Employment & Labor Law
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HINES v. WIDNALL
16 Fla. L. Weekly Fed. C780a (11th Circuit, June 27, 2003)
The plaintiffs were 5 African-American civilian employees at Eglin Air Force Base. They were attempting to file a class action suit against Eglin for race discrimination. Two were applicants, and three were current employees. Eglin used a centralized personnel ratings system based on algorithmic formulas that assigned weights to such factors as qualifications and past performance. The district court entered summary judgment for Eglin against the two applicants on the grounds they did not exhaust their available administrative remedies. The three current employees had reached settlement agreements with Eglin, and the district court dismissed their claims.
The appellate court affirmed with regard to the applicants but stated the three current employees could still have standing to appeal the denial of class certification even though they had settled their individual claims against Eglin. The district court ruled the three employees did not adequately represent the spectrum of jobs and divisions at Eglin because the class was too broad; therefore, they did not meet the requirements of class certification under Rule 23(a) of the Federal Rules of Civil Procedure. The court of appeals determined this was within the court
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