Florida Supreme Court Clarifies Filing Requirements Under Florida Civil Rights Act
On July 10, 2025, the Florida Supreme Court issued its decision in Steak N Shake, Inc. v. Ramos, resolving conflicting appellate court rulings about the administrative prerequisites for bringing a discrimination claim under the Florida Civil Rights Act (“FCRA”).
The FCRA requires individuals to file a complaint with the Florida Commission on Human Relations (“FCHR”) before pursuing a lawsuit in court. This complaint must include a short and plain statement of the facts and the relief sought. Historically, some Florida courts held that an individual must specifically reference the FCRA in their administrative complaint to later pursue an FCRA claim in court.
In Steak N Shake v. Ramos, the Florida Supreme Court rejected this interpretation. The Court held that a claimant satisfies the FCRA’s administrative exhaustion requirement even if the initial charge of discrimination, filed with the Equal Employment Opportunity Commission (“EEOC”) and dual-filed with the FCHR, only references federal law (such as the Americans with Disabilities Act) and not the FCRA itself. The Court emphasized that the statutory requirement focuses on the factual allegations and the relief sought—not on citing specific statutes.
What This Means for Employers
This decision lowers the procedural barrier for employees pursuing discrimination claims under Florida law. Employers may face FCRA claims even when the administrative charge did not explicitly reference the FCRA. As a result, employers should review all EEOC charges carefully—even those framed solely under federal law—and consider potential exposure under Florida law as well.
Radey Law Firm continues to monitor developments in employment law and is available to assist with any questions or concerns regarding compliance with the FCRA or related matters. If you have any questions, please contact Radey Law Firm at 850-425-6654.