Andrew Brown v. CSX Transportation, Inc.

CourtDistrict Court, M.D. Florida
DecidedJanuary 23, 2026
Docket8:24-cv-02777
StatusUnknown

This text of Andrew Brown v. CSX Transportation, Inc. (Andrew Brown v. CSX Transportation, Inc.) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Andrew Brown v. CSX Transportation, Inc., (M.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

ANDREW BROWN,

Plaintiff,

v. Case No. 8:24-cv-2777-VMC-LSG

CSX TRANSPORTATION, INC.,

Defendant. /

ORDER This matter is before the Court on consideration of Defendant CSX Transportation, Inc.’s Motion for Summary Judgment (Doc. # 174), filed on October 14, 2025. Plaintiff Andrew Brown responded on November 12, 2025. (Doc. # 180). CSX replied on November 26, 2025. (Doc. # 186). For the reasons that follow, the Motion is granted in part and denied in part. I. Background:

A. The Parties “CSX is a freight railroad headquartered in Jacksonville, Florida that has approximately 23,000 employees.” (Johnson Decl. at ¶ 1). Mr. Brown began working for CSX as a conductor in July 2006. (Pl. Depo. at 27:2-5). Mr. Brown worked in CSX’s Train & Engine (“T&E”) service, and the terms of his employment were governed by a collective bargaining agreement (“CBA”). (Doc. # 15-11 at ¶ 2). B. Staffing and Scheduling Procedures for T&E Employees

CSX “operates a 365-days-a-year business,” which requires some employees to work on weekends and holidays. (Doc. # 152 at ¶ 1). T&E employees like Mr. Brown “do not work a set schedule and instead are called to work on an as- needed basis.” (Doc. # 15-3 at ¶ 6; Pl. Depo. at 29:9-30:3). “T&E employees indicate that they are available for work by ‘marking up’ for it, and indicate that they are not available for work by ‘marking off.’” (Doc. # 15-3 at ¶ 6). If an employee marks off from work for FMLA leave, “the leave period starts when the employee marks off from work and ends when the employee marks back up for work.” (Id.). Many T&E employees are assigned to “pools” that operate trains between two or more locations. (Doc. # 15-11 at ¶ 3). Mr. Brown’s pool operated trains between Jacksonville and the Tampa area. (Pl. Depo. at 39:23-40:1). Employees in a pool are placed on a board based on when they returned to their home terminal and are called in to work on a rotating basis. (Doc. # 15-11 at ¶ 3). “When a train is ready for departure, the employee at the top of the board is called to work.” (Id.). “Federal law prohibits employees who operate trains from being on duty for more than 12 consecutive hours, and requires at least 10 consecutive hours of rest between on- duty periods.” (Id. at ¶ 4). “Accordingly, upon arriving at the away-from-home terminal, employees in pool service often stay overnight for their federally-mandated rest period, and are then called to operate a train back to their home terminal

sometime later.” (Id.). When Mr. Brown was assigned to a pool, he was on-call 24 hours a day unless he was marked off for some reason or on required rest. (Pl. Depo. at 29:17-31:2). Although T&E employees had vacation days, the number of employees permitted to take vacation on any particular day was capped. (Id. at 25:10-26:12; Varecka Depo. at 68:13-69:7; Bright Depo. at 33:22-35:11). If T&E employees marked off as sick, they would be assessed points under CSX’s Attendance Points System (“CAPS”), which could lead to discipline. (Doc. # 15-11 at ¶ 11; Doc. # 15-15). Points were not assessed if an employee took FMLA leave. (Doc. # 15-11 at ¶ 11). After

CSX implemented this attendance policy in or around 2015, “requests for or the use of FMLA” “nearly . . . doubled or tripled.” (2018 Jolanda Johnson Depo. at 49:14-50:2). C. CSX Disciplinary Procedures Pursuant to CSX policy, dishonesty is a dismissible offense. (Doc. # 174-17). The CBA sets forth the disciplinary process and procedures applicable to union members. (Doc. # 113-3 at ¶ 2). “The first step in the disciplinary process is to notify the employee in writing of the charges.” (Id. at ¶ 3). “Then, unless the employee waives his right to a hearing

and admits the misconduct, CSX holds a hearing on the charges.” (Id.). “A CSX manager – known as the ‘hearing officer’ – conducts the hearing, questioning witnesses and ruling on evidentiary objections. A Company official – sometimes referred to as the ‘charging officer’ – testifies about the basis of the charges.” (Id.). Charged employees can be represented by a union representative and present testimony and evidence in their defense. (Id. at ¶ 4; John Johnson Depo. at 13:13-16). “After the hearing, the hearing officer may issue findings, but does not issue discipline.” (Doc. # 113-3 at ¶ 5). “Typically, disciplinary decisions are made by either the

General Superintendent for the Region or his designee, after receiving a recommendation from Labor Relations.” (Id.). “The hearing officer’s findings are not binding on the manager(s) who ultimately decide on discipline.” (Id.). An employee may challenge CSX’s disciplinary determination by filing a grievance pursuant to the CBA. (Doc. # 15-11 at ¶ 17). The CBA establishes a “multi-step grievance process culminating in final and binding arbitration,” in which the “arbitrator can reduce or overturn the discipline.” (Id.). Pursuant to the CBA, CSX may suspend an employee charged

with a major offense, such as dishonesty, pending a hearing. (Id. at ¶ 15; Doc. # 174-17). The CBA also provides that employees must be charged within 10 days from the date the offense is discovered, and that CSX must make its disciplinary determination within 30 days of the hearing. (Doc. # 15-14 at 4, 8). D. Mr. Brown’s Application for and Initial Use of FMLA Leave

In May 2017, Mr. Brown applied for intermittent FMLA leave for “major depression and insomnia.” (Doc. # 174-3 at 2). Mr. Brown’s doctor estimated that Mr. Brown would need to take intermittent FMLA leave once a month for up to two days per episode due to his conditions. (Id.). CSX approved the application. (Pl. Depo. at 55:13-15). FMLA leave is not to be used to avoid working on weekends or holidays. (2018 Jolanda Johnson Depo. at 195:7-11). In August 2017, CSX sent Mr. Brown a warning letter after he used FMLA leave on four weekends over a six-week period. (Doc. # 174-4). Although Mr. Brown testified that he did not recall receiving that letter, he does not deny that it was sent or dispute its accuracy. (Pl. Depo. at 57:15-58:22; Doc. # 174- 8 at 32:13-21). The letter stated that CSX had reviewed Mr. Brown’s work history and determined that it appeared that he

was misusing FMLA leave “as supported by [his] established pattern of marking off FMLA leave on the weekends, in conjunction with other days off (i.e. rest days, vacation days, etc.), holidays or other pattern as indicated on the attached page.” (Doc. # 174-4 at 2). The letter further stated that continued FMLA misuse could lead to a disciplinary hearing. (Id.). E. CSX Implements an Automated System for Identifying Employees to Investigate for FMLA Misuse

In 2016, CSX implemented an automated process of identifying employees whose FMLA usage met certain criteria. (2018 Jolanda Johnson Depo. at 40:5-42:3). The purpose of this system was to identify employees who demonstrated a pattern of FMLA usage to extend their time off. (Id. at 42:16- 46:16, 55:3-56:23, 59:2-62:23). The program identified employees who had used FMLA leave on the weekend or in conjunction with any scheduled days off five times over the last 12 weeks. (Id. at 59:3-61:21, 69:5-70:4, 101:18-22). The criteria for what the program flagged as potential FMLA misuse were determined by looking at dates in which CSX had high FMLA usage. (Id. at 158:20-162:25). CSX Senior Benefits Manager Jolanda Johnson determined the criteria in collaboration with CSX’s Labor Relations, Crew Management,

and Law Departments. (Id. at 41:19-42:1, 44:3-9, 55:9-15). Each week, Ms. Johnson receives an email with the names of flagged employees and conducts “an individualized review” of each employee’s FMLA usage. (Id. at 38:19-40:10). In conducting this review, Ms.

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