Justia Civil Rights Opinion Summaries

In the case before the United States Court of Appeals for the Fourth Circuit, the plaintiff, Kristin Cosby, claimed that the South Carolina Probation, Parole & Pardon Services (SCPPP) had discriminated against her based on her gender and retaliated against her for filing discrimination complaints in violation of Title VII of the Civil Rights Act of 1964. Cosby had previously worked for SCPPP, left, and then reapplied in 2012. When she was not rehired, Cosby filed a discrimination charge with the Equal Employment Opportunity Commission (EEOC), which found in her favor. SCPPP rehired her, but Cosby alleged that she was subsequently subjected to gender discrimination and retaliation, including being denied a promotion, being investigated for inappropriate relationships with subordinates, and ultimately forced to resign.The court affirmed the district court's granting of summary judgment to SCPPP. The court held that Cosby had failed to establish her gender discrimination claim under both the disparate treatment and hostile work environment theories. For the disparate treatment claim, Cosby failed to identify a valid comparator — a similarly situated individual of a different gender who was treated more favorably. In her hostile work environment claim, Cosby's internal complaint did not constitute protected activity under Title VII because it did not oppose an unlawful employment practice. The court also found no causal connection between Cosby's 2012 EEOC charge and any adverse employment action taken by SCPPP in 2018, defeating her retaliation claim. View "Cosby v. South Carolina Probation, Parole & Pardon Services" on Justia Law

In this case, the plaintiff, an African-American male, brought an employment discrimination lawsuit against his former employer, Genzyme Therapeutic Products, LP, and one of its executives. The plaintiff alleged racial discrimination, harassment, and retaliation. The district court granted summary judgment in favor of the defendants, finding that the plaintiff failed to provide sufficient proof that the employer's stated rationale for certain adverse employment actions was pretextual. The court also found that the plaintiff did not provide enough evidence to demonstrate a causal connection between the alleged protected conduct (filing a complaint against another employee for racial discrimination) and the adverse action (a poor performance review).On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court held that the plaintiff failed to establish that there was a genuine issue of material fact as to whether the employer's proffered reason for the negative performance review was a pretext for discrimination. The court noted that the plaintiff's argument relied heavily on speculation and conjecture rather than definite and competent evidence. The court also highlighted that even if the plaintiff's direct manager thought he was deserving of a higher rating, this did not shed light on the executive's view, nor did it allow a reasonable juror to find that the executive's stated rationale was pretextual. The court concluded that a single racially tinged comment made by the executive was not sufficient to prove discriminatory intent. View "Boykin v. Genzyme Therapeutic Products, LP" on Justia Law

In this case heard by the United States Court of Appeals for the Seventh Circuit, the plaintiff, Alexis Wells, sought to hold her employer, The Freeman Company, liable for sexual assault committed by a fellow employee, Timothy Vaughn. Wells asserted that the company should be held responsible under Title VII, the Indiana Wage Payment Statute, and various tort theories. The court, however, affirmed the district court's ruling that Wells was an independent contractor, not an employee, which meant that Freeman's conduct was not tortious and Vaughn's actions could not be attributed to Freeman. The court applied the Knight factors, which analyze the "economic realities" of a work relationship, to determine whether a worker is an employee for purposes of Title VII. The court concluded that most of these factors pointed towards Wells being an independent contractor. Thus, her claims under Title VII and the Indiana Wage Payment Statute failed. The court also dismissed Wells' state law claims for Intentional Infliction of Emotional Distress (IIED) and Negligent Infliction of Emotional Distress (NIED), concluding that Freeman's pre-litigation conduct was not so outrageous as to be regarded as "atrocious," and that Vaughn's conduct was outside the scope of his employment, respectively. Therefore, the court could not hold Freeman vicariously liable for Vaughn's actions. View "Wells v. Freeman Company" on Justia Law

Jeffrey Bruno, a veteran firefighter with the Kankakee Fire Department, sued Mayor Chasity Wells-Armstrong, James Ellexson, the Human Resources Director for the City of Kankakee, and the City of Kankakee, alleging discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA). Bruno suffered a severe cardiac event in 2017 and upon his return to work was promoted to Deputy Chief. However, in 2019, he was denied a raise and presented with an employment contract that tied additional compensation to his enrollment in college courses. When Bruno requested the removal of this education condition, citing his heart condition as a barrier to attending classes, his request was denied. After signing the contract, Bruno retired and initiated legal proceedings.The United States Court of Appeals For the Seventh Circuit affirmed the district court's decision, which had granted summary judgment for the defendants. The court concluded that Bruno's request to remove the education condition was not a request for a reasonable accommodation under the ADA, as it would not impact his ability to perform his job. The court also rejected Bruno's claim of disparate treatment, as his argument of pretext was contradicted by the evidence. Bruno's ADA retaliation claim also failed because his identified protected activity was not protected under the ADA. As Bruno's IHRA and indemnification claims were dependent on his ADA claims, these too were rejected. View "Bruno v. Wells-Armstrong" on Justia Law

In the case before the United States Court of Appeals for the Fourth Circuit, Bikachi Amisi, a contract nurse, sued Officer Lakeyta Brooks and Officer Roy Townsend for violating her Fourth Amendment rights when she was mistakenly strip searched on her first day of work at Riverside Regional Jail. Amisi also brought several tort claims under Virginia state law. The defendants moved for summary judgment, arguing they were entitled to qualified immunity and good-faith immunity under Virginia law. They also argued that the Virginia Workers’ Compensation Act’s exclusivity provision barred Amisi's claims. The district court denied their motions and the defendants appealed.The Court of Appeals affirmed the district court's decision. It held that both officers were not entitled to qualified immunity, a legal protection that shields officers who commit constitutional violations but who could reasonably believe their actions were lawful, because their actions were not reasonable and Amisi’s right to be free from unreasonable strip searches was clearly established. The court also held that the Virginia Workers' Compensation Act did not bar Amisi's state-law claims because her injuries did not arise out of her employment. The Court further held that Officer Townsend was not entitled to immunity under Virginia law as his belief that his conduct was lawful was not objectively reasonable. View "Amisi v. Brooks" on Justia Law

In this case, Plaintiff Jennifer Akridge, a former employee of Alfa Mutual Insurance Company, appealed the entry of summary judgment in favor of Alfa on her claim under the Americans with Disabilities Act (ADA). Akridge had multiple sclerosis and severe migraines, and she alleged that the company wrongfully terminated her to avoid paying for her healthcare costs. Alfa argued that it eliminated her position because her duties were automated and no longer needed, and the company wanted to cut business expenses.The United States Court of Appeals for the Eleventh Circuit affirmed the summary judgment ruling. The court found that Akridge failed to establish a prima facie case of disability discrimination under the ADA. Even if she had, her evidence failed to show that Alfa’s reason for firing her (that her position was no longer needed and it wished to cut business expenses) was pretext for disability discrimination. The court also rejected Akridge's argument that she merely needs to show that her disability was a motivating factor, rather than a but-for cause, of her termination. The court clarified that, unlike Title VII, the ADA does not incorporate the motivating-factor causation standard, and an ADA plaintiff must show that a cause was outcome determinative. Therefore, it upheld the district court’s decision that Akridge did not produce sufficient evidence to suggest that her termination was a result of discrimination based on her disability.The court also affirmed the district court's award of $1,918 in discovery sanctions against Akridge. The lower court found that Akridge's motion to compel a certain deposition was not substantially justified, and the appeals court found no error or abuse of discretion in that ruling. View "Akridge v. Alfa Mutual Insurance Co." on Justia Law

In this case, the United States Court of Appeals for the Sixth Circuit was faced with the claims of Cameron Cooper, an employee with Tourette Syndrome, who sued his former employer, Coca-Cola Consolidated, Inc. (CCCI), under the Americans with Disabilities Act (ADA). Cooper's Tourette Syndrome caused him to involuntarily utter racist and profane words. He alleged that CCCI failed to provide him with reasonable accommodations and constructively discharged him by forcing him into an undesirable position.Cooper had been working as a delivery merchandiser for CCCI, a role which required excellent customer service. However, his condition led to complaints from customers due to his use of offensive language. CCCI attempted various accommodations, including having Cooper work alongside another employee and ultimately transferring him to a warehouse position with no customer contact. Cooper claimed that CCCI could have accommodated him by assigning him to a non-customer-facing delivery route.The court held that providing excellent customer service was an essential function of Cooper's job and, given his condition, he could not perform this function without an accommodation. The court further held that Cooper's proposed accommodation (assigning him to a non-customer-facing delivery route) was not objectively reasonable because the suggested delivery route did involve customer contact and there were no other non-customer-facing routes available at the time. Additionally, the court found that the warehouse position offered by CCCI was a reasonable accommodation under the ADA.As to the constructive discharge claim, the court held that Cooper failed to show that CCCI deliberately created intolerable working conditions with the intention of forcing him to quit. The court concluded that CCCI provided Cooper with reasonable accommodations each time he requested, thus, there was no evidence to support a constructive discharge claim.The court affirmed the lower court's decision to grant summary judgment in favor of CCCI. View "Cooper v. Dolgencorp, LLC" on Justia Law

The case involves Albert Collins, who was employed by the Kansas City Missouri Public School District. After the termination of his employment, Collins sued the school district, alleging racial discrimination and retaliation for participating in protected activities. The school district had fired Collins following an investigation into "attendance fraud," a scheme in which Collins admittedly took part. The three claims relevant in this case were racial discrimination during termination in violation of Title VII and 42 U.S.C. § 1983, retaliation for engaging in protected activities under Title VII and § 1983, and violation of a state law prohibiting public employers from retaliating against whistleblowers.The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision to grant summary judgment in favor of the school district. The court held that Collins failed to provide sufficient evidence for a reasonable jury to conclude that his termination was motivated by his race. He failed to demonstrate that a white employee engaged in the same fraudulent scheme was treated differently, failing to meet the "rigorous" requirement that the comparators must have dealt with the same supervisor, been subject to the same standards, and engaged in the same conduct.The court also found that Collins' retaliation claim failed for lack of evidence linking his termination to any protected conduct. His interviews about the attendance fraud scheme were not related to race, and he failed to demonstrate that another employee's claims, in which he acted as a witness, had anything to do with racial discrimination or retaliation.Regarding the whistleblower claim, the court held that a Missouri law excluding disclosures related to the employee's own violations applied to Collins. Since he failed to argue against the court's application of the statutory exclusion, his challenge to the court's grant of summary judgment on his whistleblower claim was deemed waived. View "Collins v. K.C. MO Public School District" on Justia Law

In a case before the United States Court of Appeals for the Third Circuit, a group of former union members alleged that their First Amendment rights were violated when their respective unions continued to deduct membership dues from their paychecks after they had resigned from the unions. The appellants had previously signed union membership applications authorizing the deduction of dues from their paychecks, with the authorizations being irrevocable for a year, regardless of membership status, unless the member provided written notice of revocation within a specified annual window. The appellants resigned from their respective unions after their annual revocation windows had passed, and the unions continued to deduct dues until the next annual revocation window. The appellants argued that the Supreme Court's decision in Janus v. American Federation of State, County, and Municipal Employees, Council 31, which held that public-sector unions charging fees to nonmembers is a form of coerced speech that violates the First Amendment, should extend to their situation. The Third Circuit disagreed, holding that Janus was focused on preventing forced speech by nonmembers who never consented to join a union, not members who voluntarily join a union and later resign. The court further rejected the appellants' due process claims, finding that they had not been deprived of any constitutional rights. The court also dismissed the appellants' contract defenses, finding that they had not alleged that the terms of their original membership agreements entitled them to membership in perpetuity. The court affirmed the District Court's orders dismissing the appellants' claims. View "Fultz v. AFSCME" on Justia Law

The case concerns Sandra Selden, an employee at the Des Moines Area Community College (DMACC), who alleged that she was a victim of illegal wage discrimination based on sex and wrongful retaliation. Selden discovered that a male colleague was receiving a higher salary for the same job. When her employer did not act on her complaint, attributing the pay gap to the male employee's greater seniority and initial higher salary because of his relevant experience, Selden filed a civil rights complaint. She also applied for a supervisory position, but her application was screened out due to her lack of required educational qualifications. The case went to trial and the jury awarded damages to Selden on both claims. DMACC appealed the decision.The Supreme Court of Iowa reversed the lower court's decision, holding that the record did not contain substantial evidence of an illegal pay practice. The court found that the pay gap was due to gender-neutral factors, specifically a neutral seniority system, and the decision to hire the male employee at a higher rate due to market conditions and his significant experience. The court also found that the retaliation claim was not supported by substantial evidence, as the employer consistently screened out all applicants who lacked the required qualifications. The court concluded that the lower court should have directed a verdict in favor of the defendants and remanded the case for that purpose. View "Selden v. Des Moines Area Community College" on Justia Law