Justia Civil Rights Opinion Summaries

Freeman, an African-American, began as an "at will" probationary treatment plant operator, collecting and transporting water samples across the mile-long plant. Although operators typically transport these samples in District-owned vehicles, the job description does not require a driver’s license. Three months after Freeman was hired, he was arrested for driving under the influence of alcohol, His license was suspended for six months. Freeman began seeing a substance-abuse counselor. As required by his contract, he told the District about the license suspension and his counseling. He bought a bike and a cooler to transport samples and asked whether he could use a go-cart, which does not require a driver’s license on private property. The District refused to approve a state-approved occupational driving permit that would permit him to drive a company vehicle while working. The District fired Freeman, asserting “unsatisfactory performance.” Freeman alleges that the real reason for his firing was his race and because the District regarded him as an alcoholic. Each of four court-recruited attorneys moved to withdraw. The court dismissed his claims of race and disability discrimination and of retaliation, 42 U.S.C. 1981, 1983; Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2; and under the Americans with Disabilities Act, 42 U.S.C. 12112. The Seventh Circuit vacated in part. Freeman adequately pleaded his discrimination claims. The court affirmed with respect to Freeman’s Monell contention that the District fired him pursuant to an unlawful policy. View "Freeman v. Metropolitan Water Reclamation District of Greater Chicago" on Justia Law

After plaintiff was denied tenure and terminated by the University, he filed suit against the Board of Trustees, claiming that the University discriminated against him based on race and violated both the terms and spirit of its contract with him.The DC Circuit reversed the district court's grant of summary judgment to the University on the Title VII, D.C. Human Rights Act (DCHRA), and contract claims. As to the statutory claims under Title VII and the DCHRA, the court held that plaintiff raised a plausible inference that race was a motivating factor in the University's decision to deny him tenure. As to the contract claims, the court held that the claims were not time-barred. On the merits, the court held that there was an unresolved factual dispute regarding whether an implied-in-fact contract between plaintiff and the University existed and, if it did, what the terms and intent of that contract were. Accordingly, the court remanded for further proceedings. View "Mawakana v. Board of Trustees of the University of the District of Columbia" on Justia Law

The First Circuit vacated the judgment of the district court granting Defendants' motion for summary judgment after treating the motion as a motion to dismiss pursuant too Fed. R. Civ. P. 12(b)(6), holding that the district court applied the wrong legal standard in adjudicating Defendants' summary judgment motion.Plaintiff brought this action alleging that his employer had discriminated against him on the basis of his national origin and subjected him to retaliation. Defendants moved for summary judgment. The district court considered the motion as a motion to dismiss for failure to state a plausible claim and granted the motion. The First Circuit reversed, holding that the district court's attempt to transform Defendants' fully developed motion for summary judgment into a motion to dismiss was an abuse of discretion. View "Rios-Campbell v. U.S. Department of Commerce" on Justia Law

Firefighter Mollet became a battalion chief in 2009. His relationships with chief Cohn and assistant chief Weber were strained. One night, firefighter Hernandez forgot to stow his gear. Other firefighters displayed the items and posted a paper sign with a Mexican flag and the words “Border Patrol.” Hernandez did not file a complaint but another firefighter reported it. Mollet emailed Cohn and Weber, who agreed “that this crosses the line of firehouse hazing” and asked Mollet to investigate. Four individuals were eventually disciplined. In the following months, Cohn and Weber were critical of Mollet’s performance on multiple occasions and stated that he might be demoted or reassigned. Mollet received an offer of employment from another department. Cohn and Weber indicated that he would be demoted if he did not take that position. Mollet told Weber he was going to accept the offer, which was contingent upon his passing a physical and psychological exam. Cohn sent a letter accepting Mollet’s resignation; Mollet responded he would not resign until the contingencies were met. Cohn responded that Mollet’s employment had terminated. Mollet was placed on paid leave until he submitted his resignation and began his new employment. Mollet filed suit, 42 U.S.C. 2000e, alleging he was retaliated against for opposing workplace discrimination. The Seventh Circuit affirmed summary judgment rejecting the claim; no reasonable trier of fact could find that reporting the Hernandez incident was the but-for cause of Mollet’s constructive discharge. View "Mollet v. City of Greenfield" on Justia Law

Plaintiff filed suit against the sheriff and several other county employees, alleging various claims related to the treatment plaintiff asserted he suffered as a result of his political beliefs and associations. The Eighth Circuit affirmed the district court's grant of summary judgment to the sheriff on the First Amendment discrimination and retaliation claims. The court held that both claims suffered from the same fatal flaw because they lacked an adverse employment action. In this case, none of the complained-of actions, either together or separately, constitute an adverse employment action. View "Charleston v. McCarthy" on Justia Law

The Supreme Court vacated the portion of the opinion of the court of appeals holding that the section of Ky. Rev. Stat. 342.7305 treating hearing loss workers' compensation claimants differently from other types of traumatic injury claimants violated constitutional equal protection guarantees, holding that a rational basis existed for the unequal treatment.Under section 342.7305, workers' compensation claimants suffering hearing loss may not receive income benefits unless their whole person impairment rating is at least eight percent, but other types of non-hearing loss traumatic injury claimants need not meet this threshold impairment rating to qualify for income benefits. The court of appeals held that section 342.7305(2) was unconstitutional. The Supreme Court vacated the court of appeals' opinion and affirmed the ALJ's determinations that the claimants in this case did not qualify for income benefits based on their impairment ratings, holding that a rational basis existed for the eight percent impairment threshold for income benefits. View "Teco/Perry County Coal v. Feltner" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the circuit court granting a motion to dismiss for failure to state a claim in favor of Employer on Employee's complaint alleging wrongful discharge in violation of public policy, holding that the circuit court properly dismissed the complaint.Plaintiff alleged that she was terminated in retaliation for informing other workers that one of their supervisors was a registered sex offender or, at the least, that this was a substantial motivating factor in her termination. Specifically, Plaintiff claimed that the Kentucky Sex Offender Registration Act establishes a public policy that the sex offender registry should be open and accessible to the public at large. The circuit court granted Employer's motion to dismiss, and the court of appeals affirmed. The Supreme Court affirmed, holding that even if a right to disseminate information from the sex offender registry existed to prevent termination for that dissemination, the dissemination would need to be effectuated in a manner consistent with appropriate workplace behavior and decorum. View "Marshall v. Montaplast of North America, Inc." on Justia Law

Christopher Ross appeals from a summary judgment granted in favor of the County of Riverside on Ross's claims for violation of Labor Code section 1102.5 and for violation of the provisions in the Fair Employment and Housing Act (Gov. Code, § 12900 et seq.; FEHA) prohibiting disability discrimination, failure to reasonably accommodate, failure to engage in the interactive process, and failure to prevent disability discrimination. Ross worked for the County as a deputy district attorney. He sought an accommodation with his work schedule based on a concussion syndrome he was experiencing from previous work in the Military. Supervisors there did not oblige, and Ross sued for violations of the Labor Code section 1102.5, but it was determined he could not establish his claim for disability discrimination because he could not prove he could perform the essential functions of his job. He could not establish his claim for failure to provide a reasonable accommodation for the same reasons as well as because he could not prove he had any functional limitations requiring accommodation and his requested accommodation was not reasonable. He could not establish his claim for failure to engage in the interactive process because he did not interact in good faith. And, he could not establish his claim for failure to prevent disability discrimination because he could establish his claims for disability discrimination. Because the Court of Appeal concluded there were triable issues of material fact of the questions of whether Ross engaged in protected activity under Labor Code section 1102.5 and whether Ross had a physical disability under the FEHA, it reversed the judgment as to these claims and remanded the matter for further proceedings. View "Ross v. County of Riverside" on Justia Law

In this work injury discrimination case the Supreme Court held that in order for business necessity to constitute a valid defense to a claim of work injury discrimination, an employer must demonstrate that the employee's absence caused a business impairment that could not be reasonably alleviated by means that would not result in discrimination.The Supreme Court vacated the judgment the intermediate court of appeals' judgment on appeal and the judgment of the circuit court reversing the decision of the Director of the Hawai'i Department of Labor and Industrial Relations that the work injury discrimination in this case was contravened by Hawaii law, holding that the decision of the hearing officer that the employer in this case discriminated against the employee solely because of her work injury should have been affirmed. View "BCI Coca-Cola Bottling Co. of Los Angeles, Inc. v. Murakami" on Justia Law

Plaintiffs, 47 former longtime employees of the District Child and Family Services Agency who were mostly African American, filed suit alleging claims that their terminations were unlawfully discriminatory on the basis of age and race. At issue on appeal, were the race-based claims.The DC Circuit generally affirmed the district court's grant of summary judgment on plaintiff's race-based claims, but reversed as to one issue. The court held that nothing in Title VII suggests that the practices an employer uses to effectuate the adverse employment action of layoffs, whether or not dubbed a reduction in force, are exempt from disparate-impact scrutiny. Accordingly, the court reversed the "particular practice" holding and the accompanying denial of class certification, remanding for further proceedings. The court affirmed the district court's decisions with respect to plaintiffs' challenge to the college degree requirement the Agency added to one job category, and the applicability of estoppel to certain individual plaintiffs' claims. View "Davis v. District of Columbia" on Justia Law