Elisabeth Serian v. JetBlue Airways Corporation

── Elisabeth Serian v. JetBlue Airways Corporation ── Case No.: 25-12433 Court: Court of Appeals for the Eleventh Circuit Date: March 17, 2026 Category: NEW USCA11 Case: 25-12433 Document: 23-1 Date Filed: 03/17/2026 Page: 1 of 5 NOT FOR PUBLICATION In the United States Court of Appeals For the Eleventh Circuit ____________________ No. 25-12433 Non-Argument Calendar ____________________ ELISABETH SERIAN, Plaintiff-Appellant, versus JETBLUE AIRWAYS CORPORATION, Defendant-Appellee. ____________________ Appeal from the United States District Court for the Middle District of Florida D.C. Docket No. 6:23-cv-02471-JSS-LHP ____________________ Before WILLIAM PRYOR, Chief Judge, and ROSENBAUM and GRANT, Circuit Judges. PER CURIAM: USCA11 Case: 25-12433 Document: 23-1 Date Filed: 03/17/2026 Page: 2 of 5 2 Opinion of the Court 25-12433 Elisabeth Serian appeals the summary judgment in favor of JetBlue Airways Corporation and against her complaint of disabil- ity discrimination under the Americans with Disabilities Act. See 42 U.S.C. § 12112(a). Because Serian’s complaint is untimely, we af- firm. I. BACKGROUND Serian was a flight attendant for JetBlue. In April 2020, Jet- Blue adopted a mandatory mask policy for its crewmembers in re- sponse to the COVID-19 pandemic. Serian requested an accommo- dation supported by a physician’s note stating that she could not wear a mask for health reasons. JetBlue denied the request in Au- gust 2020 and offered Serian leave or a position reassignment in- stead. In April 2022, Serian emailed JetBlue’s chief executive officer and stated that she was “done complying to tyranny” and would “no longer be wearing [her] mask on board.” She posted her email on a Facebook page for JetBlue’s crewmembers and encouraged others to join her. JetBlue suspended Serian pending an investiga- tion. During an investigatory meeting on April 18, 2022, Serian pre- sented research on the “adverse effects of prolonged mask usage” and a detailed account of her specific health concerns. JetBlue ter- minated Serian on April 26, 2022, for violating company polices. On October 4, 2022, Serian filed a charge of disability dis- crimination under the Act with the Equal Employment Oppor- tunity Commission in Florida. Serian alleged that JetBlue violated USCA11 Case: 25-12433 Document: 23-1 Date Filed: 03/17/2026 Page: 3 of 5 25-12433 Opinion of the Court 3 the Americans with Disabilities Act by failing to provide her a rea- sonable accommodation. See 42 U.S.C. § 12112(a), (b)(5). The Commission issued a right-to-sue letter that advised Serian that it did not certify her compliance with any statutes. Serian sued JetBlue in the district court. JetBlue moved for summary judgment on the ground that Serian’s complaint was un- timely because the denial of her requested accommodation oc- curred in 2020, but Serian did not file her charge until 2022. The district court granted summary judgment for JetBlue because the complaint was untimely. II. STANDARD OF REVIEW We review a summary judgment de novo and view the evi- dence in the light most favorable to the nonmovant. Albert v. Ass’n of Certified Anti-Money Laundering Specialists,