Reversal Secured in Employment-Termination Appeal

Tampa Associate Brandon Tyler successfully argued an employment-termination appeal before the Second District Court of Appeal.

The case centered around the former Head Start Director of a non-profit organization, who oversaw a federally-funded program designed to provide education services to disadvantaged children through a grant from the U.S. Department of Health and Human Services. Upon termination from his position, the former employee filed suit, asserting a third-party-beneficiary claim alleging that the non-profit had violated both federal law and the grantee contract, seeking relief as a beneficiary under those agreements.

The defense moved for summary judgment, highlighting that federal law does not provide for a private right of action in this context and that established United States Supreme Court precedent rejects third-party-beneficiary claims under federal contracts under these circumstances. In response, the Plaintiff introduced a new argument: that the termination violated an Addendum to the organization's personnel policies. Despite the Addendum expressly allowing the termination and the fact that it was never referenced in the original complaint, the trial court ultimately granted summary judgment in favor of the Plaintiff.

However, on appeal, the Second District Court reversed this decision, handing victory to our client for four key reasons:

• Improper Relief on Unpleaded Claim: The trial court erred in granting relief based on a claim (breach of the Addendum) that was never actually pleaded.
• Addendum Authorized Termination: The Addendum in question clearly permitted the termination, contradicting the Plaintiff’s assertions.
• Plaintiff Abandoned Original Claims: The Plaintiff abandoned his only pleaded cause of action, which was based on federal law and the original grantee contract.
• Admission Undermined New Argument: The Plaintiff conceded that his new claim depended on breach of the Addendum, a claim both unpleaded and without merit.

This result underscores the importance of clear pleadings and adherence to both internal policies and established legal precedent.