Justia Civil Rights Opinion Summaries

Anita Cooper, who was employed as principal of the Oark, Arkansas schools, was removed from her duties as principal. The Superintendent of the Jasper School District No. 1 of Newton County listed nine reasons as bases for the termination. The District’s Board of Directors then terminated Cooper’s employment. The circuit court reversed the Board’s decision, reinstated Cooper to her position, and awarded Cooper $64,998 in damages. The Superintendent and District appealed. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that Defendants failed to comply with the Teacher Fair Dismissal Act; (2) the circuit court did not err in concluding that the contract in the case at bar created a property right in Cooper’s position as principal of the Oark schools; and (3) the circuit court’s award to Cooper was neither excessive nor amounted to an award of “double retirement.” View "Jasper Sch. Dist. No. 1 v. Cooper" on Justia Law

Kathryn Scrivener sued Clark College, claiming that age was the reason it did not hire her for a tenure track teaching position. She was 55 years old at the time, squarely within the 40- to 70-year-old age range protected by the Washington's Law Against Discrimination (WLAD). The candidates ultimately picked for the positions were both under the age of 40. The trial court granted summary judgment in Clark College's favor, finding that Scrivener failed to prove that the college's stated reason for its decision was a pretext. The Court of Appeals affirmed. The Supreme Court took the opportunity of this case to clarify the standard must meet to overcome summary judgment: Employees may satisfy the pretext prong of the "McDonnell Douglas" framework by offering sufficient evidence to create a genuine issue of material fact either: (1) that the employer's articulated reason for its action is pretextual; or (2) that, although the employer's stated reason is legitimate, discrimination nevertheless was a substantial factor motivating the employer. Applying this standard, the Supreme Court reversed the grant of summary judgment. Scrivener created a genuine issue of material fact concerning whether age was a substantial factor motivating Clark College's decision to hire younger candidates. View "Scrivener v. Clark College" on Justia Law

Kao earned a Ph.D. in applied mathematics from Princeton, began teaching mathematics at University of San Francisco in 1991, and became a tenured professor in 1997. Kao was concerned about a lack of diversity of the faculty of the math and computer science departments, and submitted a 485-page complaint to the school in 2006 alleging race-based discrimination and harassment. He lodged a 41-page addendum to the complaint in 2007 school’s failure to advertise in professional journals. During meetings concerning the issue, Kao became “very, very upset,” and started “yelling and screaming.” USF directed Kao to have a fitness-for-duty examination after faculty members and school administrators reported that his behavior was frightening them, and the university terminated his employment when he refused to participate in the examination. Kao sued under the Fair Employment and Housing Act (Gov. Code, 12900), the Unruh Civil Rights Act (Civ. Code, 51), the Confidentiality of Medical Information Act (Civ. Code, 56), and the state constitution’s right to privacy. His defamation claim was dismissed and a jury ruled against him on his other claims. The court of appeal affirmed, rejecting an argument that USF could not lawfully require an examination.View "Kao v. Univ. of San Francisco" on Justia Law

Appellant was injured while on duty as a deputy sheriff with the Douglas County sheriff’s office. While Appellant was receiving workers’ compensation benefits, a County employee had Appellant placed under surveillance. The Sheriff’s Office later terminated Plaintiff’s employment on the basis that Appellant had been “untruthful and deceptive” regarding the extent of his injuries. The Douglas County Sheriff’s Merit Commission affirmed the termination. The district court affirmed. Thereafter, Appellant filed a petition in the district court against the Douglas County Sheriff and the County (collectively, Appellees), alleging wrongful discharge in retaliation for having pursued a workers’ compensation claim and violations of 42 U.S.C. 1983 based on three theories of liability. The district court granted Appellees’ motion for summary judgment. The Supreme Court affirmed, holding that the district court did not err when it determined (1) Appellant’s first cause of action was barred under Neb. Rev. Stat. 13-919(1); and (2) Appellees did not violate Appellant’s constitutional right to property, right to freedom of speech, or right to privacy.View "Brock v. Dunning" on Justia Law

Appellee filed an employment-discrimination action against the Dayton Police Department (DPD) and Major Mitchell Davis, her supervisor, alleging, inter alia, age- and sex-based discrimination in violation of Ohio Rev. Code 4112 and Title VII of the Civil Rights Act. DPD and Davis filed a motion for summary judgment, arguing that Davis was entitled to immunity on the basis that a supervisor employed by a political subdivision cannot be held individually liable in a discrimination action. The trial court denied the motion for summary judgment as it related to Appellee’s claim of sex discrimination under Chapter 4112 and denied the motion as it related to Davis’s claim of immunity. The court of appeals affirmed on the basis that Ohio Rev. Code 2744.03(A)(6)(c), which states that political-subdivision employees, such as Davis, are not entitled to immunity if civil liability is expressly imposed upon the employee by a section of the Revised Code. The Supreme Court reversed, holding that Ohio Rev. Code 4112.01(A)(2) and 4112.02(A) do not expressly impose civil liability on political-subdivision employees so as to trigger the immunity exception in section 2744.03(A)(6)(c).View "Hauser v. Dayton Police Dep’t" on Justia Law

Eddie Yau filed a complaint against his former employer, Santa Margarita Ford, alleging he was wrongfully terminated in violation of public policy. Yau alleged he was terminated after complaining to Santa Margarita Ford's management about fraudulent warranty repair claims being submitted to Ford Motor Company. Yau also alleged an intentional infliction of emotional distress cause of action against individual defendants who were his coworkers and supervisors, and the owner of Santa Margarita Ford. The trial court sustained demurrers without leave to amend and dismissed the action, entering separate judgments for Santa Margarita Ford and the individual defendants. After review, the Court of Appeal concluded Yau adequately pleaded his wrongful termination cause of action and therefore the judgment in favor of Santa Margarita Ford was granted in error. The Court concluded that the trial court correctly dismissed the intentional infliction of emotional distress cause of action, and the judgment in favor of the individual defendants was affirmed. View "Yau v. Santa Margarita Ford" on Justia Law

Police Chief Beck charged Officer Pedro with misconduct: use of a city police vehicle for personal business on two occasions, making a discourteous statement to a member of the public, and making a misleading statement to a supervisor conducting an official investigation. A Board of Rights found that three counts were time-barred. Beck disagreed; the board found Pedro guilty on all counts and recommended a 22-day suspension without pay. Beck approved the recommendation. The trial court found in favor of Pedro, finding counts one and four barred by the statute of limitations and counts two and three not barred. It concluded that Pedro was not informed that he was being investigated for misconduct prior to his interrogation, as required, and suppressed Pedro’s statements and set aside the guilty finding on count four. Although the court found that counts two and three were not barred by the statute of limitations, it determined that the Board had found that those counts were barred, and that its finding was final and binding because the city failed to challenge the decision. The court of appeal affirmed, finding that the Board failed to proceed as required by law by deferring to Beck’s determination on the statute of limitations rather than making a decision consistent with its own findings, and that its findings do not support its decision. Ignorance of the accused officer’s identity does not postpone the commencement of the one-year limitations period under Government Code section 3304. The discovery rule applies; the trial court properly determined that count four is time-barred. View "Pedro v. City of Los Angeles" on Justia Law