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Steak N Shake, Inc. v. Ramos

The Case

Steak N Shake, Inc. v. Ramos,
415 So. 3d 107
Supreme Court of Florida,
July 10, 2025

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

The fact that Wilfred Ramos may have experienced discrimination while employed at a Steak N Shake restaurant was not the question before the court. Instead, the court had to decide if Mr. Ramos took the proper steps before filing his lawsuit. In cases like this, Florida law says a worker must first file a complaint with the proper state agency before going to court.

Mr. Ramos filed a discrimination charge with the Equal Employment Opportunity Commission (EEOC), a Federal Government agency. He said Steak N Shake cut his hours and fired him after he experienced a back injury in a car accident. Because the EEOC works with Florida’s civil-rights agency, the EEOC sent Ramos’ charge complaint to the Florida Commission on Human Relations (FCHR).

In his charge, Mr. Ramos only mentioned federal law, not Florida law. Before the Florida Supreme Court, Steak N Shake argued that Mr. Ramos had to specifically mention Florida law to later use it to sue them. The Florida Supreme Court disagreed. The court said that Florida law says all that is needed is a short and plain statement of the facts and what they want the court to do. A worker does not have to specifically write the words “Florida Civil Rights Act,” or otherwise mention Florida law by name in the charge.

Facts of the Case

Wilfred Ramos, Jr., worked for Steak N Shake as a grill operator. While employed, he was hurt in a car accident outside of work. After his injury, Steak N Shake allegedly cut his hours and later fired him. Ramos claimed that Steak N Shake did this because of his disability from the accident and because he asked for reasonable accommodations.

Mr. Ramos filed a discrimination charge with the EEOC. In the charge, he checked the boxes for “Retaliation” and “Disability.” He also wrote that he believed he had been discriminated against because of his disability, or perceived disability. He also wrote that he was retaliated against for asking for reasonable accommodations. He used the Americans with Disabilities Act (ADA) to support his claims. He also said that he wanted the charge filed with both the EEOC and the state or local agency. Ramos did not specifically mention the Florida Civil Rights Act in his charge.

The EEOC then sent Mr. Ramos’ charge to the FCHR. The EEOC then investigated the charge filed by Mr. Ramos. After investigating, the EEOC sent Ramos a notice telling him he had the right to sue Steak N Shake.

Mr. Ramos sued Steak N Shake for discrimination and retaliation. Steak N Shake reacted by arguing that Ramos had not properly completed the agency steps required by the Florida Civil Rights Act. Steak N Shake said that Ramos had to mention the Florida Civil Rights Act in his charge to later sue under that law. The trial court agreed and threw out Mr. Ramos’ case.

Mr. Ramos appealed to Florida’s Second District Court of Appeal. That court ruled in favor of Mr. Ramos. The court said he did not have to specifically say in his charge that he was making claims under the Florida Civil Rights Act. The court said that because the EEOC and the FCHR work together, a person can file with both agencies through the same process and need not separately name Florida law.

But the Second District’s decision disagreed with a similar decision from Florida’s Fourth District Court of Appeal in a different case. Because the district courts disagreed, the Florida Supreme Court took this case to settle the question.

Issue of the Case

  1. Does a worker who sues for disability discrimination with the EEOC, and whose charge is also sent to the FCHR, have to specifically name the Florida Civil Rights Act in that charge to later sue under Florida law?

Arguments and Analysis

1. Does a worker who sues for disability discrimination with the EEOC, and whose charge is also sent to the FCHR, have to specifically name the Florida Civil Rights Act in that charge to later sue under Florida law?

At the Florida Supreme Court, Steak N Shake argued that Mr. Ramos did not correctly follow the required FCHR steps before filing suit. The company said that because Mr. Ramos mentioned only federal law in his charge, he could not sue under Florida law. Steak N Shake believed, if Mr. Ramos wanted to sue under the Florida Civil Rights Act, he had to mention that law in his complaint.

The Florida Supreme Court disagreed. The court looked at the Florida law. It said that only a short and plain statement of the facts was needed and a statement about the relief Mr. Ramos wanted. The court explained that “relief” means the help or remedy the worker wants. It did not mean the worker must write down the exact name of the law.

The court also looked at Florida’s administrative rules. Those rules focus on the basic facts of the complaint, such as:

  1. What happened?
  2. Who was involved?
  3. When did it happen?

The rules never said that a worker had to mention the Florida Civil Rights Act by name.

This is important because it showed that Florida’s system is supposed to focus on notice and facts, not on perfect legal wording. Ramos told the agencies what happened. He said the problem involved disability discrimination and retaliation. He asked for relief. And, his charge was sent to the Florida agency through the normal process. The Florida Supreme Court said that was enough.

Ruling

The Florida Supreme Court ruled for Mr. Ramos. It said that a worker does not have to specifically mention the Florida Civil Rights Act to complete the required agency steps when the charge is sent to both the federal agency and the Florida agency. The court agreed with the Second District’s decision holding and stated that the Fourth District’s decision was wrong.

Conclusion

This case makes Florida’s filing rule easier for workers who may have been discriminated against. The court said what is important is did the worker clearly describe the discrimination and properly use the agency process, not whether he used the perfect legal label.

Mr. Ramos could continue his Florida lawsuit. He still has to prove the discrimination in court. This case means his case cannot be thrown out because his original charge only mentioned federal disability law and did not also name Florida civil rights law.

Links to the Case

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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