Rishi Arora v. Miami-Dade County, Florida

Court of Appeals for the Eleventh Circuit·Decided August 25, 2026·No. 24-13267·Unpublished

Opinion

NOT FOR PUBLICATION

In the

United States Court of Appeals For the Eleventh Circuit

No. 24-13267

Non-Argument Calendar

RISHI ARORA, 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-20962-MD

Before JILL PRYOR, KIDD, and TJOFLAT, Circuit Judges. PER CURIAM:

Rishi Arora appeals the District Court’s order granting Miami -Dade County’s (the “County”) motion for summary judgment . Arora, an Asian American of Indian origin, alleged that the

2 Opinion of the Court 24-13267

County discriminated and retaliated against him in the workplace in violation of Title VII and the Florida Civil Rights Act (“FCRA”). Proceeding pro se at both the District Court and now on appeal, Arora appeals the District Court’s orders granting summary judgment for the County and denying his motion requesting the District Court Judge to recuse, and he appeals this Court’s order denying his motion to correct the record on appeal. We affirm the District Court’s grant of summary judgment on the retaliation claims. But we vacate the grant of summary judgment on the discrimination claims and remand for further proceedings.

I.

Arora has been employed by Miami-Dade County as an Enterprise Portfolio Manager in the County’s Information Technology Department (“IT Department”) since 2015. Within the IT Department , he is responsible for providing leadership in best practices and managing the operational needs of the Enterprise Program Manager Office (“EMPO”). His starting salary was $140,000 annually, and by the time he filed his initial complaint, his base salary had risen to $173,458.88—the maximum for his current classification .

On December 14, 2021, Arora’s supervisor, Maria Johnson, gave Arora an overall “satisfactory” rating on his performance evaluation for the period of November 2, 2020 through October 31, 2021.

On February 15, 2022, Johnson directed Arora to lead the Quality Assurance Office Design and Implementation Plan

24-13267 Opinion of the Court 3

(“Quality Assurance Initiative”), which sought to introduce the quality assurance function into the IT Department. Arora was chosen because of his background and experience, and because he had personally recommended adding the functionality to the IT Department . He, however, disputes that he was best suited for the assignment, asserting that he lacked a background in quality assurance and experience in the director level role, both of which he believed were required to lead such a large undertaking. Johnson advised Arora that the Quality Assurance Initiative would be his sole focus for its duration, and that she would assume his duties, including supervision of his direct reports, in the interim.

Despite being informed that the Quality Assurance Initiative would be his sole focus, Arora continued to hold staff meetings with his direct reports. As a result, Arora received a Record of Counseling for failure to follow directions on March 30, 2022.

Then, on April 25, 2022, Arora filed a charge of discrimination (the “Initial Charge”) based on national origin, race, and religion with the Equal Employment Opportunity Commission (“EEOC”). Arora indicated that the earliest discriminatory event took place on February 15, 2022 and that the discrimination was ongoing. In the Initial Charge, Arora claimed that Johnson, an African American woman, discriminated against him in the following ways: (1) requiring him to meet with her weekly; (2) assigning him to the Quality Assurance Initiative; (3) giving him his worst rating (“Satisfactory”) since he joined the Miami-Dade IT Department; (4)

4 Opinion of the Court 24-13267

verbally threatening him; and (5) giving him the Record of Counseling .

Six months later, Johnson assigned Arora as the IT Department Program Manager for the Call Center Modernization program (the “Call Center Initiative”). Johnson claims that she assigned Arora to the initiative because of his certifications and experience , but Arora disputes this, claiming that his credentials were insufficient to give directions to his superiors in the IT Department.

On October 26, 2022, Arora filed a supplement to his Initial Charge (the “Supplemental Charge”) with the EEOC. In the Supplemental Charge, Arora claimed that Johnson: (1) assigned him to lead the Call Center Initiative despite his belief that only Assistant Directors could succeed in such an initiative; (2) failed to restore him to his previous position after he completed his work on the Quality Assurance Initiative; (3) failed to restore him to a role where his subordinates directly reported to him after he completed his work on the Quality Assurance Initiative; (4) barred him from speaking with his direct reports; (5) told his direct reports to create EMPO artifacts and kept him out of discussions related to progress at the EMPO; and (6) excluded him from hiring positions that would directly report to him.

Then, on March 10, 2023, Arora filed his complaint in the District Court asserting eight causes of action: discrimination on the basis of national origin, in violation of Title VII and the FCRA (“Counts I and II”); discrimination on the basis of race, in violation of Title VII and the FCRA (“Counts III and IV”); discrimination on

24-13267 Opinion of the Court 5

the basis of religion, in violation of Title VII and the FCRA (“Counts V and VI”); and retaliation, in violation of Title VII and the FCRA (“Counts VII and VIII”).

On February 2, 2024, the County filed a motion seeking summary judgment for Arora’s claims of discrimination and retaliation . A month later, Arora’s counsel filed a motion seeking to withdraw from representing him, which the Court approved on April 24, 2024. The District Court gave Arora fourteen days to either retain a new counsel, or proceed pro se. Arora elected to proceed pro se.

The District Court heard argument from both parties on the County’s motion for summary judgment. Two days later, Arora filed a motion requesting Judge Melissa Damian recuse herself, which the Court denied. The Court then granted the County’s motion for summary judgment, finding that Arora failed to allege facts sufficient to create a genuine issue of material fact as to whether he suffered an adverse employment action.

Arora raises three issues on appeal. First, Arora challenges the District Court’s grant of summary judgment in favor of the County, arguing that he was entitled to a jury trial under the Seventh Amendment and that there was a genuine dispute of material fact. Second, Arora argues the District Court erred by denying his motion requesting Judge Damian recuse herself because her impartiality might reasonably be questioned. And, finally, Arora argues that this Court erred in denying his motion to correct the record on appeal. Additionally, the County requests that we strike the

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facts section from Arora’s initial brief for failing to follow Florida appellate procedural rules. First, we consider the County’s request to strike the facts section from Arora’s initial brief, then we consider Arora’s appeals.

II.

The County argues in its appellee brief that Arora’s statement of facts must be stricken for failure to comply with Florida Rule of Appellate Procedure 9.210. Since this case is before us under federal question jurisdiction, the Federal Rules of Appellate Procedure govern—not Florida’s procedural rules.

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