Cuddeback v. Florida Board of Education

381 F.3d 1230 (2004)

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Cuddeback v. Florida Board of Education

United States Court of Appeals for the Eleventh Circuit
381 F.3d 1230 (2004)

Facts

Sandy Cuddeback (plaintiff) was a female graduate student at the University of South Florida (defendant). Cuddeback conducted cancer research in the laboratory of a university professor, Dr. Hong Gang Wang. Cuddeback was provided a stipend, employment benefits, sick and annual leave, and the necessary training and equipment for her work in the laboratory. A comprehensive collective-bargaining agreement governed Cuddeback’s employment relationship with the university. However, much of Cuddeback’s work in the laboratory was done to finish her dissertation and complete the requirements of her graduate program. Cuddeback received excellent performance evaluations in 1998 and 1999. However, in early 2000, Dr. Wang commented on Cuddeback’s evaluation regarding her lack of productivity, focus, and communication. In the spring of 2000, Cuddeback requested a medical leave of absence due to a hand injury. Some dispute existed as to whether Cuddeback notified Dr. Wang of her injury or Cuddeback’s request for medical leave. Dr. Wang notified Cuddeback that her appointment would not be renewed due to Cuddeback’s absence from the laboratory and her failure to make improvements after her evaluation. Dr. Wang then paid a male graduate student to complete Cuddeback’s research. Cuddeback filed a lawsuit against the university, its board of trustees (defendant), and the Florida Board of Education (defendant), alleging gender discrimination in violation of Title VII of the Civil Rights Act of 1964. The university filed a motion for summary judgment, arguing that Cuddeback was a student rather than an employee and that Title VII did not apply to students. The district court granted summary judgment in favor of the university on other grounds. However, the district court ruled that Cuddeback was an employee for purposes of Title VII based on the economic-realities test, which required the district court to view the situation in accordance with the common-law principles of agency and employment. Cuddeback appealed.

Rule of Law

Issue

Holding and Reasoning (Dubina, J.)

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