Justia Civil Rights Opinion Summaries

Plaintiff filed suit against the university and others, alleging in part that defendants violated his procedural due process rights under the Fourteenth Amendment when they placed him on involuntary leave and later terminated his employment. The Second Circuit held that the district court erred in denying summary judgment to the then-President of the University, John Schwaller, on the ground of qualified immunity. The court held that failure to comply with a state procedural requirement—such as the New York Civil Service Law—does not necessarily defeat a claim for qualified immunity under federal law. Because the district court based its holding almost exclusively on Schwaller's failure to comply with the New York State Civil Service Law, it legally erred by not accessing whether his conduct violated the procedural guarantees of the federal Due Process Clause.The court held that plaintiff's placement on involuntary leave was not a deprivation of a property interest sufficient to trigger due process requirements. Therefore, Schwaller's conduct did not violate clearly established federal law and he was entitled to qualified immunity as a matter of law. Accordingly, the court reversed in part and remanded with instructions to dismiss the due process claim against Schwaller. View "Tooly v. Schwaller" on Justia Law

The First Circuit affirmed the judgment of the district court granting judgment as a matter of law to Defendant-employer on Plaintiff’s age discrimination claims and Puerto Rico law claims and granting in part Defendant’s summary judgment motion, holding that there was no error in the proceedings below.After Plaintiff was laid off as part of Defendant’s effort to cut costs, Plaintiff sued the hospital under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-634 and Puerto Rico antidiscrimination and tort law. The district court granted summary judgment in part for Defendant, finding that Defendant had facially legitimate, non-discriminatory grounds to terminate Plaintiff’s position. A jury trial ensued, but at the close of evidence the district court granted Defendant’s motion for judgment as a matter of law. The First Circuit affirmed, holding that there were fatal and uncontradicted defects in Defendant’s prima facie theory of liability as established by the evidence at trial. View "Hoffman-Garcia v. Metrohealth, Inc." on Justia Law

The First Circuit affirmed the orders of the district court judge’s rulings dismissing Plaintiff’s sexual orientation discrimination claim and granting summary judgment for Defendant on Plaintiff’s unjust discharge and age discrimination claims and awarded Defendant its costs on this appeal, holding that the judge committed no reversible error.In this diversity case governed by Puerto Rico law, the district court judge dismissed Plaintiff’s claims against her former employer on Defendant’s motions to dismiss and for summary judgment. The First Circuit affirmed, holding (1) the judge properly dismissed Plaintiff’s sexual orientation discrimination claim because Plaintiff did not plausibly plead that her firing constituted sexual orientation discrimination; and (2) the judge properly granted summary judgment for Defendant on Plaintiff’s unjust discharge and age discrimination claims. View "Villeneuve v. Avon Products, Inc." on Justia Law

The Supreme Court reversed the judgment of the trial court awarding Matthew Vacca actual and punitive damages, including substantial future lost wages, on his claim that he was retaliated against for filing a complaint with the Missouri Commission on Human Rights and Equal Employment Opportunity Commission alleging disability discrimination, holding that the trial court abused its discretion in refusing to apply judicial estoppel to Vacca’s claim of future lost wages.The circuit court found Vacca claimed in this case that he could have continued to work as an administrative law judge (ALJ) for twenty more years. In Vacca’s ongoing dissolution proceeding, however, he claimed he was entitled to maintenance because he was totally unable to work due to his disability. The circuit court concluded that it was barred from applying judicial estoppel because the dissolution judgment had been remanded for further proceedings based on evidentiary errors. The Supreme Court reversed, holding (1) once a party takes inconsistent positions, there are no fixed prerequisites to application of judicial estoppel; and (2) the trial court abused its discretion in refusing to apply judicial estoppel to preclude Vacca from making the inconsistent claim that he was able to work as an ALJ for another twenty years with reasonable accommodations. View "Vacca v. Missouri Department of Labor & Industrial Relations, Division of Workers' Compensation" on Justia Law

The Fourth Circuit affirmed the district court's grant of summary judgment for the University in an action brought by a sociology professor, alleging claims under the Equal Pay Act and Title VII. The court held that, although plaintiff established a pay disparity between her and two former administrators, she failed to present evidence creating a genuine issue of material fact that the administrators were appropriate comparators. The court also held that, in any event, the University based the administrators' higher pay on their prior service as University administrators, not their sex. View "Spencer v. Virginia State University" on Justia Law

The Ninth Circuit affirmed the district court's grant of summary judgment for the Salvation Army, in an employment discrimination action under Title VII of the Civil Rights Act and the Americans with Disabilities Act (ADA). The panel held that the religious organization exemption (ROE) applied to the Salvation Army; the ROE reached claims for retaliation and hostile work environment; and the ROE barred plaintiff's claims because the ROE was nonjurisdictional and subject to procedural forfeiture, and may be first raised at summary judgment absent prejudice. Absent prejudice resulting from the failure to timely raise the defense, the panel held that the Salvation Army permissibly invoked the ROE at summary judgment and it foreclosed plaintiff's Title VII claims.The panel also held that plaintiff failed to make out a claim under the ADA because the Salvation Army was under no obligation to engage in an interactive process in the absence of a disability. In this case, after plaintiff's clearance for work, she failed to show that she was disabled. View "Garcia v. Salvation Army" on Justia Law

Where a jury awarded plaintiff nominal compensatory damages and punitive damages for his claim of hostile work environment against his former employer, the Eighth Circuit affirmed the district court's denial of defendant's post-trial motions and grant of attorney's fees to plaintiff. The court held that the $250,000 award of punitive damages was supported by the record where plaintiff repeatedly complained to supervisors that his manager was using racial slurs and the company did not take action; plaintiff's 42 U.S.C. 1981 claim was timely under the applicable four year statue of limitations where the workplace abuse continued into the limitations period; the punitive damages amount was constitutionally sound in light of the degree of reprehensibility of defendant's misconduct; and the district court did not abuse its discretion in awarding attorney's fees and accepting the attorney's hourly rate as reasonable. View "Bryant v. Jeffrey Sand Co." on Justia Law

Commissioner, on behalf of preschool teachers employed by the Temple, filed suit alleging that the Temple violated various provisions of the Labor Code by failing to provide its preschool teachers with rest breaks, uninterrupted meal breaks, and overtime pay. The trial court granted summary judgment for the Temple and held that the Commissioner's claims were barred by the ministerial exception.The Court of Appeal reversed and held that the teachers were not "ministers" for purposes of the ministerial exception. In this case, although the Temple's preschool curriculum has both secular and religious content, its teachers were not required to have any formal Jewish education, to be knowledgeable about Jewish belief and practice, or to adhere to the Temple's theology. Furthermore, the Temple did not refer to its teachers as "ministers" or the equivalent, nor did the teachers refer to themselves as such. Therefore, the court remanded for further proceedings. View "Su v. Stephen S. Wise Temple" on Justia Law

A former employee of the Department of Health and Social Services (DHSS), Terri Reynolds-Rogers, brought a wrongful discharge suit against the State. At the time of her termination she had four union grievances pending against DHSS, and her union filed another based on the termination. The union settled all five grievances in exchange for a payment to the employee. She later sued DHSS for wrongful termination, alleging both breach of the covenant of good faith and fair dealing and several torts, including retaliatory discharge and failure to accommodate her disabilities. The superior court granted DHSS’s motion for summary judgment and entered final judgment against the employee. After review, the Alaska Supreme Court concluded the superior court was correct in deciding that the employee’s claims were resolved by the settlement of her grievances, were barred by the statute of limitations, or were legally insufficient in light of the undisputed facts. View "Reynolds-Rogers v. Alaska, Dept. of Health & Social Services" on Justia Law

The Wilcox County Board of Education ("the Board"), and Board members Lester Turk, Donald McLeod, Joseph Pettway, Jr., and Shelia Dortch (collectively, "the Board members"), petitioned the Alabama Supreme Court for a writ of mandamus to direct the Wilcox Circuit Court to vacate its order denying their motion to dismiss the claims against them based on immunity and to enter an order granting that motion. In 2017, Kimberly Perryman, as guardian and next friend of her minor son, R.M., sued the Board, and J.E. Hobbs Elementary School principal Roshanda Jackson, and teacher Timothy Irvin Smiley. Perryman alleged in 2016, Smiley, "in a fit of rage and unprovoked, did lift the Plaintiff R.M. and slam him down upon a table, with such force as to break said table." Perryman further alleged in her rendition of the facts that "Smiley was in the habit of continuously and repeatedly using harsh, physical and otherwise inappropriate tactics on the students in his class" and that "Smiley's behavior was known or should have been known to the Principal Defendant and the School Board Defendant[]." Perryman asserted claims of assault and battery and intentional infliction of emotional distress against Smiley; claims of negligence and negligent/wanton hiring, training, retention, and supervision against Jackson; and a claim of negligence against the Board. Specifically, the negligence claim against the Board stated: "The ... Wilcox County Board of Education negligently breached [its] dut[y] to R.M. by failing to supervise, discipline or remove if necessary, the Defendant teacher [Timothy Smiley], thereby placing the Plaintiff R.M. in harm's way." The Alabama Supreme Court concluded the Board and the Board members in their official capacities were entitled to immunity from the state-law claims asserted against them; the Board members in their individual capacities were entitled to State-agent immunity from any state-law claims asserted against them; and that the Board members in their individual capacities were entitled to qualified immunity from the 42 U.S.C. 1983 claim asserted against them. Therefore, the circuit court should have dismissed Perryman's claims with respect to those parties, and to that extent the petition for mandamus relief was granted. However, the Board and the Board members in their official capacities were not entitled to Eleventh Amendment immunity from the section 1983 claim, and the petition was denied with respect to that claim. View "Ex parte Wilcox County Board of Education" on Justia Law