court ordered that relief be granted

to the employee because the employer admitted terminating its

employee based on the EEOC charge. See id. at 1007-08.

Nonetheless, the Sheriff contends that Pettway “predates the

development of modern Title VII jurisprudence,” and has “been

implicitly overruled and/or [is] not consistent with Title VII’s

statutory text or purpose.” The Sheriff relies mainly on Nassar

where the Supreme Court faced the task of “defin[ing] the proper

standard of causation for Title VII retaliation claims.” Nassar, 570

U.S. at 346. In particular, the Nassar issue was whether such

retaliation claims should be analyzed under a motivating factor

standard or a but-for causation standard. Id. at 343, 346-47. After

thoroughly analyzing the statute, the Supreme Court concluded

that but-for causation is the proper standard for Title VII retaliation

claims. Id. at 351-360, 362-63.

The Sheriff argues that the Supreme Court’s requirement of

but-for causation in Nassar directly conflicts with Pettway. Nassar,

however, did not discuss Pettway or the “precise issue” of the scope

of protection afforded to those filing an EEOC charge such that it

could be said that Nassar “demolish[ed]” Pettway’s rationale.

See TL90108 LLC, 147 F.4th at 1359-60; Nassar, 570 U.S. at 351-63;

Pettway, 411 F.2d at 1007.

Undoubtedly, many aspects of Title VII litigation changed in

the forty-four years between Pettway and Nassar, but Pettway was

not premised on the lack of but-for causation, later required by

Nassar. See Nassar, 570 U.S. at 352; Pettway, 411 F.2d at 1007.

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Pettway instead answered the narrower and materially different

question of whether an employer may fire an employee for making

“false” or “malicious” statements in an EEOC charge. See Pettway,

411 F.2d at 1007.

We thus reject the Sheriff’s attempt at stretching Nassar to

disregard Pettway. “Obedience to a Supreme Court decision is one

thing, extrapolating from its implications a holding on an issue that

was not before that Court in order to upend settled circuit law is

another thing.” Main Drug, Inc. v. Aetna U.S. Healthcare, Inc., 475

F.3d 1228, 1230 (11th Cir. 2007).

Because the Sheriff does not cite any en banc decision of this

Court or decision from the Supreme Court that is clearly on point

and contrary to Pettway, it remains binding precedent in this

Circuit. The prior-panel precedent rule precludes a panel of this

Court from overturning Pettway, and it has not been undermined

to the point of abrogation.

The Sheriff raises no other issues with the jury instructions.

The district court therefore did not abuse its discretion when it

properly relied on Pettway to instruct the jury.

IV. SHERIFF’S RULE 50 MOTION BASED ON

INSUFFICIENT EVIDENCE

Next, the Sheriff argues that the district court erred in

denying his renewed Rule 50 motion because (1) the Sheriff

articulated legitimate, non-retaliatory reasons—Ellis’s drinking and

lying during the HCSO’s internal investigation—for terminating

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Ellis’s employment; and (2) Ellis failed to carry his burden to show

these reasons were pretextual and not the cause of his termination.

As table setting, we discuss Rule 50, the elements of a

retaliation claim, and how the Sheriff’s pretext arguments under

McDonnell Douglas4 play no role in post-trial motions. We then

analyze whether the trial evidence sufficiently created a jury issue

as to Ellis’s retaliation claims.

A. Rule 50 Motion for Judgment as a Matter of Law

Federal Rule of Civil Procedure 50(a) states that, if a party

has been fully heard on an issue during a jury trial and the court

determines that a reasonable jury would not have a legally

sufficient evidentiary basis to find for the party on the issue, then

the court may grant a motion for judgment as a matter of law

against the party on the claim or defense. Fed. R. Civ. P. 50(a)(1).

Rule 50(b) provides that a party may renew a denied Rule 50(a)

motion after trial. Id. R. 50(b). 5

4 McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973).

5 This Court reviews de novo the denial of a Rule 50 motion for judgment as a

matter of law, viewing the evidence in the light most favorable to the

nonmovant. St. Louis Condo. Ass’n, Inc. v. Rockhill Ins. Co., 5 F.4th 1235, 1242

(11th Cir. 2021). “Rule 50 motions should be granted ‘only when the plaintiff

presents no legally sufficient evidentiary basis for a reasonable jury to find for

him on a material element of his cause of action.’” Id. (quoting Howard v.

Walgreen Co., 605 F.3d 1239, 1242 (11th Cir. 2010)).

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20 Opinion of the Court 25-13267

B. Elements of Ellis’s Retaliation Claims

Title VII has opposition and participation clauses. The

anti-retaliation provision of Title VII provides that it “shall be an

unlawful employment practice for an employer to discriminate

against any of [its] employees” because an employee (1) “has

opposed any practice made an unlawful employment practice”

under Title VII (the “opposition clause”); or (2) “has made a charge,

testified, assisted, or participated in any manner in an investigation,

proceeding, or hearing” under Title VII (the “participation clause”).

42 U.S.C. § 2000e-3(a) (emphasis added). This case concerns the

participation clause.

The participation “clause protects proceedings and activities

which occur in conjunction with or after the filing of a formal

charge with the EEOC.” E.E.O.C. v. Total Sys. Servs., Inc., 221 F.3d

1171, 1174 (11th Cir. 2000). Even false statements made in the

context of an EEOC charge are protected under the participation

clause.6 Pettway, 411 F.2d at 1007 (holding that an employer could

not fire an employee for statements in his EEOC charge, despite

the employer believing they were false or malicious); see Total Sys.

Servs., 221 F.3d at 1175 (stating that although “false statements

made in the context of an EEOC charge (per the participation

6 In his renewed Rule 50 motion in the district court, the Sheriff “respectfully

disagree[d]” with the district court’s Pettway jury instruction but did “not

challenge that instruction for purposes of this motion.” The Sheriff did object

to the Pettway jury instruction at trial, and his Rule 59 motion for a new trial

was based in part on the Pettway jury instruction.

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25-13267 Opinion of the Court 21

clause) are protected and cannot be grounds for dismissal, . . . this

extreme level of protection for untruth is not afforded to false

statements made under the opposition clause” (citing Pettway, 411

F.2d at 1007, then citing Vasconcelos v. Meese, 907 F.2d 111, 113 (9th

Cir. 1990) (“Accusations made in the context of charges before the

[EEOC] are protected by statute; charges made outside of that

context are made at the accuser’s peril.”))).

Further, to establish a retaliation claim, the plaintiff must

show that (1) he engaged in a statutorily protected activity; (2) he

suffered an adverse employment action; and (3) there is a causal

link between the protected activity and the adverse action. Howard

v. Walgreen Co., 605 F.3d 1239, 1244 (11th Cir. 2010). “Claims of

retaliation can be supported with either direct or circumstantial

evidence.” Lapham v. Walgreen Co., 88 F.4th 879, 889 (11th

Cir. 2023).

Here, filing an EEOC charge is unquestionably a statutorily

protected activity. It is also undisputed that Ellis’s termination was

an adverse employment action. The only Rule 50 issue is thus

causation.

To establish causation in a Title VII retaliation case, the

plaintiff must show that “the desire to retaliate was the but-for

cause of the challenged employment action.” Booth v. Pasco Cnty.,

757 F.3d 1198, 1207 (11th Cir. 2014) (quoting Nassar, 570 U.S.

at 352). “Stated another way, a plaintiff must prove that had []he

not complained, []he would not have been fired.” Jefferson v. Sewon

Am., Inc., 891 F.3d 911, 924 (11th Cir. 2018).

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22 Opinion of the Court 25-13267

“Often, events have multiple but-for causes.” Bostock v.

Clayton Cnty., 590 U.S. 644, 656 (2020). Even so, “a defendant

cannot avoid liability just by citing some other factor that

contributed to its challenged employment decision.” Id. If the

illicit motive “was one but-for cause of that decision, that is enough

to trigger the law.” Id. Thus, if the defendant presents legitimate,

nonretaliatory reasons for the adverse action, “[t]he crucial

question” for the jury is not whether these proffered reasons for

the adverse action “were well-grounded but whether they actually

motivated the [employer].” Booth, 757 F.3d at 1207.

C. The Sheriff’s Pretext Arguments

The Sheriff couches his appellate arguments in the

McDonnell Douglas analytical framework. However, in Title VII

retaliation cases, this framework (including its pretext-burden

shifting) “plays no role at trial” and is “inapplicable on post-trial

motions.” Ismael v. Roundtree, 161 F.4th 752, 760 (11th Cir. 2025).

That is because “the entire evidentiary picture goes further than

pretext” and “focusing on the defendant’s justification can lead

both litigants and the court down a rabbit hole that obfuscates the

plaintiff’s affirmative claim.” Id. at 761-62 (citation modified).

Instead, “we ask whether the defendant intentionally

retaliated against the plaintiff because of the plaintiff’s protected

activity.” Id. at 762 (citing Berry v. Crestwood Healthcare LP, 84 F.4th

1300, 1310 (11th Cir. 2023)). We therefore focus our attention on

the whole trial record to determine whether Ellis presented

sufficient evidence for a reasonable jury to find that the Sheriff

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25-13267 Opinion of the Court 23

retaliated against him for filing his EEOC charge that had false

statements.

D. Analysis of Trial Evidence

Considering the trial evidence in the light most favorable to

Ellis, we conclude that sufficient evidence created a jury question

as to whether Ellis’s EEOC charge was the but-for cause of his

termination.

For starters, there was direct evidence of but-for causation.

The HCSO’s Notice stated that Ellis was terminated because his

“EEOC Charge of Discrimination publicly criticized [the HCSO] in

writing, and Deputy Ellis knowingly utilized false information to

make the claim.” And under our Circuit precedent, an employer

may not terminate an employee because of anything written in

their EEOC charge regardless of whether the employer believes

the charge is false. Pettway, 411 F.2d at 1007. The Sheriff’s

admission that Ellis’s termination was based on his EEOC charge

thus establishes the requisite causal link.

Chief Deputy Lusczynski’s and Chief Deputy Maurer’s

testimonies further support the causal link by showing that Ellis’s

EEOC charge was the driving force behind beginning the HCSO’s

internal investigation and eventually terminating Ellis.

We recognize that at trial the Sheriff articulated and

presented evidence of legitimate, nonretaliatory reasons for

terminating Ellis. Specifically, the Sheriff relies on Chief Deputy

Lusczynski’s trial testimony to argue that the HCSO terminated

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24 Opinion of the Court 25-13267

Ellis because (1) he lied about a litany of facts in the HCSO’s own

internal investigation and (2) it had concerns about his drinking. 7

The jury’s task, however, was not to decide whether these

proffered reasons for Ellis’s termination “were well-grounded.”

Booth, 757 F.3d at 1207. Rather, the jury’s job was to determine

whether those reasons “actually motivated” the HCSO to

terminate Ellis. Id. In that regard, the HCSO did not mention

those reasons in its August 2022 Notice terminating Ellis.

Lusczynski even testified that no one had expressed concern about

Ellis’s drinking before the investigation. The jury therefore had a

sufficient evidentiary basis to find that while these may have been

“well-grounded” reasons to terminate Ellis, they did not “actually

motivate[]” the HCSO to terminate Ellis. Id.

At bottom, there was sufficient evidence for a reasonable

jury to find that (1) Ellis’s EEOC charge was a but-for cause of his

termination; and (2) thus, the HCSO’s termination of Ellis was in

retaliation for filing his EEOC charge. We therefore affirm the

district court’s denial of the Sheriff’s renewed Rule 50 motion.

7 The Sheriff does not argue that Ellis’s failure to notify the HCSO of a change

in his address independently served as grounds for his termination. In fact, the

HCSO’s Internal Affairs case file for Ellis noted that failure to provide a correct

address was only “subject to reprimand.” That is consistent with trial

testimony from both Chief Deputy Lusczynski and Chief Deputy Maurer that

they never recommended an HCSO employee for termination solely because

they failed to update their address.

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V. CONCLUSION

For these reasons, we affirm the district court’s denial of the

Sheriff’s renewed Rule 50 motion for judgment as a matter of law

and his Rule 59 motion for a new trial based on the jury

instructions.

AFFIRMED.