Justia Civil Rights Opinion Summaries

Petitioner claimed a trailer was his, but, upon evidence the trailer was stolen, the justice court awarded the trailer to the State. Later, Petitioner filed for bankruptcy and scheduled the trailer as an asset of his estate. Petitioner also sued for damages for the lost use of his property as a constitutionally compensable taking. The trial court dismissed the case for want of jurisdiction, concluding that the justice court judgment was not void but was only voidable, and the judgment was voidable only if the bankruptcy court made certain determinations. The court of appeals reversed, holding (1) a judgment rendered in violation of the automatic stay is void, not merely voidable, and a state court has jurisdiction to make that determination, even though the bankruptcy court might later disagree; and (2) as to Petitioner's takings claim, subsisting fact issues precluded dismissal. The Supreme Court reversed, holding (1) a judgment that violates the automatic stay is void and subject to collateral attack in state court; but (2) the judicial award of property to the State was not, in these circumstances, a taking. Remanded.

The Chapter 7 trustee for the bankruptcy estate of Stacey Williams appealed the district court's grant of summary judgment to Gate Gourmet on Williams' claim of pregnancy discrimination, race discrimination, retaliation, and state law negligence. The court held that the district court improperly granted summary judgment on Williams' Title VII, 42 U.S.C. 2000e et seq., claim for pregnancy discrimination because Williams had presented enough circumstantial evidence to allow a jury to reasonably infer that her supervisor's action in terminating her because of her pregnancy and his inaction in not attempting to find her a light-duty job were a violation of Title VII. The district court properly granted summary judgment to Gate Gourmet on Williams' Title VII and 42 U.S.C. 1981 race discrimination claims because she had not shown a genuine issue of material fact about whether Gate Gourmet intentionally discriminated against her based on her race. Summary judgment was improperly granted against Williams' Title VII and section 1981 retaliation claims because there was a reasonable inference that the statutorily protected filing of and refusal to settle the EEOC charge caused Gate Gourmet to deny Williams a light-duty position, which was a materially adverse action. The court affirmed in part, reversed in part, vacated in part, and remanded.

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.