Case Explained: JOANN WRIGHT HAYSBERT Plaintiff – v. OUTBACK STEAKHOUSE OF FLORIDA, LLC Defendant – Appellee and BLOOMIN’ BRANDS, INC

Court: United States Court of Appeals for the Fourth Circuit Filed: 2026-08-10 The fourth-circuit affirmed the district court’s judgment in a civil negligence action arising from a slip and fall incident at an Outback Steakhouse restaurant. The appellate court rejected Dr. Haysbert’s claim regarding the revocation of her attorney’s pro hac vice admission, holding she lacked standing to assert her counsel’s due process rights because she failed to demonstrate third-party standing requirements were met. Regarding the exclusion of expert witness Dr. Filler, the court held the district court did not abuse its discretion under Federal Rule of Civil Procedure 37(c)(1) and 26(e), applying the four-factor test from Anderson v. Foundation for Advancement of American Indians to find bad faith, prejudice, a need for deterrence, and that less drastic sanctions would be ineffective given the litigation history. Finally, the court affirmed the denial of Dr. Haysbert’s Batson challenge, concluding the district court did not clearly err in finding Outback provided race-neutral reasons for striking a Black potential juror—specifically his age, silence during voir dire, and shipyard employment—and that Dr. Haysbert failed to meet her burden of proving discriminatory intent under the three-step framework established in Batson v. Kentucky and Edmonson v. Leesville Concrete Co. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.