Case Explained: Non-Argument Calendar KATHLEEN SAFFORD v. SEDGWICK CLAIMS MANAGEMENT SERVICES, INC a foreign corporation

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-24 Docket: 5:23-cv-00515-JSM-PRL The eleventh-circuit affirmed the district court’s grant of summary judgment in favor of the defendant employer, holding that the plaintiff failed to timely exhaust her administrative remedies before filing suit. The court applied the standard requiring plaintiffs in Florida to file a charge with the EEOC within 300 days for federal claims (Title VII, ADEA, ADA) or 365 days for state claims (FCRA) prior to litigation. The court determined that the plaintiff’s single EEOC charge, filed on February 1, 2023, was time-barred regarding claims based on a supervisor’s hiring in January 2022 and failed to encompass her allegations of retaliatory termination or hostile work environment, which were not raised in the administrative filing. The court rejected the plaintiff’s argument that these claims fell under the “continuing violation” doctrine, citing Supreme Court precedent establishing that discrete acts such as refusals to hire or terminations are separate actionable practices that cannot be aggregated to extend the limitations period. Additionally, the court found no basis for equitable tolling of the deadlines. Consequently, the plaintiff’s discrimination, retaliation, and hostile work environment claims were dismissed as a matter of law, leaving the judgment in favor of the employer intact. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.