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Courts are limited to granting relief that will personally benefit plaintiff

The Eleventh Circuit held that courts are limited, in Title VII cases (the federal statute that governs most discrimination and retaliation cases, including related to race, color, religion and sex), to granting relief that personally benefits the plaintiff. In this case, the plaintiff a former employee proved a violation but no damages. Instead, the trial court awarded her an injunction requiring the defendant to clean her personnel file and further to implement a training program. The Eleventh Circuit held the training-program requirement went too far because training would not benefit the plaintiff, a former employee.

In a separate unpublished opinion, the Eleventh Circuit remanded the case for the trial court to determine if the plaintiff was still the “prevailing” party eligible to recover attorney fees, especially since she had apparently rejected a higher settlement offer.

Source: Furcron v. Mail Centers Plus, LLCcase no. 187-12598 (11th Cir. 6/12/19) and