January 12, 2026|Franchise Frontlines
January 12, 2026 | United States District Court for the Middle District of Florida | Published Opinion
Executive Summary
In a published post-trial decision, Judge Charlene Honeywell of the United States District Court for the Middle District of Florida denied defendants’ motions for judgment as a matter of law and for a new trial following a jury verdict in favor of the Equal Employment Opportunity Commission (“EEOC”) in an Americans with Disabilities Act (“ADA”) failure-to-accommodate case. The EEOC alleged that The Princess Martha, LLC, a senior living facility, and its affiliated management entities failed to accommodate a job applicant who disclosed that she took prescription medication for post-traumatic stress disorder that could trigger a positive drug test. The jury found all three defendants liable and awarded damages. Defendants argued that the applicant abandoned the accommodation process, that punitive damages were unsupported, and that the management company could not be treated as a joint employer. The court rejected those arguments, concluding that sufficient evidence supported the jury’s findings, including evidence that the management company exercised control over employment policies and ADA compliance responsibilities across facilities.
Relevant Background
The Princess Martha is a senior living facility located in St. Petersburg, Florida. The facility operates within a broader corporate structure that includes TJM Properties, Inc., a real estate acquisition and management company overseeing multiple senior living facilities, and TJM Property Management, Inc., the management entity responsible for operational oversight of those facilities.
Sarah Branyan applied for employment at the Princess Martha in August 2021. During her interview, she disclosed that she was a military veteran with post-traumatic stress disorder and that she took prescription medication. Because the facility required applicants to pass a drug test as a condition of employment, Branyan attempted to provide a list of her prescriptions to explain that the medication could affect the test results.
After completing the drug screening process, Branyan left a voicemail with the facility’s human resources manager explaining that her medication could cause a positive drug test and asking for assistance verifying the prescription with the testing laboratory. According to Branyan, the facility never returned her call and ultimately did not hire her.
The EEOC filed suit on Branyan’s behalf, alleging that the defendants violated the ADA by failing to engage in the interactive process necessary to evaluate a reasonable accommodation. Following a five-day trial, the jury found all defendants liable and awarded $5,083 in back pay, $50,000 in emotional distress damages, and $350,000 in punitive damages.
The defendants filed post-trial motions seeking judgment as a matter of law, a new trial, and remittitur of damages.
Decision
The court first addressed the defendants’ renewed motion for judgment as a matter of law. The defendants argued that the EEOC failed to establish that Branyan’s prescription medication would have caused a failed drug test and that she abandoned the interactive accommodation process by failing to return a voicemail allegedly left by the facility.
The court rejected these arguments, explaining that the trial record contained sufficient evidence for a reasonable jury to find that Branyan’s medication would have produced a non-negative screening result and that the employer failed to meaningfully engage in the interactive process. Evidence showed that the applicant proactively disclosed her condition and attempted to provide documentation of her prescription medication but that the employer did not follow up or assist in verifying the information.
The court also rejected the defendants’ argument that Branyan caused a breakdown in the accommodation process by failing to return a voicemail. Although phone records showed that the facility attempted to call her, the human resources manager testified that she could not remember making the call and would likely have directed Branyan back to the laboratory rather than assisting with the accommodation request. The jury was therefore entitled to conclude that the employer failed to engage in the interactive process required by the ADA.
The court next addressed whether TJM Property Management, Inc., could be held liable as a joint employer. The defendants argued that only the facility itself was responsible for the hiring decision and that the management company should not be liable.
Applying the Eleventh Circuit’s joint-employer framework, the court explained that liability may extend to multiple entities where they share or co-determine the essential terms and conditions of employment. The evidence presented at trial showed that the management company exercised control over employment policies and compliance obligations at the facility. In particular, the human resources manager responsible for handling accommodation requests reported to the management company and was tasked with ensuring ADA compliance across multiple properties. The management company also controlled the employee handbook and the policies governing the accommodation process.
Based on this evidence, the court concluded that a reasonable jury could find that the management entity controlled the aspects of the employment relationship that gave rise to the ADA violation. The joint employer finding was therefore supported by the trial record.
The court also upheld the jury’s punitive damages award. Evidence showed that the employer had failed to provide training regarding ADA compliance and that management personnel made inaccurate statements to the EEOC during the investigation. The court determined that a reasonable jury could interpret this evidence as demonstrating reckless indifference to employees’ statutory rights.
Although the court denied the defendants’ request for judgment as a matter of law and a new trial, it granted a limited reduction of damages because federal law caps combined compensatory and punitive damages in ADA cases at $50,000 for employers of this size.
Finally, the court granted partial injunctive relief requiring the defendants to implement ADA training and adopt improved accommodation policies for hiring personnel.
Looking Forward
Although the dispute arose in the ADA accommodation context, the decision illustrates how courts analyze employment liability when multiple related business entities operate a single facility or enterprise. Courts evaluating joint employer liability often focus on which entity controls employment policies, human resources oversight, and compliance responsibilities rather than simply identifying which entity issued the employee’s paycheck.
The court’s reasoning highlights that entities responsible for developing employment policies or overseeing compliance functions may face liability even when another affiliated entity technically makes the hiring decision. In this case, the management company’s authority over human resources procedures and ADA compliance responsibilities supported the jury’s finding that it shared responsibility for the failure to accommodate the job applicant.
For franchisors and other organizations that operate through management companies or layered corporate structures, the case illustrates how centralized employment policies can become a focal point in litigation. Plaintiffs frequently argue that the entity responsible for setting workplace policies or supervising human resources functions exercises sufficient control to be treated as an employer under federal employment statutes.
The decision also underscores the importance of clear training and compliance procedures when multiple entities share operational responsibilities. Courts may view gaps in compliance training or ambiguous responsibility for accommodation requests as evidence that affiliated companies collectively control the employment framework in which alleged discrimination occurs. Maintaining well-defined roles in employment decision-making and compliance oversight remains an important safeguard in systems where multiple entities operate within a single organizational structure.
This article is based solely on the opinion of the Court in this matter. The author has not conducted any independent investigation into the facts. For the avoidance of doubt, each statement related to the law and facts in this article is drawn from the Court’s opinion in this case.
Thomas O’Connell is a Shareholder at Buchalter LLP and Chair of the firm’s Franchise Practice Group. For questions about this article or media inquiries, you can contact Tom at toconnell@buchalter.com.
This communication is not intended to create, and does not create, an attorney-client relationship or any other legal relationship. No statement herein constitutes legal advice, nor should it be relied upon or interpreted as such. This communication is for general informational purposes only and is not a substitute for legal counsel. Readers should not act or refrain from acting based on any information provided without seeking appropriate legal advice specific to their situation. For more information, visit www.buchalter.com.
