Jones v. Hogan Services, Inc.

CourtDistrict Court, M.D. Florida
DecidedSeptember 2, 2025
Docket2:25-cv-00211
StatusUnknown

This text of Jones v. Hogan Services, Inc. (Jones v. Hogan Services, 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
Jones v. Hogan Services, Inc., (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION

TAMMY JONES, an individual,

Plaintiff,

v. Case No: 2:25-cv-211-JES-NPM

HOGAN SERVICES, INC., a Missouri corporation,

Defendant.

OPINION AND ORDER This matter comes before the Court on plaintiff's Motion for Final Default Judgment (Doc. #11) filed on August 7, 2025. No response has been filed, and the time to respond has expired. Subject matter jurisdiction is premised on the presence of a federal question, the Americans with Disabilities Act (ADA). 28 U.S.C. § 1331. I. On March 13, 2025, plaintiff Tammy Jones (plaintiff) filed a Complaint (Doc. #1) under the ADA for disability discrimination and retaliation against her employer Hogan Services, Inc. (defendant or Hogan Services). Plaintiff resides in Lee County, Florida, and worked primarily in Lee County, Florida, for Hogan Services, a Missouri corporation having more than 15 employees. Plaintiff received her Notice of Right to Sue letter from the Equal Employment Opportunity Commission (EEOC) on December 23, 2024, and the Complaint was timely filed. In Count I, plaintiff alleges a violation of the ADA, and in Count II plaintiff alleges retaliation under the ADA. In the Complaint, plaintiff seeks back pay and

other benefits, front pay, reimbursement of expenses, attorney’s fees and costs, punitive damages, and compensatory damages. On June 6, 2025, service was executed on defendant Hogan Services. (Doc. #8.) After service of process, and finding no appearance by defendant, plaintiff filed a Motion for Clerk’s Default (Doc. #9) pursuant to Fed. R. Civ. P. 55(a). A Clerk’s Entry of Default (Doc. #10) was issued on July 15, 2025, pursuant to Fed. R. Civ. P. 55(a). “The mere entry of a default by the clerk does not in itself warrant the entry of default by the Court. Rather the Court must find that there is sufficient basis in the pleadings for the judgment to be entered.” GMAC Commercial Mortg. Corp. v. Maitland

Hotel Assocs., Ltd., 218 F. Supp. 2d 1355, 1359 (M.D. Fla. 2002) (citing Nishimatsu Construction v. Houston National Bank, 515 F. 2d 1200, 1206 (5th Cir. 1975)). A complaint must state a claim in order for default judgment to be granted. Id. The Court finds that an evidentiary hearing is not required in this case and will render a decision based on the documents submitted. When a default judgment occurs, a defendant admits the plaintiff’s well-pled allegations of fact. If liability is well pled, it is established by virtue of a default judgment. Buchanan v. Bowman, 820 F.2d 359, 361 (11th Cir. 1987). II. 1. Count I – Disability Discrimination

Under the ADA, “[n]o covered entity1 shall discriminate against a qualified individual on the basis of disability in regard to job application procedures, the hiring, advancement, or discharge of employees, employee compensation, job training, and other terms, conditions, and privileges of employment.” 42 U.S.C. § 12112(a). “To establish a prima facie case for disability discrimination, a plaintiff must produce sufficient evidence to permit a jury to find that she: (1) is disabled, (2) is a qualified individual, and (3) was discriminated against because of her disability.” Lewis v. City of Union City, Georgia, 934 F.3d 1169, 1179 (11th Cir. 2019) (citations omitted). Plaintiff began her employment in September 2022, as an

operations Manager, and was qualified for the position. Plaintiff performed her assigned duties and received successful performance reviews until she continued to request accommodations due to her status as a qualified person with a disability, cancer. (Doc. #1 at ¶¶ 7-9.)

1 A “covered entity” includes an employer “engaged in an industry affecting commerce who has 15 or more employees for each working day in each of 20 or more calendar weeks in the current or preceding calendar year….” 42 U.S.C. § 12111(2), (5)(A). Defendant started treating plaintiff negatively, calling her “chemo brain”, demoting her, and threatening her with termination because of her disability status. Plaintiff’s impairments impact

her ability to perform major life activities, such as thinking and working. Plaintiff has a history of these impairments that limit major bodily functions and several major life activities. (Id. at 10-12.) In Count I, plaintiff states that she is an individual with a disability with impairments that substantially limit one or more major life activity and bodily function, she has a record of the impairment and is regarded as having the impairment. Plaintiff is a qualified individual who, with a reasonable accommodation, could perform the essential functions of her job as an employee of Hogan Services. Defendant discriminated against plaintiff who suffered negative employment action as a direct and proximate cause

of the violations of the ADA. (Id. at 18-30.) The term “disability” includes a “physical or mental impairment”, a record of the impairment and being regarded as having an impairment, 42 U.S.C. § 12102(1), but “[t]he definition does not set forth a list of specific diseases and conditions that constitute physical or mental impairments because of the difficulty of ensuring the comprehensiveness of any such list. The term includes, however, such diseases and conditions as … cancer…,” 45 C.F.R. § Pt. 84, App. A. “The term ‘qualified individual’ means an individual who, with or without reasonable accommodation, can perform the essential functions of the employment position that such individual holds or desires.” 42 U.S.C. § 12111(8).

Clearly, calling plaintiff “chemo brain” and terminating her supports a finding that she was discriminated against because of her disability. Default judgment will be granted as to Count I. 2. Count II - Retaliation Under the ADA, no person shall discriminate “against any individual because such individual has opposed any act or practice made unlawful by this chapter or because such individual made a charge, testified, assisted, or participated in any manner in an investigation, proceeding, or hearing under this chapter.” 42 U.S.C. § 12203(a). “To prevail on her ADA retaliation claim, Plaintiff must show that: (1) she engaged in a statutorily protected expression, (2) she suffered an adverse employment

action, and (3) there was a causal link between the two.” Frazier- White v. Gee, 818 F.3d 1249, 1258 (11th Cir. 2016) (citing Lucas v. W.W. Grainger, Inc., 257 F.3d 1249, 1260 (11th Cir. 2001)). The first element can be established by showing a request for a reasonable accommodation. Id. Plaintiff alleges that on or about May 14, 2024, she made a formal complaint and participated in a meeting to complain of disability-based harassment and discrimination.

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273 F. Supp. 2d 1312 (M.D. Florida, 2003)
GMAC Commercial Mortgage Corp. v. Maitland Hotel Associates
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Jacqueline Lewis v. City of Union City, Georgia
934 F.3d 1169 (Eleventh Circuit, 2019)

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Jones v. Hogan Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-hogan-services-inc-flmd-2025.