Williams v. Worldwide Flight Services, Inc.

Larry Williams (plaintiff) was an African American former employee of Worldwide Flight Services, Inc. (Worldwide) (defendant). Williams claimed that his supervisor, Arthur Ambruster, discriminated against him because of his race. Ambruster referred to Williams using a particularly offensive racial epithet and called him a monkey to his face, in the presence of other employees, and over company radios and walkie-talkies. Ambruster often communicated to Williams that he wished his Black self was not there. Ambruster assigned Williams tasks, such as loading and unloading planes in dangerous weather, and assigned him additional tasks so that Williams would not have break times. Ambruster often accused Williams of theft and threatened to fire him. Ambruster even told another supervisor to falsify documentation, making it appear that Williams had a history of disciplinary problems to justify his termination. Williams sued Worldwide, bringing a claim for intentional infliction of emotional distress and for negligent retention of Ambruster. A trial court dismissed Williams’s complaint with prejudice because he did not state a cause of action. Williams appealed. Williams did not pursue other state remedies under Florida’s civil rights act or federal remedies for victims of racial discrimination, such as Title VII of the Civil Rights Act of 1964 and the Equal Employment Opportunity Commission.