Case Explained: Non-Argument Calendar RHONDA JACKSON v. SUMTER COUNTY GEORGIA

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-27 Docket: 1:22-cv-00207-LAG The eleventh-circuit affirmed the district court’s grant of summary judgment to Sumter County, Georgia, dismissing Rhonda Jackson’s discrimination and retaliation claims brought under the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The court applied a de novo standard of review, viewing evidence in the light most favorable to the nonmoving party to determine if a reasonable jury could find intentional discrimination or retaliation. Regarding the discrimination claim, the court held that Jackson failed to present a convincing mosaic of circumstantial evidence proving her termination was motivated by her disability. The court rejected her argument regarding suspicious timing because her own testimony established she informed management of her disability six months prior to termination, which is too long an interval to support such an inference. Furthermore, the court found no similarly situated employees who were treated more favorably, as Jackson was the only employee spraying Lysol on coworkers rather than just using it for general safety. Finally, the court determined that the employer’s justification—that Jackson violated harassment policies by targeting specific individuals with chemical sprays—was not pretextual, noting that the policy prohibited harassment regardless of whether it was based on a protected trait and that Jackson was free to use Lysol without spraying others. Regarding the retaliation claim, the court held that Jackson failed to establish the first element of the test: engaging in statutorily protected expression. The court reasoned that her internal grievance did not oppose an unlawful practice or make a charge under the ADA; rather, it merely disputed the investigation’s findings and sought to excuse her conduct based on her health. Because the grievance did not constitute protected activity, there was no causal link between such activity and her termination. Additionally, the court noted that Jackson could not expand the scope of her protected activity claim beyond the “filing a grievance” allegation made in her complaint during briefing. The practical consequence is that the judgment in favor of the employer stands, and Jackson’s estate receives no relief on these claims. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.