The Fifth Circuit Court of Appeals ruled on October 27, 2026, that a public official cannot claim qualified immunity in a retaliation case under the Fair Labor Standards Act (FLSA). This decision affects public employees and their ability to seek justice when they face retaliation for asserting their rights regarding pay. The case, Eva Kristine Stramaski v. Mark Lawley, Docket No. 25-20348, highlights the importance of protecting employees from retaliation in the workplace.
The dispute began when Eva Stramaski, an academic advisor at Texas A&M University, claimed her supervisor, Mark Lawley, retaliated against her after she complained about her paycheck potentially arriving late. Although her pay was ultimately received on time, Lawley labeled her as “aggressive” regarding the issue, sent her home, and later fired her after issuing a “coaching letter” that cited performance problems. Stramaski filed a lawsuit against Lawley, alleging that he violated the FLSA by retaliating against her for asserting her right to timely pay.
This case is Lawley’s second appeal. In the first appeal, the Fifth Circuit ruled that sovereign immunity did not protect Lawley from being sued personally. However, the court left open the question of whether he could claim qualified immunity. On remand, the district court determined that qualified immunity did not apply, leading Lawley to appeal again.
The central question before the court was whether a public official could invoke qualified immunity in a retaliation suit under the FLSA. The court ruled that qualified immunity does not apply to such cases. The opinion stated, “The common law did not immunize malicious retaliation when Congress authorized private FLSA retaliation suits, and the policies underlying qualified immunity do not justify extending the defense to such claims.” Judges Willett, Engelhardt, and Douglas presided over the case.
The court’s ruling clarifies that public officials cannot hide behind qualified immunity when they retaliate against employees for asserting their rights under the FLSA. This decision reinforces the protections afforded to employees who complain about wage-related issues and ensures that they can seek justice without fear of retaliation.
The impact of this ruling is significant for public employees across the country. It sets a precedent that strengthens the FLSA's anti-retaliation provisions, ensuring that employees can assert their rights without the threat of losing their jobs. This ruling may encourage more employees to speak out against unfair treatment in the workplace, knowing that they have legal recourse against retaliatory actions.
Looking ahead, it remains to be seen whether Lawley will seek further appeals in this case. However, the court’s ruling is a strong affirmation of the rights of employees under the FLSA. The decision also raises questions about how public officials will navigate personnel decisions in light of this ruling, as they may now face greater scrutiny regarding their treatment of employees who assert their rights.
Details were not available in the court filing regarding any potential related cases or further appeals. However, the outcome of this case may influence future litigation involving FLSA retaliation claims and the application of qualified immunity in similar contexts.
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