Justia Civil Rights Opinion Summaries

Plaintiff-appellant La’Tonya Ford worked at Jackson National Life Insurance (“Jackson”) for about four years. During her time there, Ford allegedly suffered sex- and race-based discrimination; faced retaliation for complaining about her treatment; endured a hostile work environment; and was constructively discharged. After she left Jackson for another job, Ford sued the company for (1) discrimination; (2) retaliation; (3) hostile work environment; and (4) constructive discharge. Jackson moved for summary judgment; the district court granted Jackson’s motion and dismissed all of Ford’s claims. Ford now appeals, urging us to reverse the court on each claim. The Tenth Circuit affirmed the dismissal of her discrimination claim. But it reversed in part the dismissal of her retaliation claim; her hostile-work-environment claim; and her constructive-discharge claim. View "Ford v. Jackson National Life, et al." on Justia Law

Canyon County employed William Hartman as a heavy equipment operator at the Pickles Butte landfill in Nampa, Idaho, from 2012 until 2017. In February 2017, Hartman reported to Canyon County’s Human Resources Office that a female co-worker was being sexually harassed. The next month, Hartman, who was an army veteran, told both the director of the landfill, David Loper, and his immediate supervisor that he was taking narcotics prescribed to him for chronic pain. Canyon County requested Hartman provide, by a set deadline, medical documentation confirming his prescription and verifying that his use of narcotics would not adversely impact his ability to safely operate equipment. Hartman stated he was attempting to obtain the documentation, but he failed to provide it within the requested timeframe. On April 28, 2017, Loper sent Hartman a “Notice of Intent to Terminate,” informing him that his employment with Canyon County would be terminated effective May 2, 2017. The notice stated that pursuant to Rule 11.04 of the Canyon County Personnel Manual and “I.C. § 72-1701 et. seq. [sic],” Hartman could request a good faith hearing concerning the termination within two days of receiving the letter. Prior to Hartman’s receipt of the notice, Canyon County paid Hartman the balance of his accrued leave. Hartman did not request a good faith hearing. Hartman filed a notice of tort claim with Canyon County on July 27, 2017, alleging he had been unlawfully terminated. He filed a charge of discrimination with the Idaho Human Rights Commission on August 3, 2017. On November 28, 2018, Hartman filed a complaint against Canyon County, alleging: (1) disability-based discrimination in violation of the Idaho Human Rights Act (“IHRA”) and Americans with Disabilities Act (“ADA”); (2) unlawful retaliation in violation of Title VII of the Civil Rights Act (“Title VII”); and (3) unlawful termination in violation of the Uniformed Services Employment and Reemployment Rights Act (“USERRA”). Hartman later voluntarily dismissed his USERRA claim. After considering the parties’ supplemental briefing the district court issued a written decision, granting Canyon County’s motion for summary judgment. Finding that the district court erred in its grant of summary judgment, the Idaho Supreme Court reversed and remanded for further proceedings. View "Hartman v. Canyon County" on Justia Law

In March 2018, the officers were involved in the fatal shooting of a homeless man. The Oakland Police Department investigated the incident, concluding that the officers’ use of force was reasonable and complied with Police Department policy. The Chief of Police agreed. Separately, the Community Police Review Agency (CPRA), the investigative body of the City’s civilian oversight Police Commission, investigated the incident and determined that the use of force was objectively reasonable. The Compliance Director disagreed with the Chief of Police and the CPRA, instead recommending termination of the officers for unreasonable use of force. After their termination, the officers sought a writ of mandate and declaratory relief in state court.The Ninth Circuit vacated, for lack of subject matter jurisdiction, the district court’s judgment on the pleadings in favor of Defendants and remanded with instructions to remand this case to state court. The panel held that this was a case arising under state law that properly belonged in the state courts. Recognizing that under Section 1331, a case can “arise under” federal law in two ways, the panel determined that it lacked subject matter jurisdiction under both branches of federal question jurisdiction. First, the panel lacked subject matter jurisdiction under the federal cause of action branch because federal law did not create the causes of action asserted. The panel next held that it lacked subject matter jurisdiction under the substantial federal question branch. View "FRANCISCO NEGRETE V. CITY OF OAKLAND" on Justia Law

Plaintiff, a Florida LLC, sued a Canadian company, Teck Resources Limited, alleging that it had illegally trafficked in property to which Plaintiff says it has a claim. The district court granted Teck’s motion, holding that Florida’s long-arm statute didn’t provide jurisdiction over Teck and, additionally, that Teck lacked the necessary connection to the United States to establish personal jurisdiction under Federal Rule of Civil Procedure 4(k)(2).The Eleventh Circuit affirmed holding that courts should analyze personal jurisdiction under the Fifth Amendment using the same basic standards and tests that apply under the Fourteenth Amendment. The court wrote that applying the minimum-contacts test here is relatively straightforward. The court held that Teck doesn’t have contacts with the United States sufficient to establish either specific or general personal jurisdiction over it. Plaintiff’s suit doesn’t arise out of or relate to any of Teck’s ties with the United States. And because a relationship between the defendant’s conduct within the forum and the cause of action is necessary to exercise specific jurisdiction, the lack of any such relationship here dooms Plaintiff’s effort to establish specific personal jurisdiction over Teck. View "Herederos De Roberto Gomez Cabrera, LLC v. Teck Resources Limited" on Justia Law

On appeal, the St. Martin Parish School Board (the “School Board”) challenges the district court’s (1) exercise of remedial jurisdiction over the case, (2) denial of its motion for unitary status, and (3) imposition of additional equitable relief. The Fifth Circuit concluded that hat the district court properly retained remedial jurisdiction over the action; the court otherwised affirmed in part and reversed in part.The court explained that the district court did not clearly err in determining that the School Board failed to achieve unitary status in student assignment, faculty assignment, and the quality of education. The denial of unitary status was, therefore, not clearly erroneous. However, the court found that the district court abused its discretion in closing Catahoula Elementary School. The record demonstrates that progress has been made and progress can continue through the implementation of other reasonable, feasible, and workable remedies. Accordingly, the court reversed the closing of Catahoula Elementary School and remanded for consideration of other methods of addressing that concern. View "Borel v. Sch Bd Saint Martin Parish" on Justia Law

Plaintiff claimed her employment was terminated in retaliation for complaining she was going to be paid late. She filed a complaint against a department head within the Texas A&M Engineering Station in his individual capacity (“DH”), alleging he violated the anti-retaliation provision of the Fair Labor Standards Act (“FLSA”)  DH moved to dismiss Plaintiff’s retaliation claim because the suit was barred by sovereign immunity, and in the alternative, that he was entitled to qualified immunity. The district court determined that neither immunity applied.   The Fifth Circuit affirmed the rejection of sovereign immunity as a defense, affirmed the denial of the defense of sovereign immunity and vacated the judgment denying the defense of qualified immunity. The court held that holding public officials individually liable for retaliation under the FLSA also is consistent with the court’s prior holdings regarding individual liability in other FLSA contexts. However, the court wrote it discovered no Fifth Circuit opinion that holds qualified immunity is a defense under the FLSA. The court concluded that Plaintiff’s claim would be barred by qualified immunity because she does not allege that DH violated a clearly established law. However, the antecedent question is whether qualified immunity applies to the FLSA to begin with. The court, therefore, remanded for the district court to decide this question in the first instance. View "Stramaski v. Lawley" on Justia Law

The Bureau of Alcohol, Tobacco, Firearms, and Explosives (“ATF” or the “Bureau”) promulgated a rule classifying “bump stocks” as machine guns. The Bureau’s new rule instructed individuals with bump stocks to either destroy them, abandon them at the nearest ATF facility, or face criminal penalties. Plaintiffs initially moved for a preliminary injunction to stop the rule from taking effect, which the District Court denied, and a panel of this Court affirmed. At the merits stage, the District Court again rejected Plaintiffs’ challenges to the rule under the Chevron framework. See Chevron, U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984).The central question on appeal was whether the Bureau had the statutory authority to interpret “machine gun” to include bump stocks and the DC Circuit affirmed. In employing the traditional tools of statutory interpretation, the court found that the disputed rule is consistent with the best interpretation of “machine gun” under the governing statutes. The court explained that it joins other circuits in concluding that these devices, which enable such prodigious rapid-fire capability upon a pull of the trigger, fall within the definition of “machine gun” in the National Firearms Act and Gun Control Act. View "Damien Guedes v. ATF" on Justia Law

Plaintiffs are nine female detention service officers working at the Dallas County Jail who are employed by Defendant-Appellee Dallas County Sheriff’s Department. Dallas County (“the County”). A gender-based scheduling policy went into effect and only male officers were given full weekends off whereas female officers were allowed two weekdays off or one weekday and one weekend day off. Plaintiffs alleged that they were told that it would be safer for the male officers to be off during the weekends as opposed to during the week.   Plaintiffs filed suit against the County for violations of Title VII and the Texas Employment Discrimination Act (the “TEDA”). On appeal, Plaintiffs argued that the district court erred by considering whether the County’s scheduling policy constituted an adverse employment action rather than applying the statutory text of Title VII and the TEDA. The Fifth Circuit affirmed the district court’s motion to dismiss The court held that Plaintiffs’ did not plead an adverse employment action, as required under the Fifth Circuit’s Title VII precedent. The court explained that the conduct complained of here fits squarely within the ambit of Title VII’s proscribed conduct: discrimination with respect to the terms, conditions, or privileges of one’s employment because of one’s sex. Given the generally accepted meaning of those terms, the County would appear to have violated Title VII. However, the court explained it is bound by the circuit’s precedent, which requires a Title VII plaintiff to establish a prima facie case of discrimination by showing that she “suffered some adverse employment action by the employer.” View "Hamilton v. Dallas County" on Justia Law

Michael Cruz sued defendant insurance companies alleging they terminated his contract, under which he sold defendants’ insurance products, on the basis of race, in violation of 42 U.S.C. § 1981. In support, Cruz relied on a statement allegedly made by his district manager, which Cruz argued represented direct evidence of discrimination, as well as circumstantial evidence. The district court granted summary judgment to defendants, ruling that the district manager’s statement was inadmissible hearsay and that Cruz’s circumstantial evidence did not otherwise demonstrate discriminatory intent. Without considering Cruz’s circumstantial evidence, the Tenth Circuit reversed because the district manager’s alleged comment was not inadmissible hearsay; it was admissible under Federal Rule of Evidence 801(d)(2)(D) as a party-opponent admission made by an agent within the scope of the agency relationship. And because that admission constituted direct evidence of discrimination, the grant of summary judgment was reversed and the matter remanded for further proceedings. View "Cruz v. Farmers Insurance, et al." on Justia Law

Plaintiff sued the National Geospatial-Intelligence Agency and the Director of the Central Intelligence Agency alleging religious discrimination and retaliation under Title VII. The Fourth Circuit affirmed the district court’s dismissal. The court explained that because the alleged discrimination and retaliation arose from Plaintiff’s failure to satisfy additional security requirements and would require the court to review the merits of the security-authorization decision, the court is bound by the decision in Department of the Navy v. Egan, 484 U.S. 518 (1988), to affirm the district court’s dismissal of this matter for lack of jurisdiction.   The court explained that it agrees that courts must exercise caution in expanding the reach of Egan. Nevertheless, the court declined to adopt the hardline position, urged by Plaintiff, that Egan’s rationale may only ever apply to determinations explicitly labeled “security clearances.” Rather, as in Foote and Sanchez, this case requires a more detailed analysis of whether the judgment at issue is of the type that Egan intended to shield from judicial review. Furhter, the court held that the CIA’s decision to stop Plaintiff’s assignee-security authorization processing is the kind of discretionary predictive judgment shielded from judicial review by Egan. View "Nathan Mowery v. National Geospatial Intelligence Agency" on Justia Law