Justia Civil Rights Opinion Summaries

Plaintiff was a life insurance agent with the New Life Insurance Company for more than forty years. In 2009, Plaintiff was informed that his agent contract would be terminated. In 2012 and 2014, Plaintiff filed two separate suits against New York Life, alleging, in addition to several common-law claims, age discrimination under both Massachusetts law and the federal Age Discrimination in Employment Act. The U.S. District Court of the District of Massachusetts consolidated the two cases. The district court then granted summary judgment for New York Life on all claims. The First Circuit affirmed, holding (1) Plaintiff’s state law age discrimination claims were time barred; (2) no reasonable jury could conclude that New York Life engaged in age discrimination under federal law in terminating his agent contract; and (3) no reasonable jury could conclude that the termination breached Plaintiff’s contract with New York Life or violated any of Plaintiff’s common law rights. View "Santangelo v. New York Life Ins. Co." on Justia Law

The Professional Massage Training Center (PMTC) filed suit against the Accreditation Alliance of Career Schools and Colleges (ACCSC) after ACCSC denied PMTC’s application for re-accreditation. The district court entered judgment in favor of PMTC, finding that ACCSC had violated the school’s due process rights. The court awarded the school more than $400,000 in damages and ordered ACCSC to fully reinstate its accreditation. The Supreme Court reversed in part and affirmed in part, holding (1) the district court erred in conducting a de novo approach to the accreditation process; (2) judged by the correct standard of review, the accreditation decision was well supported and not arbitrary or capricious; and (3) the district court correctly dismissed PMTC’s state law claims for breach of contract, negligence, and tortious interference. Remanded. View "Prof’l Massage Training v. Accreditation Alliance of Career Schs." on Justia Law

In 1999, Allstate reorganized its business and terminated the at-will employment contracts of about 6,200 sales agents, offering them conversion to independent contractor status; $5,000 and an economic interest in their accounts, to be sold to buyers approved by Allstate; severance pay equal to one year’s salary; or severance pay of 13 weeks’ pay. Employees who chose independent contractor status received a bonus of at least $5,000, were not required to repay any office-expense advances, and acquired transferable interests in their business two years after converting. All employees who chose not to convert and left the company were bound by noncompetition covenants in their original contracts. As a condition of becoming independent contractors, agents were required to sign a release waiving existing legal claims against Allstate. The Equal Employment Opportunity Commission sued, claiming that the company violated federal anti-retaliation laws. The district court reversed. The Third Circuit affirmed, noting the settled rule that employers can exchange consideration for releases of claims and that EEOC established neither protected activity nor an adverse action. View "Equal Emp't Opportunity Comm'n v. Allstate Ins. Co" on Justia Law

Rosana Claudio-de Leon (Claudio) and the University of the East of the Ana G. Mendez University System (SUAGM) entered into an employment contract that contained a forum selection clause precluding adjudication in federal court. Claudio, Luis F. Carrasquillo-Rivera, and the conjugal partnership Carrasquillo-Claudio (collectively, Appellants) filed suit against SUAGM in the district court, alleging, among other claims, pregnancy and gender discrimination. The district court dismissed Appellants’ Title VII pregnancy and gender discrimination claim and supplemental state law claims due to the forum selection clause. The First Circuit affirmed as modified, holding (1) the forum selection clause was applicable and enforceable; but (2) the district court should have dismissed the case without prejudice to permit Appellants to refile in the appropriate forum. Remanded.View "Claudio de-Leon v. Ayala" on Justia Law

This case stemmed from the district court’s approval of the Utah Department of Financial Institutions’ (UDFI) seizure of America West Bank Members, L.C. (Bank) and the appointment of the Federal Deposit Insurance Corporation as receiver of the Bank. The Bank filed a complaint against the State, UDFI, and the director of UDFI (collectively, the State), alleging breach of contract, breach of the covenant of good faith and fair dealing, constitutional takings, and due process violations. The district court dismissed the Bank’s claims for lack of sufficient factual allegations under Utah R. Civ. P. 12(b)(6). The Supreme Court affirmed, holding (1) the district court did not err when it dismissed the Bank’s claims; and (2) the district court did not hold the Bank to a heightened pleading standard.View "America West Bank Members, L.C. v. State" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of his former employers, BoA, on his claim of age discrimination under the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. 621 et seq., and breach of contract. Under the McDonald Douglas Corp v. Green framework, assuming arguendo that plaintiff met his burden of demonstrating a prima facie case of age discrimination, the court agreed with the district court that BoA has satisfied its burden to articulate a legitimate, nondiscriminatory reason for plaintiff's termination. BoA has explained that plaintiff's employment was terminated as part of a company-wide reduction in force; two months prior to his termination, plaintiff received a negative mid-year performance review; and as of September 2010, plaintiff was ranked 136th across all BoA sales personnel for the year and his performance was the worse of all employees in his group. In regards to the breach of contract claim, the district court correctly determined that plaintiff was an at-will employee and that although annual bonuses were discretionary, there is no record evidence, or even an allegation, indicating that plaintiff was promised a mid-year bonus. Accordingly, the court affirmed the judgment of the district court. View "Delaney v. Bank of America Corp." on Justia Law

Jeffrey Healey and Edward Given, residents of the Massachusetts Treatment Center, were each civilly committed as a sexually dangerous person. Plaintiffs brought separate suits, which were later consolidated, challenging the conditions of their confinement and the adequacy of their sexual offender treatment. Plaintiffs sought equitable relief against the Massachusetts Department of Corrections and other state officials (collectively, the DOC). Both plaintiffs alleged violations of the Constitution and state statutory provisions, and Healey alleged that the DOC was not in compliance with the terms of a management plan (Plan) for the Center developed by the DOC during the course of prior litigation. The district court granted Plaintiffs declaratory and injunctive relief on some claims and entered judgment in favor of the DOC on the remaining claims. The First Circuit (1) reversed the declaratory judgment in favor of Healey on his contempt claim as well as injunctive relief compelling the Commonwealth’s compliance with the Plan’s provisions; and (2) affirmed the district court’s judgment in favor of Defendants in all respects with the exception of the judgment for Plaintiffs regarding the constitutionality of the pharmacological evaluation and treatment provided by Defendants, as that portion of the judgment was not challenged on appeal. View "Healey v. Dennehy" on Justia Law

Plaintiff filed suit against John Travolta, Atlo, and others (collectively, "Atlo"), seeking a declaration as to whether a three-page agreement or a four-page agreement was the enforceable termination agreement between the parties, and whether a confidentiality provision, if one exists, is enforceable. Atlo filed an anti-strategic lawsuit against public participation (anti-SLAPP) motion to strike the first amended complaint under Code Civ. Proc., 425.16. The court held that a declaratory relief action filed in response to an attorney's letters threatening litigation over the contract dispute does not come within the provisions of an anti-SLAPP lawsuit where the lawsuit sought a declaration regarding the terms of plaintiff's termination agreement, not whether Atlo may send demand letters or threaten litigation. Accordingly, the court concluded that the trial court properly denied the motion to strike the complaint and affirmed the judgment of the trial court. View "Gotterba v. Travolta" on Justia Law

MHFS filed suit against the County, the Commission, and others for interfering with its business operations at the Baxter County Airport. The court concluded that the district court did not err in dismissing MHFS's claims for breach of contract where MHFS did not allege any breach of contract distinct from the breach of the duty to act in good faith; Arkansas law does not recognize a "continuing tort" theory; even if the court were to assume such acts were intentional, MHFS failed to state a claim for intentional interference with its business relationship; the district court correctly dismissed MHFS's civil rights claims for denial of procedural due process where MHFS was not deprived of any property or liberty interest; the district court did not abuse its discretion by declining to exercise supplemental jurisdiction over state law claims; and the district court did not abuse its discretion in denying the motion to amend following its dismissal of the action. Accordingly, the court affirmed the judgment of the district court. View "Mountain Home Flight Service v. Baxter County, et al." on Justia Law

Lisa Knitter worked as a "handyman" for Lewis General Contracting, Inc. (LGC) from March to October 2010. During this time, LGC's sole client was Picerne Military Housing, LLC (Picerne), now known as Corvias Military Living, LLC. Knitter performed handyman services exclusively on Picerne properties. She sued Picerne under Title VII of the Civil Rights Act of 1964, alleging: (1) she was paid lower wages than her male counterparts; (2) Picerne effectively fired her in retaliation for her complaints of sexual harassment and wage discrimination; and (3) after she was fired, Picerne denied her application for vendor status in retaliation for her prior complaints of discrimination. The district court granted summary judgment to Picerne, dismissing Knitter's Title VII action because Picerne was not her employer. The district court also dismissed her claim for retaliatory denial of vendor status because Knitter did not apply for employment with Picerne when she applied to be a vendor. Knitter appealed to the Tenth Circuit Court of Appeals. Finding no reversible error, however, the Tenth Circuit affirmed. View "Knitter v. Picerne Military Housing" on Justia Law