Dolch v. Sixth Judicial Circuit Court of Florida

CourtDistrict Court, M.D. Florida
DecidedMay 6, 2025
Docket8:24-cv-01521
StatusUnknown

This text of Dolch v. Sixth Judicial Circuit Court of Florida (Dolch v. Sixth Judicial Circuit Court of Florida) 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
Dolch v. Sixth Judicial Circuit Court of Florida, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

JESSICA DOLCH,

Plaintiff,

v. Case No: 8:24-cv-1521-KKM-TGW

SIXTH JUDICIAL CIRCUIT,

Defendant. ___________________________________

ORDER Jessica Dolch sues the Sixth Judicial Circuit of Florida and alleges violations of the Florida Civil Rights Act (FCRA), the Family and Medical Leave Act

(FMLA), and the Florida Whistleblower Act (FWA). Sec. Am. Compl. (Doc. 14). The Sixth Circuit moves to dismiss Dolch’s Second Amended Complaint. Motion to Dismiss (MTD) (Doc. 15); Sec. Am. Compl. For the reasons below, I grant in part and deny in part the motion. I. BACKGROUND Jessica Dolch began her tenure with the Sixth Circuit in 2014 as an employee in human resources. Sec. Am. Compl. ¶ 3. The Sixth Circuit initially hired Dolch as a Human Resource Generalist and then “reclassified” her position to Human

Resources Analyst II in October 2022. . ¶ 4. Dolch remained in that position until she resigned. . During her employment, she completed various training programs

and attained several certifications. . ¶¶ 6–14. In 2019, Dolch was diagnosed with Undifferentiated Connective Tissue

Disease (lupus). . ¶¶ 15–16. She advised her supervisors of her diagnosis. . ¶ 16. The Sixth Circuit initially made certain accommodations for Dolch, including allowing her to work remotely three days a week and to take one day off per month

for her lupus drug infusion treatment. . ¶¶ 17–18, 20. The Sixth Circuit also allowed Dolch to utilize remote work whenever she had lupus-related “flare ups.” .

¶ 19. In July 2023, the Sixth Circuit moved to a new annex, which did not have

parking for the Human Resources Department. . ¶¶ 21–22. Because the summer heat negatively affected Dolch’s lupus, she requested to park in the closer handicap parking space. . ¶ 23. The Sixth Circuit denied her request because the spot was

reserved for another employee with a broken foot. . No further accommodation was made regarding the parking spot. . One day after walking from the parking

lot to her office in the annex, Dolch fainted in her office. . ¶ 24. After this episode, she asked security if something could be done to

accommodate her because walking from the parking lot to the office had caused her to pass out. . ¶ 25. Because one of Dolch’s immediate supervisors worked from

home on Fridays, Dolch was told she could park in that spot on Fridays. . ¶ 26. But no accommodation was made for parking on Thursdays, the other day Dolch

worked onsite. . In 2023, a Human Resources Manager position became available. . ¶¶ 27– 28. The Sixth Circuit advertised the position both internally and externally, though

the usual practice had been to advertise it internally first. . ¶ 28. Dolch applied to the position and was given an interview, but the interview process “did not follow

the guidelines in the handbook.” . ¶¶ 29–30. Though the interview panel should have consisted of three interviewers, it only consisted of two, who were “in [a]

supervisory position over her.” . ¶¶ 29–30, 33. And although only one interview ordinarily occurs, two were arranged for Dolch, the second including a judge, which was unusual. . ¶ 31. Dolch expressed her concerns about these irregularities. .

¶ 32. On September 6, 2023, prior to her second interview, Dolch sent the

interviewers an email informing them that she had a lupus infusion treatment scheduled for Friday, September 8, 2023, at 11 A.M., and that she would not work

past 9:45 A.M. that morning to commute to the appointment. . ¶ 33. Dolch was informed after sending that email that her interview was scheduled for September 8,

2023, “during the time of her infusion.” . ¶¶ 34, 60. A human resources analyst, Ms. Sprowell, informed Dolch that she had told the interviewers “that they were

scheduling Plaintiff’s second interview on the same day as her medical appointment.” . ¶ 35. Dolch thereafter withdrew her application from the manager position, stating

in an email that “the disparate treatment was not worth having a toxic supervisor who could not make it any more obvious she does not like me, and did not want me

in that role.” . ¶ 36. Ms. Riyad, who was one of the interviewers and Dolch’s immediate supervisor, told Dolch she should have said something if there was a

problem with the interview date but did not offer Dolch an opportunity to interview at a different time. . ¶¶ 37, 39. At some point after withdrawing her application, Dolch requested to go on

intermittent FMLA leave to care for her husband and father. . ¶ 40. Her husband “needed surgery” and her father “came out of remission from cancer.” . In response,

her direct supervisor and the Trial Court Administrator told Dolch she needed “to submit a set schedule she could work while out on intermittent leave.” . ¶ 41. As

Dolch was uncertain of when her father and husband would need care, she could not submit a set schedule and was therefore “forced to go out on full-time FMLA leave.”

. ¶ 43. Upon her return from FMLA leave, Dolch received “significant new job

duties.” . ¶ 44. Some of these duties involved duties of the manager position for which she had applied, and some duties were previously done by the assistant that Dolch supervised. . These responsibilities “increased stress which exacerbated the

symptoms of [Dolch’s] lupus.” . ¶ 45. Also upon her return, the new Human Resources Manager asked Dolch to record administrative leave as “free leave” since

he had not kept track of the leave, which Dolch refused to do, believing it to “constitute[] fraud.” . ¶ 46.

Dolch contacted the General Counsel of the Office of the State Court Administrator (OSCA) about being asked to record leave incorrectly. . ¶ 47. The General Counsel advised her to contact the Sixth Circuit Court Counsel, “out of

respect for the courts,” instead of going to the Inspector General. . The Sixth Circuit Court Counsel told Dolch the matter would be “handled in house” and not

to involve the Inspector General. . Dolch resigned at some point after these events. . ¶ 4. After resigning, she

submitted an “[Americans with Disabilities Act] grievance” to the OSCA and a charge to the EEOC, and then filed this lawsuit against the Sixth Circuit. . at 1–

2, ¶ 48. The Sixth Circuit moves to dismiss. MTD. II. LEGAL STANDARD

Federal Rule of Civil Procedure 8(a)(2) requires “a short and plain statement of the claim showing that the pleader is entitled to relief.” is pleading standard “does not require ‘detailed factual allegations,’ but it demands more than an

unadorned, the-defendant-unlawfully-harmed-me accusation.” , 556 U.S. 662, 678 (2009) (quoting , 550 U.S. 544, 555

(2007)). “A pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of

the elements of a cause of action will not do.’ ” (quoting , 550 U.S. at 555). “Nor does a complaint suffice if it tenders ‘naked assertion[s]’ devoid of ‘further

factual enhancement.’ ” (quoting , 550 U.S. at 557). “To survive a motion to dismiss” for failure to state a claim, a plaintiff must plead sufficient facts to state a claim that is “plausible on its face.” (quoting , 550 U.S. at 570). A claim is plausible on its face when a “plaintiff pleads factual content that allows the court to draw the reasonable inference that the

defendant is liable for the misconduct alleged.” “In analyzing the sufficiency of the complaint,” I may consider “well-pleaded

Free access — add to your briefcase to read the full text and ask questions with AI

Related

William Collado v. United Parcel Service Co.
419 F.3d 1143 (Eleventh Circuit, 2005)
June Cruz v. Publix Super Markets, Inc.
428 F.3d 1379 (Eleventh Circuit, 2005)
Pielage v. McConnell
516 F.3d 1282 (Eleventh Circuit, 2008)
Crenshaw v. Lister
556 F.3d 1283 (Eleventh Circuit, 2009)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
John Sims v. Trus Joist MacMillan
22 F.3d 1059 (Eleventh Circuit, 1994)
Razner v. Wellington Regional Medical Center, Inc.
837 So. 2d 437 (District Court of Appeal of Florida, 2002)
University of Central Florida Board of Trustees v. Turkiewicz
21 So. 3d 141 (District Court of Appeal of Florida, 2009)
Woodham v. Blue Cross and Blue Shield of Fla., Inc.
829 So. 2d 891 (Supreme Court of Florida, 2002)
Deas v. Volunteers of America
98 F. Supp. 2d 464 (S.D. New York, 2000)
Peguy Delva v. The Continental Group, Inc.
137 So. 3d 371 (Supreme Court of Florida, 2014)
Regina White v. Beltram Edge Tool Supply, Inc.
789 F.3d 1188 (Eleventh Circuit, 2015)
Barbara Rustowicz v. North Broward Hospital District n/k/a Broward Health
174 So. 3d 414 (District Court of Appeal of Florida, 2015)
Jenny Martin v. Eli Lilly & Co.
702 F. App'x 952 (Eleventh Circuit, 2017)
Ebonie Batson v. The Salvation Army
897 F.3d 1320 (Eleventh Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Dolch v. Sixth Judicial Circuit Court of Florida, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dolch-v-sixth-judicial-circuit-court-of-florida-flmd-2025.