Copeland V. Georgia Dep’t of Corrections
U.S. District Court for the Southern District of Georgia
On remand from the Eleventh Circuit Court of Appeals
Case no. 22-13073 (11th Cir.)
Case no. 6:20-cv-00057-JRH-BKE (S. Dist. GA)
STATUS: ONGOING
BACKGROUND
Plaintiff Tyler Copeland is a transgender man who served as a sergeant for three years at Rogers State Prison in Georgia. Since the time Copeland came out as transgender at work, he endured constant and humiliating harassment from prison coworkers and supervisors. Guards called Copeland “baby girl” and “ma’am” on prison-wide radio communications and in front of inmates. Dangerously, given his position and need to command respect from inmates, Copeland’s colleagues disobeyed and undermined him, despite his repeated complaints to his supervisors, prison management, and human resources personnel.
In June of 2020, Mr. Copeland brought a lawsuit in the Southern District of Georgia. He alleged that he was subject to a hostile work environment and discriminatory non-selection based on his transgender status, and retaliation for his protected activity, in violation of Title VII of the Civil Rights Act of 1964.
The district court GRANTED summary judgment for the state-defendants on all three counts. In part, the district court concluded that Copeland’s Title VII hostile work environment claim failed because the harassment he suffered was not sufficiently severe or pervasive.
Mr. Copeland appealed to the Eleventh Circuit. On March 28, 2024, the appellate court VACATED the district court’s decision granting summary judgment for Count 1 (hostile work environment), and remanded the issue for further proceeds before the district court. The decision AFFIRMED the district court’s findings pursuant to Counts 2 and 3 (non-selection and retaliation), meaning that Mr. Copeland cannot revive those claims.
The Eleventh Circuit decision is significant in that it recognized that intentional and repeated misgendering may satisfy the “severe or pervasive” requirement for actionable unlawful harassment.
The case currently pending before the District Court for the Southern District of Georgia.
Follow along for updates.
FILINGS & Orders
ORIGINAL COMPLAINT - JUN 9, 2020
DISTRICT COURT DECISION GRANTING SUMMARY JUDGMENT FOR STATE-DEFENDANTS - AUG 22, 2022
11TH CIR. CT. DECISION - MAR 28, 2024
FILINGS BY NON-PARTIES
BRIEF FOR THE UNITED STATES AS AMICUS CURIAE SUPPORTING PLAINTIFF-APPELLANT - DEC 8, 2022
See embedded links in BACKGROUND section for more documents.