Justia Civil Rights Opinion Summaries

Plaintiff sued her employer under the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-43, and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601-54, and asserted other state common law claims including breach of employment contract. Plaintiff subsequently appealed the dismissal of her breach of contract claim with prejudice, the denials of her motions for leave to amend her complaint, the denial of her motion for consideration, and the adverse grant of her MHRA and FMLA claims by the district court. The court did not reach the merits of plaintiff's arguments because any error with respect to the dismissal of the breach of employment contract claim was harmless where plaintiff resigned from her employment with the county and failed to generate a genuine issue of fact as to constructive discharge in the context of her MHRA reprisal claim. The court also held that because plaintiff failed to generate an issue of fact as to whether she suffered a materially adverse employment action, summary judgment was appropriate as to her MHRA retaliation claim. The court further held that summary judgment was properly granted on plaintiff's FMLA interference claim where plaintiff did not contest the district court's finding that she received the full twelve weeks of FMLA leave to which she was entitled each year she requested it. The court finally held that summary judgment was properly granted on plaintiff's FMLA retaliation claim where she failed to generate an issue of fact as to whether she suffered an adverse employment action.

Appellant appealed the district court's orders granting summary judgment in favor of the City of Lake Lotawana, and its mayor, and the subsequent dismissal of her wrongful termination and retaliation claims. On appeal, appellant contended that the city breached her employment contract and that she established triable issues of fact as to her retaliation claims. The court held that the city was entitled to summary judgment on appellant's wrongful termination claim where she did not have an enforceable contract or viable tort claim. The court also held that appellant was terminated because of her inappropriate activities and therefore, the dismissal of appellant's retaliation claims was affirmed because nothing in the record indicated that her opposition to unlawful discrimination was a contributing factor to her termination. The court further held, for the same reasons, that appellant could not succeed under the more stringent standard applied in the Title VII and Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., claims. Accordingly, the court affirmed the judgement of the district court.

Las Vegas Metropolitan Police Department (LVMPD) was named as a defendant in an action alleging civil rights violations. LVMPD had an insurance policy with respondent Coregis Insurance to protect against liability for police officer actions when the damages exceeded a certain amount. Coregis denied LVMPD coverage for the civil rights claims because LVMPD did not notify Coregis of its potential liability until ten years after the incident that led to the lawsuit. After settling the action, LVMPD filed a declaratory-judgment action seeking a judicial determination that Coregis was required to defend and indemnify LVMPD for damages related to the civil rights claims. The district court entered summary judgment in favor of Coregis, concluding that LVMPD's notice was clearly late and that Coregis was prejudiced by the late notice. The Supreme Court reversed the summary judgment, holding (1) when an insurer denies coverage of a claim because the insured party failed to provide timely notice of the claim, the insurer must demonstrate that notice was late and that it was prejudiced by the late notice in order to assert a late-notice defense to coverage; and (2) there were genuine issues of material fact regarding the timeliness of LVMPD's notice. Remanded.