Justia Civil Rights Opinion Summaries

Natasha Knox, a Black woman of Jamaican descent, worked as a customer service attendant at three Clean Rite laundromats in the Bronx from December 2018 until her termination in April 2019. She alleged that her supervisors, Cecilia Ashmeade and Kenneth Ferris, made derogatory comments about her race and national origin, and that Clean Rite failed to accommodate her disability following a thumb injury. Knox also claimed she was not paid for extra shifts worked at other locations and was wrongfully terminated after reimbursing herself for taxi fare from the cash register, which she claimed was permitted.The United States District Court for the Southern District of New York granted summary judgment in favor of Clean Rite, dismissing Knox’s claims of discriminatory and retaliatory termination, hostile work environment, refusal to accommodate her disability, and unpaid wages. The district court found that Knox had not provided sufficient evidence to support her claims. Knox’s motion to strike the defendants’ answer and request for default judgment against Ashmeade and Ferris, who had failed to appear, was denied as moot.The United States Court of Appeals for the Second Circuit reviewed the case de novo and found that Knox had presented sufficient evidence to survive summary judgment on all her claims. The court noted that evidence such as Knox’s testimony and sworn affidavit could lead a reasonable jury to find in her favor. The court vacated the district court’s judgment and remanded the case for further proceedings on each of Knox’s claims. The claims against Ashmeade and Ferris were reinstated for the district court to reconsider Knox’s motion to strike their answer and for default judgment. View "Knox v. CRC Management Co." on Justia Law

Former employees of Shriners Hospitals for Children were terminated for refusing to get a COVID-19 vaccination. They sued their employer, its agents, and the Executive Commissioner of Texas Health and Human Services, alleging violations of their right to refuse the vaccine under 42 U.S.C. § 1983, the Emergency Use Authorization (EUA) Statute, and various Texas state laws.The United States District Court for the Southern District of Texas dismissed all claims. It found no personal jurisdiction over the agents due to the fiduciary shield doctrine, determined that Shriners was not a state actor when it implemented the vaccination policy, and ruled that the EUA Statute did not apply. The court also dismissed the claims against the Commissioner, concluding she was not liable for failing to stop Shriners from enforcing the policy. The state-law claims were dismissed for lack of supplemental jurisdiction.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. It agreed that there was no personal jurisdiction over the agents and that Shriners was not a state actor when it adopted the vaccination policy. The court also held that the EUA Statute did not apply to Shriners in its capacity as an employer and that the Commissioner was entitled to qualified immunity because the plaintiffs did not demonstrate a clearly established right requiring her intervention. The appellate court modified the dismissal of the state-law claims to be without prejudice and affirmed the judgment as modified. View "Pearson v. Shriners Hospitals" on Justia Law

Stacie Culp and Stephanie Peters, both servers at Remington of Montrose Golf Club, LLC, alleged they were sexually harassed by bartender Jason DeSalvo. They filed claims under Title VII of the Civil Rights Act of 1964 and the Colorado Anti-Discrimination Act (CADA) for sexual harassment and retaliation. Remington's management conducted a limited investigation, resulting in DeSalvo's suspension and demotion. Culp claimed her hours were reduced in retaliation, leading to her resignation. Peters alleged inadequate investigation and retaliation, including being scheduled to work with DeSalvo post-suspension, leading to her departure.The United States District Court for the District of Colorado granted summary judgment for Remington on Peters's retaliation claim but allowed other claims to proceed to trial. The jury found against Peters on her remaining claims and returned inconsistent special verdicts on Culp's claims, awarding her punitive damages under Title VII despite finding no violation of her rights.The United States Court of Appeals for the Tenth Circuit affirmed the district court's summary judgment on Peters's retaliation claim, holding that neither the inadequate investigation nor the scheduling with DeSalvo constituted materially adverse actions. However, the court found the jury's verdict on Culp's claims irreconcilably inconsistent and vacated the verdict, remanding for a new trial on her harassment and retaliation claims. The court upheld the district court's evidentiary rulings, noting that objections to the admission of certain evidence were not properly preserved for appeal. View "Culp v. Remington of Montrose Golf Club" on Justia Law

Susan Kinder, a white woman, was employed by the Marion County Prosecutor’s Office (MCPO) and alleged racial discrimination when she was reassigned to a new role. She claimed violations of Title VII and the Equal Protection Clause. Kinder had conflicts with a black colleague, Lydia Richardson, who accused her of making racially insensitive remarks. An investigation found the animosity was mutual. The prosecutor decided to reassign both employees, but Kinder viewed her new role as a demotion.The Equal Employment Opportunity Commission (EEOC) issued a right-to-sue letter on April 28, 2022, but Kinder’s counsel could not access it until July 6, 2022. Kinder filed her complaint on October 4, 2022, alleging Title VII and Equal Protection Clause violations. The MCPO moved for summary judgment, arguing the Title VII claim was untimely and that the office was not a suable entity under 42 U.S.C. § 1983. The United States District Court for the Southern District of Indiana granted summary judgment to the MCPO, finding the Title VII claim was filed outside the 90-day window and that the MCPO was an arm of the state, immune from § 1983 claims.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the 90-day period for filing the Title VII claim began when Kinder’s counsel was notified on June 15, 2022, that the right-to-sue letter was available, making the October 4 filing untimely. The court also held that the MCPO is an arm of the state and not a suable “person” under § 1983, as the office is financially interdependent with the state and enjoys state indemnification for employment-related actions. View "Kinder v Marion County Prosecutor's Office" on Justia Law

Annette Rodriguez, the plaintiff, served as the Director of the City of Corpus Christi and Nueces County Public Health District. Her salary was split between the City and the County. In 2019, the City increased her salary to 90% of the market rate. During the COVID-19 pandemic, Rodriguez requested and initially received overtime pay, but the City later stopped these payments. Rodriguez faced several allegations of policy violations and creating a hostile work environment, leading to a disciplinary memorandum. Despite a positive evaluation from the County, the City terminated her in 2022 and hired a new director.Rodriguez sued the City in the United States District Court for the Southern District of Texas, claiming violations under the Equal Pay Act, Fair Labor Standards Act (FLSA), Title VII, and 42 U.S.C. § 1983. The district court dismissed her Section 1983 claim on the pleadings, finding she did not allege a constitutionally protected interest in continued employment. The court granted summary judgment to the City on the remaining claims, concluding Rodriguez was exempt from FLSA overtime pay requirements, did not establish the equal-work or equal-pay prongs of her EPA claim, and failed to identify a proper comparator for her Title VII claim.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's rulings, agreeing that Rodriguez did not engage in protected activity under the FLSA, failed to identify a proper comparator for her Title VII and EPA claims, and did not establish pretext for retaliation. The court also found that Rodriguez remained an exempt employee despite receiving additional overtime pay temporarily. The court concluded that the City paid Rodriguez on a salary basis, maintaining her exempt status under the FLSA. View "Rodriguez v. City of Corpus Christi" on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

The case involves Jose Rosado, a Hispanic male of Colombian origin, who worked as an Information Technology (IT) Specialist for the United States Navy. Rosado alleged that he was denied promotions on five occasions between 2014 and 2018 due to race, national origin, and age discrimination, as well as retaliation for his prior Equal Employment Opportunity (EEO) activity. The promotions in question were for various IT Specialist positions within the Naval Facilities Engineering Command, Southeast (NAVFAC SE).In the lower court, the United States District Court for the Middle District of Florida granted summary judgment in favor of the Navy. The court concluded that Rosado failed to establish a prima facie case of discrimination or retaliation for any of the promotion decisions. Specifically, the court found that Rosado did not provide sufficient evidence to show that he was equally or more qualified than the individuals who were selected for the positions or that the Navy's decisions were influenced by discriminatory or retaliatory motives.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Rosado did not establish a prima facie case of discrimination because he failed to show that the selected candidates were similarly situated in all material respects or that unlawful discrimination played any part in the Navy's decision-making process. Additionally, the court found that Rosado did not present sufficient evidence to support his retaliation claims, as there was no indication that retaliatory animus influenced the Navy's actions.In summary, the Eleventh Circuit affirmed the district court's grant of summary judgment for the Navy, concluding that Rosado did not provide enough evidence to support his claims of discrimination and retaliation. View "Rosado v. Secretary, U.S. Department of the Navy" on Justia Law

Betty Grooms, a Missouri clerk of court, filed a lawsuit under 42 U.S.C. § 1983 against Alice Bell and Judge Steven Privette, alleging violations of her First Amendment rights through discrimination and retaliation, and violations of her substantive due process rights. Grooms, a Republican, had defeated Bell, a Democrat, in an election for Circuit Clerk. Bell, who retained her job under Grooms, later married Privette, a Republican judge. Tensions arose when Bell and Privette were uncooperative with Grooms, leading to Bell's resignation and announcement to run for Circuit Clerk. Privette ordered Grooms to prepare detailed spreadsheets, which he repeatedly rejected, and initiated a contempt prosecution against her, which was eventually dismissed by the Missouri Supreme Court.The United States District Court for the Western District of Missouri dismissed Grooms's claims, ruling that the defendants did not violate her clearly established First Amendment rights and did not violate her substantive due process rights. The court found that the defendants' actions did not constitute adverse employment actions under clearly established law and that Grooms did not suffer a serious deprivation of a protected interest.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Bell and Privette were entitled to qualified immunity on the First Amendment claim, as Grooms failed to show that their actions constituted adverse employment actions under clearly established law. Additionally, the court found that Grooms's substantive due process claim was inadequate, as she did not demonstrate a serious deprivation of a protected interest. The court concluded that the defendants' conduct did not shock the conscience and did not violate Grooms's substantive due process rights. View "Grooms v. Privette" on Justia Law

A national news reporter employed by a prominent newspaper sued her employer and six of its editors in Superior Court, alleging violations of the D.C. Human Rights Act and the common law tort of negligent infliction of emotional distress. She claimed that the defendants discriminated against her based on her status as a sexual assault victim and her gender, took adverse employment actions against her, subjected her to a hostile work environment, and retaliated against her for protesting their discriminatory actions.The defendants moved to dismiss the complaint under Superior Court Civil Rule 12(b)(6) for failure to state a claim and filed a special motion to dismiss under the D.C. Anti-SLAPP Act, arguing that the claims arose from acts in furtherance of the right of advocacy on issues of public interest. The Superior Court denied the special motion to dismiss, finding that the claims did not arise from speech protected by the Anti-SLAPP Act, but granted the Rule 12(b)(6) motion, concluding that the complaint failed to plausibly allege unlawful discrimination or retaliation.The District of Columbia Court of Appeals reviewed the case and affirmed the denial of the special motion to dismiss, agreeing that the Anti-SLAPP Act did not apply. The court reversed the dismissal of the counts alleging adverse action discrimination, finding that the complaint plausibly alleged that the defendants took certain adverse employment actions against the reporter in violation of the Human Rights Act. However, the court affirmed the dismissal of the hostile work environment and retaliation claims, concluding that the allegations did not meet the necessary legal standards. The court also noted that it was premature to decide whether the defendants' actions were protected by the First Amendment, leaving that issue open for further proceedings. View "Sonmez v. WP Company, LLC" on Justia Law

A registered nurse, Alexandra Melino, sued her former employer, Boston Medical Center (BMC), alleging violations of Title VII of the Civil Rights Act and Massachusetts General Laws by denying her request for a religious exemption from BMC's COVID-19 vaccination mandate. Melino's primary duties involved direct patient care in critical units. During the pandemic, BMC converted several units to COVID-19 units and faced significant staffing challenges due to the virus. BMC implemented a vaccination policy based on CDC recommendations to mitigate the risk of COVID-19 transmission among staff and patients.The United States District Court for the District of Massachusetts granted summary judgment to BMC, holding that Melino's requested exemption would impose undue hardship on the hospital. The court found that Melino could not work remotely, could not work in-person unvaccinated without risking patient safety, and that any feasible accommodation would impose substantial costs on BMC. Melino's motion to strike portions of an affidavit submitted by BMC was also denied due to her failure to comply with local procedural rules.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court affirmed the district court's decision, agreeing that BMC had demonstrated undue hardship by showing that allowing Melino to work unvaccinated would increase the risk of COVID-19 transmission. The court noted that Melino did not provide any medical evidence to contradict BMC's reliance on CDC recommendations. Additionally, Melino's argument that BMC should have considered alternative accommodations was waived as it was not raised in the lower court. The court upheld the district court's rulings, affirming the grant of summary judgment in favor of BMC. View "Melino v. Boston Medical Center" on Justia Law