Velvet Ann Saulsberry v. Billy Woods, in his official capacity as Sheriff of Marion County

Summary

The United States District Court for the Middle District of Florida granted Sheriff Billy Woods’s amended motion for final summary judgment in Velvet Ann Saulsberry’s action. The court rejected Saulsberry’s retaliation claims under Title VII and the Florida Civil Rights Act, finding no causal connection between her prior litigation and the Sheriff’s conduct, and rejected her inverse-condemnation claim concerning disputed access to her property. The court denied as moot Saulsberry’s motion to bifurcate trial and directed the Clerk to close the case.

Holdings

1. Summary judgment was warranted because Saulsberry failed to present evidence connecting her prior discrimination litigation or other protected activity to the alleged adverse actions by the Sheriff.
2. The Sheriff's refusal or failure to resolve the disputed access rights, including not issuing or rescinding trespass warnings and cautioning Saulsberry against blocking access, did not constitute a taking of her property.

Questions Presented

1. Whether Saulsberry presented sufficient evidence of a causal connection between her protected activity and an adverse action to survive summary judgment on her Title VII and Florida Civil Rights Act retaliation claim.
2. Whether the Sheriff's failure to issue or maintain trespass warnings and his warning concerning blockage of the disputed roadway constituted a compensable temporary taking of Saulsberry's property.

Disposition

other