Summary
The United States District Court for the Middle District of Florida grants Sheriff Rick Wells’s motion for summary judgment in Tara M. Burge’s action alleging sex discrimination, race discrimination, and retaliation. The court addresses Burge’s resignation from the Manatee County Sheriff’s Office, the investigation into her association with a convicted felon and alleged misuse of law-enforcement databases, the Florida Department of Law Enforcement referral, and the comparators identified by Burge.
Court
United States District Court for the Middle District of Florida, Tampa Division
Jurisdiction
United States District Court for the Middle District of Florida, Tampa Division
Decision date
December 10, 2025
Docket number
8:24-cv-2955-VMC-CPT
Disposition
other
Questions Presented
- Whether Wells could be held liable under 42 U.S.C. § 1983 for alleged race discrimination and retaliation when his employment decision was subject to meaningful review by a Career Service Appeal Board.
- Whether Burge's resignation constituted a constructive discharge and therefore an adverse employment action under Title VII.
- Whether Burge identified a similarly situated male comparator sufficient to establish a prima facie Title VII sex-discrimination claim.
- Whether the Sheriff's stated reasons for the employment action—association with a felon and misuse of law-enforcement databases—were pretextual.
Holdings
- Wells was not the final policymaker with respect to Burge's alleged termination because the decision was subject to meaningful review by the Career Service Appeal Board, whose decision was binding on the Sheriff, and further review by a Florida circuit court.
- Burge's resignation was voluntary and did not constitute a constructive discharge or adverse employment action under Title VII.
- Burge did not identify a male comparator who was similarly situated in all material respects.
- Burge failed to show that Wells's stated reasons—her prolonged association with a convicted felon and misuse of law-enforcement databases—were false or a pretext for discrimination or retaliation.
Court Document
Open PDFLoading document…