A three-judge panel of the U.S. Court of Appeals for the Eleventh Circuit unanimously affirmed a lower court’s decision to dismiss a pandemic-era discrimination suit by a group of workers at a commercial airline and affiliated company. A Florida federal court judge previously ruled that the workers’ claim that the companies’ COVID-19 policies discriminated against them based on religion was insufficient to survive dismissal, and that the court lacked jurisdiction over the case.
The Eleventh Circuit panel also lambasted the workers’ attorney for misusing artificial intelligence (AI). Evidently, documents that the workers’ lawyer filed with the court were full of citations to nonexistent cases. Even worse, after the court made him aware of the issue, he replaced those case citations with equally “hallucinated” cases. The panel characterized the attorney’s actions as “blatant and repeated misconduct.”
The case of Estate of Lane Caviness, et al. v. Atlas Air, Inc., et al., Case Number 24-11033, originated after Atlas Air and Flight Services International required their employees to get COVID-19 vaccinations absent a religious exemption. Employees who received an exemption were required to submit to periodic testing and wear a mask while working.
In response, a group of workers claimed in their most recent complaint, filed in October 2023, that Atlas and Flight Services created a hostile work environment due to these COVID-related policies. The workers also argued that getting the vaccine violated their religious beliefs, the testing requirement was burdensome, and masks were useless.
The district court dismissed the workers’ claims against Flight Services for lack of jurisdiction. The appellate panel agreed, noting that the company is a Texas company and that its employees’ temporary attendance at training sessions in Florida did not confer jurisdiction on the Florida court. Likewise, the court found no evidence that the vaccination policies affected workers attending the Florida trainings.
Furthermore, while the panel stated that the Atlas workers made plausible claims sufficient for the court to have jurisdiction over them, they could not prove any religious discrimination by the employer. In fact, the airline honored valid religious exemptions by allowing testing and masking instead of vaccinations.
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