Emily Laughlin v. Miami-Dade County, Florida

CourtCourt of Appeals for the Eleventh Circuit
DecidedDecember 15, 2025
Docket24-13284
StatusUnpublished

This text of Emily Laughlin v. Miami-Dade County, Florida (Emily Laughlin v. Miami-Dade County, Florida) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Emily Laughlin v. Miami-Dade County, Florida, (11th Cir. 2025).

Opinion

USCA11 Case: 24-13284 Document: 25-1 Date Filed: 12/15/2025 Page: 1 of 20

NOT FOR PUBLICATION

In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 24-13284 Non-Argument Calendar ____________________

EMILY LAUGHLIN, Plaintiff-Appellant, versus

MIAMI-DADE COUNTY, FLORIDA, Defendant-Appellee. ____________________ Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 1:23-cv-23350-KMM ____________________

Before JILL PRYOR, LAGOA, and WILSON, Circuit Judges. PER CURIAM: Appellant Emily Laughlin was a probationary employee of the Animal Services Department (the “ASD”) of Appellee Miami- Dade County, Florida (the “County”). During her probationary USCA11 Case: 24-13284 Document: 25-1 Date Filed: 12/15/2025 Page: 2 of 20

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period, the County determined that she had failed the terms of her probation and then terminated her employment. Laughlin sued the County after her termination, raising disability discrimination claims under the Americans with Disabilities Act of 1990 (the “ADA”), the Rehabilitation Act of 1973 (the “RA”), and the Florida Civil Rights Act (the “FCRA”). She alleged that she was disabled because of her medical conditions and the County terminated her because of her disability. In response, the County argued that it had a legitimate, nondiscriminatory reason for ending Laughlin’s em- ployment, pointing to her poor performance while on probation. The district court granted summary judgment to the County. After careful consideration, and for the reasons explained below, we affirm the grant of summary judgment. I. BACKGROUND In the section that follows, we discuss the case’s factual back- ground—including Laughlin’s probationary employment at the ASD, her medical conditions, and the County’s determination that she had failed her probation and its decision to terminate her em- ployment. We then lay out her lawsuit’s procedural history. USCA11 Case: 24-13284 Document: 25-1 Date Filed: 12/15/2025 Page: 3 of 20

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A. Factual Background In February 2022, Laughlin was hired as an outreach special- ist for the Miami-Dade County ASD. 1 Her job duties included booking and hosting pet adoption events at the ASD’s animal shel- ter and in the community. Upon hiring, Laughlin had to success- fully complete a 12-month probationary period before attaining civil service status. Probationary employees are informally evalu- ated by their supervisors rather than through formal performance reviews. Employees who fail probation lose their positions at the ASD. Several months into her probationary period, Laughlin be- gan to experience health problems. She had migraines, dizzy spells, ringing in her ears, lightheadedness, difficulty swallowing, and ep- isodes of vomiting. The vomiting occurred as frequently as 20 to 30 times per day and made it hard for her to eat. Laughlin’s doctor diagnosed her with a brain tumor and masses on her thyroid, as well as an autoimmune disease. After receiving these diagnoses, Laughlin began to seek medical treatment for her medical condi- tions with specialists, including a neurosurgeon, a neurologist, and a gastroenterologist. Laughlin discussed her health problems with Gilda Nunez, her supervisor at the time, and a human resources manager. She was asked to provide documentation about her conditions. She

1 Because the district court granted summary judgment against Laughlin, we

consider the record in the light most favorable to her. See Copeland v. Dep’t of Corr., 97 F.4th 766, 770 n.1 (11th Cir. 2024). USCA11 Case: 24-13284 Document: 25-1 Date Filed: 12/15/2025 Page: 4 of 20

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submitted a nurse’s note that said she had “multiple complex med- ical issues” and “require[d] time off to work to complete required testing and follow up.” Doc. 20-8 at 1. 2 The ASD gave her an ac- commodation to work from home on some days and to work flex- ible hours, provided that she worked eight hours each day. Although Laughlin had been given permission to work from home, Bronwyn Stanford, the ASD director, was unhappy with this accommodation. Stanford “wasn’t a fan of people working from home.” Doc. 20-1 at 50–51. She questioned Laughlin about her ac- commodation, asking, “But how long do you think you’re going to be working from home? Is that gonna stop soon? Can we stop that soon?” Doc. 20-2 at 5–6. Laughlin also had problems with other coworkers once she became sick and started working from home. She reported that they became less responsive to her emails, less responsive to her calls, and less willing to help her with organizing events. One col- league even said that she would respond to Laughlin’s calls or emails only if Laughlin was working at the office. In October 2022, Laughlin helped organize MEGA, the shel- ter’s largest event of the year. While planning the event, Laughlin received no assistance from her coworkers, who gave her “the cold shoulder.” Doc. 20-2 at 52. The adoption counselors would not help her decorate. Needing assistance, she asked her mother and mother-in-law to come to the shelter and help out. Shortly before

2 “Doc.” numbers refer to the district court’s docket entries. USCA11 Case: 24-13284 Document: 25-1 Date Filed: 12/15/2025 Page: 5 of 20

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the event, Stanford emailed all ASD staff giving a “SHOUT OUT” to Laughlin for bringing “her mother and aunt here” and doing “an amazing job with decorations.” Doc. 28-4 at 2. In November 2022, Laughlin was assigned a new supervisor, Victoria Valledor, the ASD shelter program manager. Although she allowed Laughlin to work from home, Valledor organized in- person meetings on days when Laughlin was not in the office. Valledor also created an events committee but did not place Laugh- lin on it, perhaps “in preparation of getting rid of [her].” Doc. 20-1 at 123–24. At one point, Laughlin overheard Valledor telling an- other colleague “something along th[e] lines” of “you know she’s faking it, right? Being sick. There’s no way she has a brain tumor.” Doc. 20-1 at 130–31. Laughlin’s relationship with her coworkers continued to de- teriorate. At “almost every event,” members of the ASD staff com- plained about Laughlin’s performance. Doc. 20-5 at 68. According to Valledor, Laughlin would frequently forget to do things at events and then burden other staff to “make up for what she was not doing.” Id. For one event, Valledor said she had to “scramble last minute” because Laughlin failed to ensure that a mobile animal clinic vehicle was available. Id. at 53. Additional issues regarding Laughlin’s performance arose af- ter a December 2022 event. Although Laughlin was not attending the event, she had signed out a portable credit card machine for the use of a counselor who was working the event. When Laughlin was in the office at the end of the next week, she made sure that USCA11 Case: 24-13284 Document: 25-1 Date Filed: 12/15/2025 Page: 6 of 20

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the credit card machine had been returned. But the adoption coun- selor did not return receipts related to the event to ASD’s finance division. Instead, the counselor put the receipts in Laughlin’s office. Laughlin did not know that the receipts were there, and they were not timely turned in to the finance division. Twelve days after the event, members of the finance division found the receipts on Laughlin’s desk. They complained to Valledor, saying that because the receipts had not been turned in, the finance division was “ex- tremely tardy in completing the reconciliation process and submit- ting documentation.” Doc. 20-16 at 2. Laughlin didn’t deny that the receipts were overdue.

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Emily Laughlin v. Miami-Dade County, Florida, Counsel Stack Legal Research, https://law.counselstack.com/opinion/emily-laughlin-v-miami-dade-county-florida-ca11-2025.