Justia Civil Rights Opinion Summaries

Creighton Preparatory School expelled Plaintiff after he made lewd remarks about a teacher. Plaintiff sued Creighton under Title IX of the Education Amendments of 1972 on the theory that the school had discriminated against him by failing to perform an “adequate and impartial investigation.” The district court granted Creighton’s motion to dismiss. It first dismissed the Title IX claim because Plaintiff had failed to “allege [that] his sex played any part in the disciplinary process at all.” Then, with the federal question gone, it declined to exercise supplemental jurisdiction over Plaintiff’s breach-of-contract claim.The Eighth Circuit affirmed. The court explained that Plaintiff does not allege that Creighton faced external pressure to punish male students, much less gave in by expelling him. The court reasoned that without an allegation of that kind, the complaint fails to plausibly allege the sort of “causal connection between the flawed outcome and gender bias” required to make an erroneous outcome theory work.Further, the court wrote that treating men and women differently can support an inference of sex discrimination, but it requires identifying a similarly situated member of the opposite sex who has been “treated more favorably.” For Plaintiff, he had to find “a female accused of sexual harassment” who received better treatment. There are no female students at Creighton, an all-boys school, let alone any who have faced sexual-misconduct allegations. The court explained that to the extent that Plaintiff argues that believing them over him raises an inference of discrimination, there is nothing alleged that the school did so because of his sex. View "Elijah Wells v. Creighton Preparatory School" on Justia Law

The Supreme Court affirmed the judgment of the trial court dissolving Plaintiff's marriage to Defendant, holding that Plaintiff was not entitled to relief on his allegations of error.At issue in this case was the extent to which a Connecticut court may enforce the terms of a "ketubah," a contract governing marriage under Jewish law. The trial court in this case denied Plaintiff's motion to enforce the terms of the parties' ketubah as a prenuptial agreement on the ground that doing so would be a violation of the First Amendment to the United States constitution. The Supreme Court affirmed, holding (1) the trial court properly denied Plaintiff's motion to enforce the ketubah; and (2) the trial court's alimony order, considered in light of Plaintiff's net earning capacity, was not an abuse of discretion. View "Tilsen v. Benson" on Justia Law

Plaintiff sued The Savannah College of Art and Design, Inc. (“SCAD”) for race discrimination and retaliation after he was fired from his job as Head Fishing Coach. As part of his employment onboarding, however, Plaintiff signed a document agreeing to arbitrate—not litigate—all legal disputes that arose between him and SCAD. Accordingly, SCAD moved to dismiss and compel arbitration. The district court, approving and adopting the magistrate judge’s Report and Recommendation (“R & R”), granted SCAD’s motion. On appeal, Plaintiff argued that the district court erred by ignoring that his agreement with SCAD was unconscionable and that SCAD waived its right to arbitrate. He also argued that the district court abused its discretion in rejecting his early discovery request.   The Eleventh Circuit affirmed the district court’s order granting SCAD’s motion to dismiss and compel arbitration. The court concluded that the Plaintiff’s arbitration agreement is neither substantively nor procedurally unconscionable. Further, the court found that SCAD did not waive its right to enforce arbitration and that the district court did not abuse its discretion in overruling Plaintiff’s request for early discovery. In short, the court concluded that Plaintiff is bound by his agreement to arbitrate his legal claims against SCAD. View "Isaac Payne v. Savannah College of Art and Design, Inc." on Justia Law

The First Circuit affirmed the district court's order entering summary judgment in favor of Defendant with respect to Plaintiff's assertion that he was wrongfully deprived of thousands of dollars in commissions he alleged he was due, holding that there was no error.After he resigned, Plaintiff brought suit against Defendant, his former employer, asserting claims for nonpayment of wages under the Act, breach of contract, unjust enrichment, and quantum meruit. Defendant successfully removed the action to federal district court, which granted summary judgment in favor of Defendant. The First Circuit affirmed, holding that the district court (1) did not err in granting in part Defendant's motion to strike certain portions of his response to the summary judgment motion; and (2) did not err in granting summary judgment against Plaintiff on his claims. View "Klauber v. VMware, Inc." on Justia Law

On a  Mesa Airlines flight from Birmingham to Dallas Fort Worth International Airport, a flight attendant grew concerned about two passengers, Plaintiffs.  She alerted the pilot, who, despite the reassurance of security officers, delayed takeoff until the flight was canceled. The passengers were told the delay was for maintenance issues, and all passengers, including the two in question (Plaintiffs), were rebooked onto a new flight that reached DFW. After learning the real reason behind the cancellation, Plaintiffs sued Mesa under 42 U.S.C. Section 1981. The airline countered that it had immunity under 49 U.S.C. Section 44902(b) and 49 U.S.C. Section 44941(a).     Given the unusual facts that all passengers had their flight canceled, the primary issue on appeal whether such conduct constitutes disparate treatment under Section 1981, whether a Section 1981 claim can exist without a “breach” of contract, and whether Section 44902(b) grants immunity to airlines for allegedly discriminatory decisions, thereby negating Section 1981’s application against airlines in this context.   The Fifth Circuit reversed the district court’s judgment. The court held that Section 1981 prohibits discrimination in contracting. Section 44902(b) provides immunity to airlines in their decision to remove passengers they feel are “inimical to safety.” There is a straightforward way to reconcile these two statutes: If a passenger’s protected status is the but-for cause of the airline’s decision to remove them (such that the passenger has made out a Section 1981 claim), then Section 44902(b) does not grant immunity to the airline because the decision is not based on a fear that the passenger was inimical to safety. View "Abdallah v. Mesa Air Group" on Justia Law

Following an investigation, Rollins determined that Plaintiff- John Doe violated its sexual misconduct policy. Doe was able to graduate and receive his undergraduate degree but was not allowed to participate in commencement/graduation ceremonies. Rollins imposed a sanction of dismissal, resulting in permanent separation of Doe without the opportunity for readmission; privilege restrictions, including a prohibition on participating in alumni reunion events on or off campus; and a contact restriction as to Roe. Doe sued Rollins in federal court, asserting two claims under Title IX, 20 U.S.C. Section 1681—one for selective enforcement and one for erroneous outcome—and a third claim under Florida law for breach of contract. Following discovery, the district court excluded the opinions proffered by Doe’s expert as to Rollins’ purported gender bias. Then, on cross-motions for summary judgment, the district court (a) entered summary judgment in favor of Rollins on the Title IX claims and (b) entered partial summary judgment in favor of Doe on the breach of contract claim.   The Eleventh Circuit affirmed. The court concluded that the district court did not abuse its discretion in precluding Doe’s expert from presenting opinions about Rollins’ purported gender bias and that it correctly granted summary judgment in favor of Rollins on Doe’s two Title IX claims. On the breach of contract claim, the court wrote that it cannot review Doe’s challenge to the district court’s partial denial of summary judgment because materiality is not a purely legal issue under Florida law and was later resolved by the jury. View "John Doe v. Rollins College" on Justia Law

Plaintiff, a former employee, sued on behalf of herself and similarly situated employees, claiming that St. Luke’s violated the Fair Labor Standards Act’s (“FLSA”) overtime provisions by failing to fully compensate employees for work performed. She also brought an unjust-enrichment claim under state law. The district court certified two classes with different lookback periods: (1) an FLSA collective comprised of employees who worked for St. Luke’s between September 2016 and September 2018, 1 and (2) an unjust-enrichment class comprised of all employees who worked for St. Luke’s in Missouri between April 2012 and September 2018. Houston also asserted individual claims, one under the Missouri Minimum Wage Law, and one for breach of her employment contract. The district court granted summary judgment to St. Luke’s on all claims.   The Eighth Circuit vacated and remanded. The court explained that Plaintiff has raised a genuine dispute that the rounding policy does not average out over time. The court explained that no matter how one slices the data, most employees and the employees as a whole fared worse under the rounding policy than had they been paid according to their exact time worked. Here, the rounding policy did both. It resulted in lost time for nearly two-thirds of employees, and those employees lost more time than was gained by their coworkers who benefited from rounding. The court concluded that the employees have raised a genuine dispute that the rounding policy, as applied, did not average out over time. The district court, therefore, erred in granting summary judgment on the FLSA and Missouri wage claims. View "Torri Houston v. St. Luke's Health System, Inc." on Justia Law

Plaintiff worked for Tug Hill Operating, LLC, for approximately a year and a half at rig sites in West Virginia. He commenced an action against Tug Hill under the Fair Labor Standards Act (“FLSA”), alleging that while Tug Hill formally classified him as an independent contractor, he actually qualified as an employee for purposes of the FLSA based on the degree of control that Tug Hill exercised over his work. He, therefore, claimed that Tug Hill was required to pay him overtime for those weeks in which he worked more than 40 hours. Tug Hill filed a motion to dismiss Plaintiff’s action on the ground that Plaintiff was contractually required to arbitrate his claim against it. In addition, RigUp itself filed a motion to intervene in order to seek the action’s dismissal in favor of arbitration. The district court granted both motions.   The Fourth Circuit reversed both rulings and remanded. The court explained that the numerous provisions in the Agreement preclude any conclusion that the Agreement was entered into solely or directly for the benefit of Tug Hill, such that Tug Hill could enforce it as a third-party beneficiary. Accordingly, the district court erred in granting Tug Hill’s motion to dismiss and compelling Plaintiff, under the arbitration agreement between him and RigUp, to proceed to arbitration with respect to his FLSA claim against Tug Hill. Moreover, the court explained that because RigUp’s agreement with Plaintiff expressly disclaimed any interest in any litigation, Plaintiff might have with a company in Tug Hill’s position RigUp cannot now opportunistically claim that intervention is necessary. View "Lastephen Rogers v. Tug Hill Operating, LLC" on Justia Law

Plaintiffs are twenty-six former employees of International Business Machines Corporation (“IBM”) who signed separation agreements requiring them to arbitrate any claims arising from their termination by IBM. The agreements set a deadline for initiating arbitration and included a confidentiality requirement. Plaintiffs missed the deadline but nonetheless tried to arbitrate claims under the Age Discrimination in Employment Act of 1967 (“ADEA”). Their arbitrations were dismissed as untimely. They then sued IBM in district court, seeking a declaration that the deadline is unenforceable because it does not incorporate the “piggybacking rule,” a judge-made exception to the ADEA’s administrative exhaustion requirements. Shortly after filing suit, Plaintiffs moved for summary judgment and attached various documents obtained by Plaintiffs’ counsel in other confidential arbitration proceedings. IBM moved to seal the confidential documents. The district court granted IBM’s motions to dismiss and seal the documents. On appeal, Plaintiffs argued that (1) the filing deadline in their separation agreements is unenforceable and (2) the district court abused its discretion by granting IBM’s motion to seal.   The Second Circuit affirmed. The court first wrote that the piggybacking rule does not apply to arbitration and, in any event, it is not a substantive right under the ADEA. Second, the court held that the presumption of public access to judicial documents is outweighed here by the Federal Arbitration Act’s (“FAA”) strong policy in favor of enforcing arbitral confidentiality provisions and the impropriety of counsel’s attempt to evade the agreement by attaching confidential documents to a premature motion for summary judgment. View "In re IBM Arb. Agreement Litig." on Justia Law

The First Circuit affirmed the judgment of the district court in favor of the Puerto Rico Highways and Transportation Authority (PRHTA) and its executive directors (collectively, Appellees) and dismissing this complaint brought by sixty-nine current and former employees of the PRHTA (collectively, Appellants), holding that the district court did not err or abuse its discretion.Appellants brought this action challenging the PRHTA's decision no longer to give effect to a regulation providing Appellants with additional compensation. Specifically, Appellants claimed that the decision was contrary to P.R. Act No. 66-2014, giving rise to violations of the Contracts Clause and Due Process Clause. The district court granted summary judgment for the PRHTA on the federal constitutional claims and declined to exercise supplemental jurisdiction over Appellants' claims under Puerto Rico law. The First Circuit affirmed, holding that the district court (1) did not err in concluding that Appellants could not establish their federal constitutional claims; and (2) did not abuse its discretion in declining to exercise jurisdiction over Appellants' remaining Puerto Rico law claims. View "Vazquez-Velazquez v. P.R. Highway & Transportation Authority" on Justia Law