Justia Civil Rights Opinion Summaries

MaChelle Joseph, a former head women’s basketball coach at Georgia Tech, and Thomas Crowther, a former art professor at Augusta University, filed separate complaints alleging sex discrimination and retaliation under Title IX and other laws. Joseph claimed that Georgia Tech provided fewer resources to the women’s basketball team compared to the men’s team and retaliated against her for raising these issues. Crowther alleged that he was retaliated against after being accused of sexual harassment and participating in the investigation.The United States District Court for the Northern District of Georgia dismissed Joseph’s Title IX claims, ruling that Title VII precluded them, and granted summary judgment against her remaining claims. For Crowther, the district court denied the motion to dismiss his Title IX claims, allowing them to proceed.The United States Court of Appeals for the Eleventh Circuit reviewed these consolidated appeals. The court held that Title IX does not provide an implied right of action for sex discrimination in employment, reversing the district court’s decision to allow Crowther’s Title IX claims and affirming the dismissal of Joseph’s Title IX claims. The court also ruled that Crowther’s retaliation claim under Title IX, based on his participation in the investigation, did not state a valid claim. Additionally, the court found that Joseph’s claims of sex discrimination under Title VII, based on her association with the women’s team, were not viable. Finally, the court affirmed the summary judgment against Joseph’s retaliation claims under Title VII, Title IX, and the Georgia Whistleblower Act, concluding that she failed to show that the reasons for her termination were pretextual. View "Joseph v. Board of Regents of the University System of Georgia" on Justia Law

Jeannine Bedard, a Los Angeles Police Department (LAPD) officer, refused to comply with the City of Los Angeles’s COVID-19 vaccination mandate and did not sign a notice enforcing the mandate. Consequently, the Chief of Police sought to terminate her employment. The LAPD Board of Rights reviewed the proposed discipline, found Bedard guilty of failing to comply with conditions of employment, and upheld her discharge. The Board also found that the City violated Bedard’s due process rights by not providing sufficient time to respond to the charges and awarded her back pay, which the City did not pay.Bedard filed a petition for a writ of mandate in the Superior Court of Los Angeles County, arguing that the disciplinary action was procedurally and legally invalid and seeking reinstatement and back pay. The trial court found the termination justified but agreed that the City violated Bedard’s due process rights by giving her insufficient time to respond. The court awarded her back pay.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. Bedard argued that her termination was improper because it was based on her refusal to sign an allegedly illegal contract, was too harsh a penalty, and violated her due process rights under Skelly v. State Personnel Board. The appellate court affirmed the trial court’s decision, holding that Bedard’s refusal to comply with the vaccination mandate justified her termination. The court found substantial evidence supporting the trial court’s conclusion that Bedard’s termination was not solely based on her refusal to sign the notice but also on her refusal to comply with the vaccination requirement. The court also held that the appropriate remedy for the due process violation was back pay, not reinstatement. View "Bedard v. City of Los Angeles" on Justia Law

Several contractors and an employee, who regularly handle public works projects for PennDOT and SEPTA, challenged Philadelphia's requirement for project labor agreements (PLAs) on public projects. These PLAs mandated union recognition and membership, and set workforce diversity goals. The plaintiffs argued that these requirements violated their First Amendment rights and the Equal Protection Clause, as well as 42 U.S.C. § 1981. They were ineligible to bid on certain city projects due to their existing collective bargaining agreements with the United Steelworkers, which is not affiliated with the required unions.The United States District Court for the Eastern District of Pennsylvania granted summary judgment to Philadelphia. The court found that the plaintiffs lacked standing to challenge the union-eligibility requirement and failed to show that the diversity requirement caused them harm based on race. The court also concluded that the plaintiffs' § 1981 claim failed because race was not a but-for cause of their inability to work on city projects with PLAs.The United States Court of Appeals for the Third Circuit reviewed the case and found that the plaintiffs had standing to challenge the union-eligibility requirement under the First Amendment. The court determined that the plaintiffs suffered a concrete and particularized injury by being ineligible to bid on city projects due to the PLAs. The court also found that the plaintiffs' claims were not moot despite Philadelphia's subsequent changes to the PLAs, as the plaintiffs sought damages for past violations and prospective relief.The Third Circuit also found that the plaintiffs had standing to raise an Equal Protection claim, as they demonstrated an intent to bid on future projects covered by the PLAs. The court vacated the District Court's judgment and remanded the case for further proceedings to consider the merits of the plaintiffs' First Amendment, Equal Protection Clause, and § 1981 claims. View "Road-Con Inc v. City of Philadelphia" on Justia Law

In January 2015, Sarah Schoper, a tenure-track assistant professor at Western Illinois University, suffered a traumatic brain injury resulting in high-functioning mild aphasia and other physical disabilities. Despite her condition, she returned to teaching in May 2015, with accommodations from the University. Schoper applied for tenure in 2017 but was denied based on her teaching evaluations, which had declined post-injury. She then filed a lawsuit alleging disability discrimination and failure to accommodate under the Americans with Disabilities Act.The United States District Court for the Central District of Illinois granted summary judgment in favor of the University. The court found that Schoper could not prove that her disability was the but-for cause of her negative tenure recommendation. Additionally, the court ruled that Schoper failed to show how her requested accommodation—additional time to meet tenure criteria—would enable her to perform the essential functions of her job.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that Schoper was not a qualified individual under the ADA because her teaching evaluations did not meet the University's tenure requirements. The court also found that her request for more time to achieve tenure was not a reasonable accommodation, as it essentially sought a second chance rather than a modification to enable her to perform her job. Furthermore, the court concluded that no reasonable jury could find that Schoper's disability was the but-for cause of the University's decision to deny her tenure, given the multiple layers of review and the lack of evidence showing discriminatory intent by the reviewers. View "Schoper v. Board of Trustees of Western Illinois University" on Justia Law

The plaintiff, Laurie DeVore, worked at the University of Kentucky from 1999 to 2022. She retired rather than comply with the University's COVID-19 test-or-vaccinate policy, which she claimed conflicted with her religious beliefs. DeVore filed a lawsuit alleging that the University violated Title VII of the Civil Rights Act of 1964 by failing to accommodate her religious beliefs. The University had denied her requests for a hybrid work schedule and religious exemptions from the testing policy, which required unvaccinated employees to undergo weekly COVID-19 testing.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the University. The court found that DeVore did not establish a prima facie case of religious discrimination because she failed to demonstrate that the University's policy conflicted with her sincerely held religious beliefs. DeVore appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court examined whether DeVore had a sincere religious belief that conflicted with the University's testing policy. DeVore's objections to the nasal PCR tests were initially based on invasiveness, manipulation, and coercion. However, the University offered alternative testing methods, such as oral swab and saliva tests, which DeVore also rejected without providing evidence of a religious conflict with these alternatives.The Sixth Circuit affirmed the district court's decision, holding that DeVore failed to establish a conflict between her religious beliefs and the University's testing policy. The court noted that DeVore's objections were largely based on personal moral codes and secular concerns rather than religious principles. Consequently, DeVore's Title VII claim did not succeed. View "DeVore v. University of Kentucky Board of Trustees" on Justia Law

Estella Morris, an employee of the Central Arkansas Veterans Healthcare System (CAVHS), filed civil-rights claims against her employer, alleging racial discrimination and retaliation. Morris, who is black, claimed she was denied a promotion to Chief of Social Work Service in favor of a white colleague, Anne Wright, despite having veteran preference. Morris also alleged that her pay upgrade request was sabotaged by her supervisor, Michael Ballard, in retaliation for her previous discrimination complaints.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of CAVHS. The court found that Morris had established a prima facie case of race discrimination but concluded that CAVHS had provided a legitimate, nondiscriminatory reason for promoting Wright—her more favorable references. The court held that Morris failed to show that this reason was a pretext for racial discrimination. Regarding the retaliation claim, the court found no evidence that Ballard's actions were causally linked to Morris's protected activities or that the person who denied the pay upgrade was aware of her discrimination complaints.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision de novo. The appellate court affirmed the summary judgment, agreeing that Morris did not demonstrate a causal connection between her race and the promotion decision. The court also found that Morris failed to show that Ballard's alleged sabotage of her pay upgrade request was linked to her protected activities. The court concluded that no reasonable jury could find that CAVHS's actions were motivated by racial discrimination or retaliation. View "Morris v. Department of Veterans Affairs" on Justia Law

Three black officers, Cedric Green, Darrell Clark, and Reginald Cooper, alleged a history of racial discrimination within the Alexandria Police Department (APD). They claimed that over their decades-long careers, they faced systemic racism, including derogatory comments and unfair treatment. Clark and Cooper were eventually terminated, and Green was demoted. They argued that these actions were retaliatory, following their complaints to HR and the FBI about racial harassment and misconduct within the department.The United States District Court for the Western District of Louisiana granted summary judgment in favor of the City of Alexandria and other defendants. The court found that the plaintiffs failed to present competent evidence to support their claims. Specifically, the court noted that the plaintiffs' reliance on their complaint and unsubstantiated assertions did not meet the evidentiary standards required to survive summary judgment. The court also found that the city provided legitimate, non-retaliatory reasons for the adverse employment actions taken against the plaintiffs.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court agreed that the plaintiffs did not provide sufficient evidence to establish a hostile work environment, as the incidents cited were either not racially motivated or not severe and pervasive enough. The court also found no causal connection between the plaintiffs' protected activities (complaints to HR and the FBI) and the adverse employment actions. Additionally, the court held that the city had legitimate reasons for the terminations and demotion, which the plaintiffs failed to show were pretextual. The court also dismissed the plaintiffs' claims under Louisiana's whistleblower statute and their Monell claims against the city, citing a lack of evidence of a discriminatory policy or custom. View "Clark v. City of Alexandria" on Justia Law

The plaintiffs, all State troopers, filed a lawsuit against the Commonwealth and the heads of the State Police and the State Board of Retirement. They claimed that the defendants' policy of denying the accrual of benefits, such as seniority, length-of-service credit, and vacation and sick time while on leave under the Paid Family and Medical Leave Act (PFMLA), violated the act. Additionally, they argued that the policy discriminated against female employees in violation of other state laws.A Superior Court judge dismissed the portion of the complaint alleging violations of the PFMLA. The judge concluded that the act does not guarantee the accrual of benefits during PFMLA leave. The plaintiffs then sought clarification on the interpretation of the act, and the case was reported to the Appeals Court. The Supreme Judicial Court of Massachusetts transferred the case to itself for review.The Supreme Judicial Court of Massachusetts held that the PFMLA does not require employers to guarantee the accrual of vacation and sick time during an employee's leave. The court interpreted the plain language of the statute, particularly sections 2(e) and 2(f), and concluded that while employees must be restored to their previous position with the same status and benefits upon returning from leave, the act does not mandate the continued accrual of benefits during the leave period. The court affirmed the lower court's dismissal of the PFMLA claims and remanded the case for further proceedings consistent with its opinion. View "Bodge v. Commonwealth" on Justia Law

Rene Galvan, a former employee of the Indiana Department of Child Services (DCS), filed a lawsuit against the State of Indiana and his former supervisor, Joanie Crum, alleging race and sex discrimination, retaliation, and a violation of his Fourteenth Amendment right to due process. Galvan, a large Mexican male, claimed he was terminated based on his race and sex and retaliated against for his complaints of discrimination. He also alleged that Crum deprived him of his property rights without due process. The district court granted summary judgment in favor of the defendants, and Galvan appealed.The United States District Court for the Southern District of Indiana granted summary judgment to the defendants, finding no evidence that Galvan’s termination was based on race or sex discrimination. The court noted that Galvan’s performance issues, including his judgment regarding child safety and professional demeanor, were well-documented. The court also found no causal connection between Galvan’s complaints of discrimination and his termination, dismissing his retaliation claim. Additionally, the court held that Galvan received adequate due process before his termination, as he was given notice of the charges and an opportunity to respond.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court agreed that Galvan failed to provide sufficient evidence to support his claims of discrimination and retaliation. The court also found that the pre-termination procedures provided to Galvan met the requirements of due process, as he was given notice of the charges and an opportunity to respond. The court concluded that the district court properly granted summary judgment in favor of the defendants. View "Galvan v. State of Indiana" on Justia Law

Corey McNellis, a former Athletic Director and Assistant Principal at Ponderosa High School in the Douglas County School District (DCSD), was placed on administrative leave and subsequently terminated after expressing reservations about a school play, "The Laramie Project," in a staff email chain. McNellis offered to add a "Christian perspective" to the production, which led to his investigation and termination.McNellis sued DCSD in the United States District Court for the District of Colorado, alleging First Amendment retaliation under 42 U.S.C. § 1983, and religious discrimination and retaliation under Title VII and Colorado law. The district court dismissed the case under Federal Rule of Civil Procedure 12(b)(6), finding that McNellis failed to state a plausible claim for relief.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the dismissal of McNellis's First Amendment retaliation claim, concluding that his speech was made pursuant to his official duties and not as a private citizen. The court also affirmed the dismissal of his retaliation claims under Title VII and CADA, finding that McNellis failed to plausibly allege a causal connection between his complaints about the investigation and his termination.However, the Tenth Circuit reversed the dismissal of McNellis's discrimination claims under Title VII and CADA. The court found that McNellis had plausibly alleged that his termination was linked to his religious comments, which could give rise to an inference of discrimination. The case was remanded for further proceedings on these claims. View "McNellis v. Douglas County School District" on Justia Law