Justia Civil Rights Opinion Summaries

A custodian for a city police department sued the city and some of its employees, claiming she experienced sexual harassment and retaliation in violation of the Iowa Civil Rights Act (ICRA). The custodian alleged that a deputy chief made her uncomfortable with his behavior and comments, and that after she reported this, she faced retaliation from her administrative manager, who threatened her and her coworkers.The Iowa District Court for Linn County denied the defendants' motions for summary judgment on the custodian's claims of sexual harassment and retaliation, except for the claim of constructive discharge. The defendants then sought interlocutory review.The Iowa Supreme Court reviewed the case and found that the alleged harassment by the deputy chief was not sufficiently severe or pervasive to support an ICRA claim. The court also determined that the alleged acts of retaliation by the administrative manager did not amount to a materially adverse action as required for an ICRA claim. Consequently, the court reversed the district court's decision and remanded the case for dismissal of the custodian's claims. View "Rheeder v. Gray" on Justia Law

Martin Misjuns, a Fire Captain and paramedic with the Lynchburg Fire Department, was terminated after posting offensive social media content targeting transgender individuals. Misjuns alleged that his termination was due to his political and religious views, which he expressed on his Facebook pages. He claimed that the City of Lynchburg and its officials conspired to violate his constitutional rights, leading to his firing.The United States District Court for the Western District of Virginia dismissed all of Misjuns' claims. The court found that the claims against the individual defendants in their official capacities were duplicative and dismissed them. The court also dismissed Misjuns' breach of contract, equal protection, conspiracy, and wrongful termination claims. The court partially dismissed his First Amendment claims but later dismissed them entirely.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal of Misjuns' claims. The court held that Misjuns failed to establish Monell liability against the City of Lynchburg, as he did not adequately plead that a policy or custom caused the alleged constitutional violations. The court also found that the City's Employment Policies & Procedures handbook did not constitute a binding contract, thus dismissing the breach of contract claim. Additionally, the court upheld the dismissal of the conspiracy and wrongful termination claims against the individual defendants, as those claims were not asserted against the City and had been dismissed by agreement.The Fourth Circuit concluded that Misjuns did not sufficiently plead facts to state a claim for relief on any of his six claims, affirming the district court's decision. View "Misjuns v. City of Lynchburg" on Justia Law

Marlean Ames, a heterosexual woman, worked for the Ohio Department of Youth Services since 2004. In 2019, she applied for a management position but was passed over in favor of a lesbian woman. Subsequently, Ames was demoted from her role as a program administrator, and a gay man was hired to fill her previous position. Ames filed a lawsuit under Title VII, alleging discrimination based on her sexual orientation.The District Court granted summary judgment to the agency, applying the McDonnell Douglas framework for evaluating disparate-treatment claims. The court held that Ames failed to make a prima facie case of discrimination because she did not show "background circumstances" suggesting the agency discriminated against majority-group members. The Sixth Circuit affirmed, requiring Ames to meet this additional burden as a straight woman.The Supreme Court of the United States reviewed the case. The Court held that the Sixth Circuit's "background circumstances" rule, which imposes a heightened evidentiary standard on majority-group plaintiffs, is inconsistent with Title VII's text and precedents. Title VII prohibits discrimination against any individual based on protected characteristics without distinguishing between majority and minority groups. The Court vacated the judgment and remanded the case for application of the proper prima facie standard under Title VII. View "Ames v. Ohio Department of Youth Services" on Justia Law

Petra Brokken sued her employer, Hennepin County, alleging religious discrimination under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA), and wrongful discharge under Minnesota’s Refusal of Treatment statute. Brokken claimed that the County's Covid-19 vaccine and testing policy conflicted with her religious beliefs. After initially granting her a religious exemption, the County revised its policy, threatening termination and loss of accrued benefits if she did not comply. Brokken retired under duress and subsequently filed her lawsuit.The United States District Court for the District of Minnesota dismissed Brokken's claims. The court ruled that she failed to plead an adverse employment action, did not plausibly plead religious beliefs conflicting with the County’s policy, and that the MHRA does not provide a cause of action for failure to accommodate religious beliefs. Additionally, the court found that Minnesota’s Refusal of Treatment statute does not create a private right of action.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s dismissal of the wrongful discharge claim under Minnesota’s Refusal of Treatment statute, agreeing that it does not create a private right of action. However, the court reversed the dismissal of Brokken’s Title VII and MHRA claims. The appellate court held that Brokken plausibly pled an adverse employment action and sufficiently alleged that her religious beliefs conflicted with the County’s policy. The court also recognized that the MHRA provides protection against failures to accommodate religious beliefs. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Brokken v. Hennepin County" on Justia Law

Alexander Smith, a Christian firefighter in Atlantic City, was prohibited from growing a beard due to the city's grooming policy, which he claimed violated his religious beliefs. Smith sued the city, alleging violations of the Free Exercise Clause, the Equal Protection Clause, and Title VII’s accommodation and anti-retaliation provisions. The District Court denied his motion for a preliminary injunction and later granted summary judgment for the city on all claims.The United States District Court for the District of New Jersey initially denied Smith's motion for a preliminary injunction, finding that his claims were unlikely to succeed on the merits. After discovery, the court granted summary judgment in favor of the city on all four claims, leading Smith to appeal the decision.The United States Court of Appeals for the Third Circuit reviewed the case. The court vacated the District Court’s judgment regarding Smith’s Title VII accommodation claim and his free exercise claim, finding that the city's grooming policy was not generally applicable and failed strict scrutiny. The court affirmed the District Court’s judgment on the equal protection claim and the Title VII retaliation claim, concluding that Smith did not establish a prima facie case of retaliation. Additionally, the court reversed the denial of Smith’s motion for a preliminary injunction, recognizing a likelihood of success on the merits and the irreparable harm caused by the loss of First Amendment freedoms. View "Smith v. City of Atlantic City" on Justia Law

A private fencing coach alleged that during a flight, a university’s assistant fencing coach sexually harassed and assaulted her. She reported the incident to the university’s head coach, who discouraged her from reporting it further and, along with the assistant coach, allegedly retaliated against her within the fencing community. The university later investigated and confirmed the harassment but found no policy violation. The coach sued the university, the two coaches, and the Title IX coordinator, claiming violations of Title IX and state-law torts.The United States District Court for the Middle District of North Carolina transferred the case to the Middle District of Pennsylvania due to improper venue and judicial efficiency. After the transfer, the plaintiff amended her complaint, and the defendants moved to dismiss. The transferee court dismissed the entire suit, holding that the plaintiff, as neither a student nor an employee, was outside the zone of interests protected by Title IX. It also dismissed the state-law tort claims as untimely or implausible.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the zone-of-interests test applies to Title IX claims and that the plaintiff’s claims related to her exclusion from university-hosted fencing events and retaliation manifesting on campus were within that zone. The court affirmed the dismissal of the state-law tort claims against the university and its employees, except for the claims against the assistant coach, which were not time-barred under North Carolina’s three-year statute of limitations. The case was vacated in part, affirmed in part, and remanded for further proceedings. View "Oldham v. Penn State University" on Justia Law

Cheryl Butler was hired as an assistant law professor at Southern Methodist University (SMU) in 2011. After a mandatory third-year performance review, her contract was renewed, and she became eligible for tenure consideration in the fall semester of 2015. Due to illness, Butler requested an extension of the tenure vote, which was denied, but she was later granted leave under the Family Medical Leave Act (FMLA) for the spring semester of 2016. Her tenure committee, chaired by Professor Roy Anderson, concluded that Butler met tenure standards for scholarship and service but not teaching. Consequently, the law faculty voted not to recommend tenure, and Butler's appeals to the SMU Law School Dean and the Provost were unsuccessful. Butler completed the 2016-2017 academic year without teaching any classes.Butler filed a lawsuit against SMU and several of its employees, alleging racially discriminatory tenure standards and processes, and retaliation for her internal complaints about race, disability, and FMLA discrimination. She brought federal statutory claims under 42 U.S.C. § 1981, Title VII of the Civil Rights Act of 1964, the Rehabilitation Act of 1973, the Americans with Disabilities Act, Title IX, and the FMLA. Additionally, she asserted state-law discrimination and retaliation claims under Texas Labor Code Chapter 21, along with state common law claims for breach of contract and negligent supervision. Against the employee defendants, she claimed defamation, conspiracy to defame, and fraud.The United States District Court for the Northern District of Texas dismissed Butler's defamation and fraud claims against the employee defendants, citing preemption by Chapter 21 of the Texas Labor Code. The court held that the gravamen of these claims was unlawful employment discrimination and retaliation, which Chapter 21 specifically addresses. Butler appealed, and the United States Court of Appeals for the Fifth Circuit certified a question to the Supreme Court of Texas regarding whether Chapter 21 preempts common law defamation and fraud claims against employees based on the same conduct as discrimination claims against the employer.The Supreme Court of Texas held that Chapter 21 does not preempt common law defamation and fraud claims against employees. The court reasoned that Chapter 21 subjects only employers to liability for discriminatory and retaliatory conduct and does not immunize individuals from liability for their own tortious actions. Therefore, Butler's defamation and fraud claims against the employee defendants are not foreclosed by Chapter 21. View "BUTLER v. COLLINS" on Justia Law

In August 2021, the Cook County Health and Hospitals System implemented a policy requiring all personnel to be fully vaccinated against infectious diseases, including COVID-19. Exemptions were allowed for disability, medical conditions, or sincerely held religious beliefs. Plaintiffs, who are healthcare employees or contractors, requested religious exemptions, which were granted. However, the accommodation provided was a transfer to unpaid status pending termination, with a limited time to find a non-existent remote position. Plaintiffs argued this was religious discrimination violating the Free Exercise Clause of the First Amendment.The United States District Court for the Northern District of Illinois previously denied plaintiffs' motions for preliminary injunctions against the vaccine mandates, including Cook County’s. The Seventh Circuit affirmed this denial, rejecting the plaintiffs' facial challenge to the mandate. On remand, plaintiffs amended their complaint but were denied permission to add a claim under the Illinois Religious Freedom Restoration Act until after the court ruled on the County’s motion to dismiss. The district court dismissed the second amended complaint, considering it a facial challenge, which had already been ruled upon.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the plaintiffs waived their as-applied challenge by not raising it in the district court or their opening brief on appeal. The court also noted that plaintiffs conceded they no longer sought injunctive relief and did not pursue a facial challenge. Consequently, the court affirmed the district court’s dismissal of the constitutional claim. Additionally, the court found no abuse of discretion in the district court’s denial of leave to amend the complaint to include the Illinois RFRA claim. The court criticized the plaintiffs' counsel for poor advocacy and procedural errors. View "Lukaszczyk v Cook County" on Justia Law

Alisha Strife, a former U.S. Army service member with disabilities, requested that her employer, Aldine Independent School District (AISD), allow her service dog to accompany her at work. Strife's disabilities include PTSD and physical impairments, and her service dog, Inde, assists her with these conditions. Strife submitted her accommodation request on August 30, 2022, but AISD took six months to approve it, during which time Strife provided multiple medical documents supporting her need for the service dog.The United States District Court for the Southern District of Texas dismissed Strife's claims for failure to accommodate and hostile work environment. The court also granted AISD's motion for summary judgment on Strife's claims of disability discrimination, retaliation, and interference. The district court found that Strife did not suffer a physical injury during the six-month period and that she failed to allege a hostile work environment. The court also concluded that AISD had legitimate reasons for its actions and that Strife did not demonstrate that AISD's rationale was pretextual.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's dismissal of the hostile work environment claim, agreeing that Strife's allegations did not meet the standard for a hostile work environment. The court also affirmed the summary judgment on the disability discrimination, retaliation, and interference claims, finding that AISD had legitimate reasons for its actions and that Strife did not provide sufficient evidence of pretext.However, the Fifth Circuit reversed the dismissal of Strife's failure-to-accommodate claim. The court found that Strife had pled sufficient facts to suggest that AISD's six-month delay in granting her accommodation request could constitute a failure to accommodate her disability. The case was remanded to the district court for further proceedings on this claim. View "Strife v. Aldine Independent School District" on Justia Law

Lisa Barnhill, a white woman, sued the U.S. Attorney General, alleging racial and gender discrimination, retaliation, and a hostile work environment under Title VII of the Civil Rights Act of 1964. Barnhill claimed she faced discrimination from her African American supervisor and others while employed by the DEA. Some of her claims were dismissed under Fed. R. Civ. P. 12(b)(6), and others were resolved on summary judgment under Fed. R. Civ. P. 56(a).The United States District Court for the Eastern District of Virginia dismissed Barnhill's race and gender discrimination claims, finding she failed to allege facts showing discriminatory animus. The court also dismissed her retaliation claims related to promotion denials and a five-day suspension, concluding she did not plausibly allege a connection between her EEO proceeding and these adverse actions. However, the court allowed her retaliation claims related to a management review and temporary duty reassignment, as well as her hostile work environment claim, to proceed.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Barnhill's discrimination claims, agreeing she did not plausibly allege discriminatory animus. The court also affirmed the dismissal of her retaliation claims related to promotion denials and the suspension, finding no causal connection to her EEO proceeding. On summary judgment, the court found that the management review was initiated by a supervisor without discriminatory animus and that the temporary duty reassignment was justified by legitimate, nonretaliatory reasons. The court also concluded that Barnhill's hostile work environment claim failed because the adverse actions she experienced were responses to her own behavior, not severe or pervasive harassment.The Fourth Circuit affirmed the district court's decision, holding that Barnhill failed to establish the necessary elements for her claims. View "Barnhill v. Bondi" on Justia Law