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Easy to Read Summary: Steak N Shake, Inc. v. Ramos

The Case

PlaintiffVersusDefendantVolumeReporterPageCourtYear
Steak N Shake, Inc.v.Ramos415So. 3d107Fla.2025

A case citation talks about the case and where to find the court decision. To learn more, read: How to Find the Court Case and What Each Part Means in the Case Citation.

Keywords

administrative exhaustion, disability discrimination, dual filing, employment discrimination, Equal Employment Opportunity Commission (EEOC), Florida Civil Rights Act (FCRA), Florida Commission on Human Relations (FCHR), retaliation, statutory interpretation.

Summary

Wilfred Ramos worked at Steak N Shake as a grill cook. He was hurt in a car accident outside of work. After the accident, his boss cut his hours and then fired him. Ramos believed he was fired because of his disability from the accident and because he asked for reasonable accommodations (reasonable help to do his job).

Steak N Shake asked the court to dismiss the case because Mr. Ramos should have first filed his complaint with a state agency, the Florida Commission on Human Relations. Instead, he filed with the Equal Employment Opportunity Commission (EEOC), a federal agency that handles job discrimination cases. The EEOC shared his complaint with Florida’s civil rights agency, the Florida Commission on Human Relations (FCHR).

Here is the big question the court had to answer: Did Ramos have to write “Florida law” in his complaint, or was it enough to just describe what happened?

Steak N Shake said he had to name Florida law. The Florida Supreme Court said no — describing the facts was enough.

What Happened?

  1. Ramos was hurt in a car accident.
  2. Steak N Shake cut his hours and then fired him.
  3. Ramos believed he was fired because of his disability and because he asked for help at work.
  4. He filed a complaint with the Equal Employment Opportunity Commission (EEOC). He checked boxes for “Disability” and “Retaliation.” He also asked for his complaint to be shared with the state agency.
  5. The EEOC shared his complaint with the Florida Commission on Human Relations (FCHR) because that is their policy.
  6. The EEOC investigated and told Ramos he had the right to sue Steak N Shake.
  7. Ramos sued Steak N Shake in court.
  8. A lower court sided with Steak N Shake.
  9. Mr. Ramos asked the Florida Second District Court of Appeal to change the lower court decision.
  10. The Appeals court sided with Mr. Ramos.
  11. The Appeals court said he did not need to specifically mention the Florida Civil Rights Act (FCRA) in his complaint.
  12. Because the EEOC and FCHR work together, filing with one agency counts as filing with both.
  13. Mr. Ramos did not need to separately name Florida law in his filing.
  14. However, another court in Florida gave a different opinion in a similar case so the state Supreme Court reviewed the case.

The Argument

Steak N Shake said: Because Ramos only mentioned federal law in his complaint, rather than “Florida Civil Rights Act”, he should not be allowed to sue under Florida law.

Ramos said: He described what happened clearly. He checked the right boxes. He asked for his complaint to be shared with the FCHR. That should be enough.

What the Supreme Court Decided

The Florida Supreme Court sided with Ramos.

The court said Florida law only requires a worker to write a short, clear description of what happened and what help they want. A worker does not have to write the name of the Florida law in the complaint.

The court also pointed out that Florida’s rules for complaints focus on basic facts, what happened, who was involved, and when it happened. The rules never say a worker must name a specific law. Since Ramos clearly described the discrimination, asked for help, and his complaint was sent to the FCHR, he followed the rules correctly

Why This Matters

This case is good news for workers in Florida. It means that if you file a job discrimination complaint and clearly explain what happened, you will not lose your case just because you forgot to write the name of a specific law.

Ramos can now move forward with his lawsuit. He still must prove in court that Steak N Shake discriminated against him.

How to Find the Court Case

The full listing of a court case is called a citation. This citation talks about the case and where to find the court decision. Below are a table and a list of what each part means in this court case citation.

Court Case Citation   

PlaintiffVersusDefendantVolumeReporterPageCourtYear
Steak N Shake, Inc.v.Ramos415So. 3d107Fla.2025

The Parts of the Court Case Citation

  • Plaintiff: The last name of the person or name of the group who is bringing the case to court. In this case, the plaintiff is Steak N Shake, Inc.
    • In cases where there is more than one person, the first person listed, sometimes known as the “lead” plaintiff.
  • Versus: The short way to write “versus” is a lowercase letter v with a period (v.). This separates the “parties” of the case, the name of the plaintiff from the name of the defendant.
  • Defendant: The last name of the person or name of the group who the case is being brought against. In this case, the last name is Ramos.
    • In cases where there is more than one defendant, the name listed in the citation is the first defendant named in the lawsuit.
  • Volume: This is the bound volume where the case can be found. In this case, the volume is 415.
  • Reporter: This is the source where the case is found. In this case, the third series of the Southern Reporter (So. 3d).
  • Page: This is the first page of the volume where the case is found. In this case, 107 is the page.
  • Court: The court that heard the case. In this case, the Supreme Court of Florida (Fla.).
  • Year: The year or date the case was decided by the court. In this case, 2025.

Links to the Court Case

Disclaimer

These materials do not constitute legal advice and should not be relied upon in any individual case. Please consult an attorney licensed in your state for legal advice and/or representation. These materials were prepared by the legal research staff of the Burton Blatt Institute (BBI) at Syracuse University in partnership with the Southeast ADA Center to highlight legal and policy developments relevant to civil rights protections and the impact of court decisions in the Southeast Region under the Americans with Disabilities Act (ADA). These materials are based on federal disability rights laws and court decisions in effect at the time of publication. Federal and state disability rights law can change at any time.  In addition, state and local laws and regulations may provide different or additional protections. Materials are intended solely as informal guidance, and are neither a determination of your legal rights nor responsibilities under the ADA or other federal, state, and local laws, nor binding on any agency with enforcement responsibility under the ADA. The accuracy of any information contained herein is not warranted. Any links to external websites are provided as a courtesy and are not intended to nor do they constitute an endorsement of the linked materials.

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