Justia Civil Rights Opinion Summaries

Hutterville Colony, a nonprofit religious corporation, had two opposing factions. Both factions sought exclusive power over Hutterville. Their schism led to two lawsuits, including one faction's suit seeking judicial dissolution of Hutterville. Eventually, the Supreme Court ordered dismissal of the suit, concluding that the circuit court lacked subject matter jurisdiction to order judicial dissolution of Hutterville. This appeal concerned the circuit court's actions following the Court's decision. The Supreme Court affirmed, holding (1) the circuit court did not err when it continued to exercise jurisdiction over Hutterville and its property following remittitur; (2) the circuit court had the authority and duty to wind up the receivership and discharge the receiver; (3) the circuit court did not abuse its discretion in ordering payment of the receiver's fees and expenses from receivership funds and allowing the receiver to use receivership funds to pay the expenses of third parties; (4) the circuit court did err in releasing the receiver from liability, as the receiver's appointment and receivership were valid under state law; and (5) the circuit court did not err in ordering the receiver to return receivership funds to the corporation. View "Wipf v. Hutterville Hutterian Brethren" on Justia Law

The parties in this case were a group of chess players and their opponent, the Puerto Rico Chess Federation. The chess players filed suit against the chess federation in Puerto Rico court, alleging violations of their rights under the United States and Puerto Rico constitutions and Puerto Rico law. The chess federation successfully removed the case to federal court. The chess players subsequently filed a second case, again in Puerto Rico court, excluding any claims under federal law. The federation also removed this case. The district court consolidated the two cases and declared jurisdiction over the second case under the All Writs Act. Ultimately, the district court granted summary judgment in favor of the federation on all claims. The First Circuit Court of Appeals affirmed in part and reversed in part, holding (1) the district court had federal subject matter jurisdiction over the first case but did not have subject matter jurisdiction over the second case; and (2) the district court incorrectly granted summary judgment to the federal on some of the chess players' Commonwealth law claims. View "Ortiz-Bonilla v. Federacion de Ajedrez de P.R., Inc." on Justia Law

Lockheed Martin Corp. sought to set aside a decision of the Administrative Review Board of the Department of Labor (the "ARB" or the "Board") that concluded Lockheed violated Section 806 of the Sarbanes-Oxley Act. The Board affirmed the decision of an administrative law judge ("ALJ"), who concluded Lockheed violated the Act by constructively discharging employee Andrea Brown after she had engaged in protected activity. Brown worked as Communications Director for Lockheed from June 2000 to February 2008. In 2003, she became the Director of Communications in Colorado Springs, Colorado. In May 2006, Brown began having difficulty getting responses from one of her supervisors on work-related matters. She discussed the problem with Tina Colditz, a coworker and personal friend. Colditz ran a pen pals program for the company, through which Lockheed employees could correspond with members of the U.S. military deployed in Iraq. Colditz told Brown that the supervisor had developed sexual relationships with several of the soldiers in the program, had purchased a laptop computer for one soldier, sent inappropriate emails and sex toys to soldiers stationed in Iraq, and traveled to welcome-home ceremonies for soldiers on the pretext of business while actually taking soldiers to expensive hotels in limousines for intimate relations. Colditz told Brown she was concerned the supervisor was using company funds for these activities. Brown thus became concerned Owen’s actions were fraudulent and illegal and that there could be media exposure which could lead to government audits and affect the company’s future contracts and stock price. Brown brought her concerns to Jan Moncallo, Lockheed’s Vice President of Human Resources. Moncallo told Brown she would submit an anonymous ethics complaint on Brown’s behalf, and that she would be protected from retaliation because no one would know her identity. Moncallo sent an Prior to 2006, Brown received a "high contributor" or "exceptional contributor" rating in her performance evaluations. In late 2006, and thereafter, however, Brown received a lower rating of "successful contributor." In 2007, Lockheed announced to all employees it was undergoing a corporate-structure reorganization. Brown began reporting to a new supervisor, who according to Brown, had a negative attitude toward her from the beginning of their professional relationship. Shortly thereafter, Brown received a phone call from the former supervisor telling her that Brown’s job had been posted on the internet and that she should get her resume together. Brown would suffer from an emotional breakdown, fall into a deep depression, and take medical leave over the changes. Brown brought a complaint alleging violations of Sarbanes-Oxley. In his Recommended Decision and Order, the ALJ found that Brown had engaged in protected activity; she suffered materially adverse employment actions, including constructive discharge; and her engagement in protected activity was a contributing factor in the constructive discharge. The ALJ awarded reinstatement, back pay, medical expenses, and non-economic compensatory damages in the amount of $75,000. Lockheed timely appealed the ALJ’s decision to the Administrative Review Board of the Department of Labor, which affirmed. Finding no error in the Board's decision, the Tenth Circuit affirmed. View "Lockheed Martin v. DOL" on Justia Law

Painter's Mill Grille, the owner and operator of a restaurant, and its principals filed a complaint against the restaurant's landlord and its agents. Plaintiff alleged that defendants, motivated by racial animus, interfered with plaintiff's business and its opportunity to sell the restaurant, including its leasehold interest, in violation of 42 U.S.C. 1981, 1982, and 1985(3), as well as state tort principles. The court agreed with the district court's conclusion that plaintiff's principals did not have standing to be plaintiffs and that Painter's Mill Grille did not set forth sufficient facts to state a claim to relief that was plausible on its face. Accordingly, the court affirmed the district court's dismissal of the complaint under Rule 12(b)(6). View "Painter's Mill Grille, LLC v. Brown" on Justia Law

In a two-year period, more than eleven million cigarettes manufactured by an Indonesian cigarette manufacturer were sold in Tennessee. After the manufacturer withdrew its cigarettes from the United States market, the State suit the manufacturer, alleging that the manufacturer had failed to pay into the Tobacco Manufacturers' Escrow Fund as required by Tenn. Code Ann. 47-31-101 to -103. The trial court dismissed the suit for lack of personal jurisdiction over the manufacturer. The court of appeals reversed. At issue on appeal was whether Tennessee courts may exercise personal jurisdiction over the Indonesian manufacturer where the manufacturer's cigarettes were sold in the State through the marketing efforts of a Florida entrepreneur who purchased the cigarettes from an independent foreign distributor. The Supreme Court reversed, holding that Tennessee courts lacked personal jurisdiction over the manufacturer because the State failed to establish that the manufacturer purposely availed itself of the privilege of doing business in Tennessee. View "State v. NV Sumatra Tobacco Trading Co." on Justia Law

Plaintiff Allstate Sweeping, LLC (Allstate) is owned and operated by two white women: Martha Krueger and Barbara Hollis. In January 2006 it began performing pressure-washing services at Denver International Airport (DIA) under a contract with the City and County of Denver (Denver). Although the contract term was through July 2008, it was terminated by Denver July, 2007. Defendant Calvin Black, a contract-compliance technician at DIA, was assigned to monitor Allstate’s contract. Black is an African-American male. Allstate claimed that it was subjected to gender- and race-based discrimination and to retaliation for its complaints of discrimination. It filed suit in the federal district court in Colorado against Denver and four DIA employees, including Black, claiming violations of 42 U.S.C. 1981, 42 U.S.C. 2000d (Title VI), and the Equal Protection Clause of the Fourteenth Amendment. The district court granted summary judgment to all defendants except Black, holding that there were genuine issues of fact regarding whether Black was motivated by racial and gender bias and whether Black created a hostile work environment in such a way as to make plaintiff’s contract "unprofitable and its owners miserable." It did not address Allstate’s retaliation claim. Black appealed the denial of his motion for summary judgment, contending that he was entitled to qualified immunity and that the Tenth Circuit had jurisdiction to review the denial under the collateral-order doctrine. Upon review, the Tenth Circuit held that it lacked jurisdiction to review the district court’s determinations because such sufficiency determinations are not reviewable under the collateral order doctrine. The Court did, however, have jurisdiction to review the legal sufficiency of the claim that Black made Allstate’s owners "miserable" and to review the sufficiency of the evidence of the retaliation claim (which the district court did not consider). The Court reversed the denial of summary judgment on those claims. View "Allstate Sweeping, LLC v. Black" on Justia Law

Upon an investigation by the Maine Bureau of Insurance (Bureau) and the Maine Attorney General's Office (AG's Office) into the questionable business practices of Bankers Life and Casualty Company (Company), Appellant, the Company's employee, accepted responsibility for his own unlawful conduct. In exchange, several state officials (Appellees) representing the Bureau and the AG's Office agreed to take no further action against Appellant. Appellees, however, subsequently agreed to Appellant's termination in a separate agreement with the Company. Appellant filed a complaint against Appellees, asserting violations of 42 U.S.C. 1983 and 42 U.S.C. 1985(2). The district court dismissed the complaint, concluding (1) Appellees were entitled to absolute immunity on the section 1983 claim, and (2) Appellant failed to plead a plausible section 1985(2) claim. The First Circuit Court of Appeals affirmed, holding (1) Appellees met their burden in establishing they were entitled to absolute immunity for entering into the consent agreements with Appellant and the Company, and the district court did not err by refusing to invoke the doctrine of judicial estoppel on Appellees' immunity defense; and (2) because the complaint failed to allege any racial or class-based invidiously discriminatory animus underlying Appellees' actions, the district court properly dismissed Appellant's section 1985(2) claim. View "Knowlton v. Shaw" on Justia Law

Plaintiff Willie Barlow, Jr., appealed the district court’s grant of summary judgment in favor of his former employer, C.R. England, Inc., on his claims for race discrimination, wrongful discharge in violation of Colorado public policy, and failure to pay overtime in violation of the Fair Labor Standards Act (FLSA). England employed Plaintiff as a security guard and also paid him to perform janitorial work through a company Plaintiff formed. Plaintiff began receiving workers’ compensation benefits after he sustained an injury at work in June 2007. In November, England terminated its janitorial services contract with Plaintiff's company. A few months later, England fired Plaintiff from his security guard position after he failed to notice and report a theft of several trailer doors from England’s premises. The district court concluded that: (1) there was no evidence England fired Plaintiff for race-based reasons, or in retaliation for his workers’ compensation claim; (2) Plaintiff performed his janitorial work as an independent contractor, not an employee, and thus could not assert a claim for wrongful discharge from that position; and (3) Plaintiff's status as an independent contractor precluded an FLSA claim for overtime. Upon review, the Tenth Circuit affirmed with regard to Plaintiff's claims for discrimination and violation of the FLSA. The Court reversed, however, Plaintiff's state-law claim for wrongful discharge. View "Barlow, Jr. v. C.R. England Inc." on Justia Law

In 2002 and 2003, appellee American Home Services, Inc. (AHS), a siding, window, and gutter installation company, contracted with Sunbelt Communications, Inc. (Sunbelt), for Sunbelt to send a total of 318,000 unsolicited advertisements to various facsimile machines operating in metropolitan Atlanta. In October 2003, appellant A Fast Sign Company, Inc. d/b/a Fastsigns (Fastsigns), one of the recipients of these unsolicited advertisements, brought a class-action lawsuit against AHS, asserting violations of the Telephone Consumer Protection Act of 1991 (TCPA) (47 U.S.C. sec. 227). At the conclusion of a bench trial, the trial court found that AHS violated the TCPA because it admitted in judicio that it had sent 306,000 unsolicited facsimile advertisements. Finding that violation of the TCPA was wilful and knowing, the trial court awarded the class $459 million in damages, or the amount of $1,500 for each fax sent. The trial court declined to award punitive damages and attorney's fees. AHS appealed the ruling to the Court of Appeals. The Court of Appeals vacated the trial court's judgment and remanded the case, finding that the trial court erroneously applied the TCPA by basing liability and damages on the number of unsolicited advertisements sent rather than the number of unsolicited advertisements received by class members. The issue before the Supreme court was whether the Court of Appeals erred when it determined that only the receipt of an unsolicited fax created an actionable violation of the TCPA. Upon review, the Supreme Court reversed the appellate court's judgment and remanded the case for further proceedings. View "A Fast Sign Company, Inc. v. American Home Services, Inc." on Justia Law

Two physicians who contracted with HMOs refused to accept capitation payments in place of fee-for-service payments, so the HMOs dropped the physicians' contracts. The physicians brought constitutional and antitrust claims against the companies, which the district court rejected on a motion to dismiss. The physicians appealed. The First Circuit Court of Appeals affirmed, holding (1) because the appellees were not governmental actors, Appellants' constitutional claims failed; and (2) because the appellees that Appellants contended violated the Sherman Act were not independent firms and were, rather, wholly owned subsidiaries of the same parent company, the appellees could not have violated the Act's conspiracy prohibition. View "Gonzalez-Maldonado v. MMM Health Care, Inc." on Justia Law