Justia Civil Rights Opinion Summaries

George Rodrique, II, a photographer for WCVB-TV, sued his employer, Hearst Stations, Inc. ("Hearst"), after it denied his request for a religious exemption from the company's COVID-19 vaccination requirement and subsequently terminated him for refusing to receive the vaccine. Rodrique claimed that Hearst's actions violated Title VII of the Civil Rights Act of 1964, which prohibits religious discrimination in employment.The United States District Court for the District of Massachusetts granted Hearst's motion for summary judgment, concluding that Rodrique's objections to the vaccine were not religious in nature. The court did not address whether accommodating Rodrique's request would have imposed an undue hardship on Hearst.Rodrique appealed to the United States Court of Appeals for the First Circuit, arguing that his objections were indeed religious and that granting the exemption would not have caused undue hardship. He contended that Hearst provided insufficient evidence that the COVID-19 vaccine reduces virus transmission.The First Circuit assumed, without deciding, that Rodrique's objections were religious. However, it affirmed the district court's summary judgment on different grounds, holding that Hearst reasonably relied on objective medical evidence, including public health guidance, to conclude that the vaccine reduces the likelihood of transmitting COVID-19. The court found that Hearst's reliance on such evidence was reasonable and that accommodating Rodrique's request would have imposed an undue hardship on the company. Thus, the First Circuit affirmed the district court's order granting summary judgment to Hearst. View "Rodrique v. Hearst Communications, Inc." on Justia Law

Marcus Todd, a state employee in Minnesota, alleged that a union violated his First and Fourteenth Amendment rights by deducting union dues from his paycheck without his consent. Todd joined the American Federation of State, County, and Municipal Employees in 2014 and authorized dues deductions. In 2018, a new authorization card was allegedly signed electronically with Todd's name, which he claims was forged. After the Supreme Court's decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, Todd attempted to resign from the union and stop dues deductions, but the union continued until May 2021, citing an annual opt-out period.The United States District Court for the District of Minnesota dismissed Todd's federal claims, stating that he voluntarily agreed to the dues deductions before Janus and was contractually bound to the opt-out period. The court also found that the union did not act under color of state law regarding the alleged forgery and dismissed Todd's claims for prospective relief as moot. The court declined to exercise jurisdiction over Todd's state law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Todd's claims failed due to the lack of state action, as the union's actions were based on private agreements, not state statutes. The court referenced Hoekman v. Education Minnesota and Burns v. School Service Employees Union Local 284, which established that private agreements for dues deductions do not constitute state action. The court also found that the alleged forgery did not establish state action, as it was a private misuse of state law. Consequently, the Eighth Circuit affirmed the district court's judgment. View "Todd v. AFSCME" on Justia Law

Marci Walkingstick Dixon, a Native American woman and member of the Cherokee Nation, worked at Northeastern State University (NSU) in the Information Technology Services Department. After being supervised by Dr. Richard Reif, she reported experiencing discriminatory comments and actions based on her race and sex. Following her complaint to NSU's Title IX officer, she faced increased hostility from Dr. Reif. In 2018, after a dispute over compensatory time and subsequent reprimand, she formally complained about a hostile work environment. NSU then began characterizing her time report as falsified and eventually terminated her employment, citing poor job performance and improper timekeeping.The United States District Court for the Eastern District of Oklahoma granted summary judgment in favor of NSU and Dr. Reif on Dixon's claims of Title VII sex and race discrimination, Title VII retaliation, and FMLA retaliation. The court found that Dixon failed to establish a prima facie case of discrimination or retaliation and could not show that NSU's reasons for her termination were pretextual. The court also concluded that Dr. Reif was not Dixon's employer under the FMLA.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court reversed the district court's summary judgment on Dixon's Title VII sex and race discrimination claims and her Title VII retaliation claim, finding that she had established a prima facie case and presented sufficient evidence of pretext. However, the court affirmed the summary judgment in favor of Dr. Reif on the FMLA retaliation claim, agreeing with the lower court's application of the economic reality test to determine that Dr. Reif was not Dixon's employer under the FMLA. View "Dixon v. Regional University System of the Oklahoma Board" on Justia Law

Carmen Wannamaker-Amos, a Black woman, worked in quality management at Purem Novi, Inc. for over thirty years. Despite receiving positive reviews from her supervisors, she faced negative treatment from Javad Hosseini, Purem’s chief quality executive. Hosseini repeatedly urged her supervisors to fire her, and in January 2020, after a problem with an automobile part, he requested her termination. Purem terminated her two days later. Wannamaker-Amos sued Purem, alleging racial and sex discrimination under Title VII of the Civil Rights Act of 1964 and the Civil Rights Act of 1866.The United States District Court for the District of South Carolina granted summary judgment to Purem, ruling that Wannamaker-Amos failed to produce sufficient evidence that the nondiscriminatory reason given for her firing was pretextual. The court found that she did not meet her employer’s legitimate expectations at the time of her termination.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that numerous issues of material fact were in dispute. The court found that Wannamaker-Amos provided ample evidence to dispute Purem’s claims about her performance and that Hosseini’s criticisms were baseless. The court also noted that Purem’s shifting reasons for her termination and failure to follow its own disciplinary policies could indicate pretext for discrimination. The court emphasized that it is the role of the jury to decide which party’s evidence is more persuasive.The Fourth Circuit vacated the district court’s grant of summary judgment and remanded the case for further proceedings, allowing a jury to determine whether Wannamaker-Amos was subjected to intentional discrimination. View "Wannamaker-Amos v. Purem Novi, Inc." on Justia Law

Respondents John Arvanites and Jonathon Burdette, both peace officers employed by the City of Las Vegas, were involved in a disciplinary investigation. A City employee lodged a complaint against Arvanites, and Burdette was notified as a witness. The City referred the complaint to its Human Resources Department, and a human resources analyst conducted the interviews. Respondents, including the Las Vegas Police Protective Association, sought declaratory and injunctive relief, arguing that NRS 289.060 required a ranked peace officer to conduct such investigations.The Eighth Judicial District Court of Clark County granted summary judgment in favor of the respondents. The court determined that the City violated the Nevada Peace Officer's Bill of Rights (POBR) by allowing a human resources employee to lead the investigation. The court declared that the City must ensure a peace officer conducts any interrogation or hearing in connection with such investigations and enjoined the City from using non-peace officers for these tasks.The Supreme Court of Nevada reviewed the case and affirmed the district court's decision. The court held that NRS 289.060(2)(d) requires a ranked peace officer to lead any investigation that could result in punitive action against another peace officer. The court found that the term "officer" in the statute refers to a peace officer, based on legislative history, statutory context, and public policy considerations. The court concluded that the City violated the statute by having a human resources employee lead the investigation and upheld the district court's order granting summary judgment for declaratory and injunctive relief. View "CITY OF LAS VEGAS VS. LAS VEGAS POLICE PROTECTIVE ASS'N." on Justia Law

Kristen M. Barnett, a former registered nurse at INOVA Health Care Services, refused to receive the COVID-19 vaccine due to her religious beliefs. INOVA had a policy requiring vaccination unless an exemption was granted. Barnett initially received a medical exemption but later requested a religious exemption, which was denied. She was subsequently placed on administrative leave and then discharged for noncompliance. Barnett filed a lawsuit against INOVA, alleging religious discrimination under Title VII and the Virginia Human Rights Act (VHRA).The United States District Court for the Eastern District of Virginia granted INOVA's motion to dismiss Barnett's complaint in its entirety. The court found that Barnett failed to state a claim for reasonable accommodation under Title VII because her objection did not raise issues related to abortion or fetal cells. The court also dismissed her disparate treatment claims under Title VII and the VHRA, finding them duplicative and lacking a comparator.The United States Court of Appeals for the Fourth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Barnett had sufficiently alleged religious discrimination for all three claims at the motion to dismiss stage. The court found that Barnett's allegations demonstrated her sincere religious beliefs and that her refusal to receive the vaccine was religious in nature. The court also found that Barnett's allegations supported a reasonable inference of discriminatory intent by INOVA.The Fourth Circuit reversed the district court's dismissal and remanded the case for further proceedings, allowing Barnett's claims to proceed. View "Barnett v. INOVA Health Care Services" on Justia Law

Plaintiff-appellant Kimberly A. Ripoli, a decorated veteran, claimed she experienced gender-based discrimination when terminated from her role as Associate Director of the Rhode Island Office of Veterans Affairs (OVA). She sued the State of Rhode Island, Department of Human Services, Office of Veterans Affairs under Title VII of the Civil Rights Act of 1964 and various Rhode Island statutes. The district court granted summary judgment in favor of the State on all claims.The United States District Court for the District of Rhode Island granted summary judgment for the State, dismissing Ripoli's claims of gender-based discrimination, retaliation, and hostile work environment. Ripoli did not address the district court's adverse rulings on her retaliation or hostile work environment claims in her appeal, leaving those rulings intact.The United States Court of Appeals for the First Circuit reviewed the case. The court vacated the district court's order on Ripoli's disparate treatment claims, finding that she had established a prima facie case of discrimination and raised genuine issues of material fact regarding whether the State's reasons for her termination were pretextual. The court noted that Ripoli presented evidence suggesting her role was not redundant, that the reorganization was not driven by budgetary constraints, and that she was replaced by a less-qualified heterosexual male. The court affirmed the district court's summary judgment on Ripoli's retaliation and hostile work environment claims, as she did not pursue these on appeal. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Ripoli v. Rhode Island Department of Human Services" on Justia Law

Dr. Tara Gustilo, an Asian American obstetrician-gynecologist of Filipino descent, was demoted from her position as Chair of the OBGYN Department at Hennepin Healthcare System, Inc. (HHS) in April 2021. Following her demotion, she filed charges with the Equal Employment Opportunity Commission (EEOC) and subsequently sued HHS, alleging race discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA), as well as a First Amendment retaliation claim under 42 U.S.C. § 1983.The United States District Court for the District of Minnesota granted summary judgment in favor of HHS, finding no genuine dispute of material fact regarding the race discrimination, retaliation, and First Amendment claims. The court concluded that Dr. Gustilo failed to establish a prima facie case of race discrimination and that there was no evidence she opposed an unlawful employment practice. Additionally, the court found no material fact dispute regarding whether the HHS Board considered her Facebook posts in its decision to demote her.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court reversed the district court's grant of summary judgment on the First Amendment retaliation claim, finding that there was a material fact dispute regarding whether the HHS Board ratified the MEC's decision and the basis for it, which included consideration of Dr. Gustilo's Facebook posts. The court remanded the case for further proceedings to determine if the posts were protected speech and to apply the Pickering balancing test.The court declined to review the district court's summary judgment rulings on the Title VII and MHRA claims at this time, as they are now interlocutory. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Gustilo v. Hennepin Healthcare System, Inc." on Justia Law

Plaintiffs Antonio Juarez, Jose Hinojosa, Jose Espinosa, and Maria Morfin filed a lawsuit against the San Bernardino City Unified School District following an incident involving Officer Alejandro Brown, a District employee. In February 2018, Juarez found a cell phone and later, Officer Brown, tracking his phone, confronted the plaintiffs, identifying himself as a District police officer. Brown, armed and displaying his badge, demanded compliance, struck Juarez with his firearm, and threatened the others. Brown later pled guilty to assault and battery and threatening the plaintiffs under color of law.The Superior Court of Riverside County sustained the District’s demurrer to the plaintiffs’ second amended complaint without leave to amend, leading to the dismissal of the case. The court found the complaint insufficient to establish that Officer Brown was acting within the scope of his employment with the District and dismissed the claims of negligence, battery, assault, negligent hiring, supervision, and retention, false arrest and imprisonment, intentional and negligent infliction of emotional distress, and violation of the Bane Act.The Court of Appeal, Fourth Appellate District, Division One, State of California, reversed and remanded the case. The appellate court held that the scope of employment is a factual issue that cannot be resolved as a matter of law on demurrer. The court found that Officer Brown’s off-duty misconduct, while investigating a suspected theft and wielding his authority as a peace officer, could be regarded as an outgrowth of his employment. The court directed the trial court to vacate its order sustaining the demurrer, enter a new order overruling the demurrer, and conduct further proceedings. The appellate court also rejected the District’s arguments regarding the Bane Act and found the plaintiffs’ allegations sufficient to state a cause of action for negligent hiring, supervision, and retention. View "Juarez v. San Bernardino City Unified Sch. Dist." on Justia Law

Ngozi Iweha, a Black woman born and educated in Nigeria, was hired as a staff pharmacist at Larned State Hospital (LSH) in Kansas. She alleged that she faced a hostile work environment, disparate treatment, and retaliation in violation of Title VII. Incidents included exclusion from projects, insensitive comments about Nigeria, and a confrontation with a coworker involving "slave trade beads." She was eventually placed on administrative leave and terminated following an investigation into her workplace conduct.The United States District Court for the District of Kansas granted summary judgment in favor of the defendants. The court found that the incidents described by Iweha did not amount to a hostile work environment as they were not sufficiently severe or pervasive. The court also determined that Iweha failed to show that her termination was pretextual. The court noted that the employer's progressive discipline policy was discretionary and that the investigation into Iweha's conduct was independent and thorough. Additionally, the court found that Iweha did not establish a prima facie case of retaliation, as her complaints did not specifically allege discrimination based on race or national origin.The United States Court of Appeals for the Tenth Circuit affirmed the district court's judgment. The appellate court agreed that the incidents described by Iweha were not severe or pervasive enough to create a hostile work environment. The court also found that Iweha failed to demonstrate that the reasons for her termination were pretextual. The court noted that the investigation into her conduct was independent and that the decision to terminate her was based on legitimate, non-discriminatory reasons. The court also upheld the finding that Iweha did not establish a prima facie case of retaliation. View "Iweha v. State of Kansas" on Justia Law