Justia Civil Rights Opinion Summaries

Plaintiff asserted federal claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and under 42 U.S.C. 1981, as well as a state-law claim for intentional infliction of emotional distress, asserting that his employer subjected him to racial discrimination. At the time plaintiff filed both his EEOC charge and his complaint initiating the instant case, plaintiff was a debtor in a Chapter 13 proceeding, having filed a petition for bankruptcy. The employer subsequently moved for summary judgment, arguing that plaintiff should be judicially estopped from pursuing his claims against the employer because he failed to disclose those claims to the bankruptcy court. The district court granted the motion, dismissing plaintiff's case, and plaintiff appealed. The court held that the district court did not abuse its discretion in applying judicial estoppel to plaintiff's claims after finding that plaintiff failed to create a fact issue regarding his purported inadvertence. Accordingly, the court affirmed the judgment.

Plaintiff-Appellant Mauerhan and the Chapter 7 Bankruptcy Trustee brought suit against Mauerhan's former employer Defendant-Appellee Wagner Corporation alleging a violation of the Americans with Disabilities Act (ADA). The lower court granted Defendant's motion for summary judgment, and Plaintiffs appealed. Mauerhan had tested positive for drug use and was fired from Defendant's employ, but was told he may return if he was able to complete a rehabilitation program. Mauerhan completed the program, but Defendant's job duties and compensation would be less than what it previously had been. Mauerhan declined Defendant's offer. Later that year, Mauerhan filed for Chapter 7 bankruptcy, and received a discharge of his debts by the end of the year. After filing for bankruptcy, but before the case was closed, Mauerhan learned that he had a viable claim of discrimination against Defendant under the ADA, and filed it with the EEOC. The Bankruptcy Trustee learned of the claim, and moved to amend Mauerhan's bankruptcy petition to include the claim in the bankruptcy estate. The lower court found that Mauerhan had only abstained from drugs for one month, too short to receive protection from the ADA at the time Mauerhan asked to be rehired. On appeal, this Court upheld the lower court's grant of summary judgment.