Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's grant of summary judgment for defendants in an action brought by plaintiff after he was terminated as an employee of the Arkansas State Treasurer. The court held that plaintiff's initial argument regarding his defamation, false light, and invasion of privacy claims were without merit because the district court had denied summary judgment on these issues; the district court appropriately granted Defendant Milligan, in his official capacity as Treasurer of the State of Arkansas, summary judgment on plaintiff's Rehabilitation Act claim where the Treasurer neither accepted nor distributed federal financial assistance; the district court's jury instructions on defamation were not erroneous; the district court did not abuse its discretion by failing to give plaintiff's proposed jury instructions regarding invasion of privacy, agency, and cat's paw theory as to the Americans with Disabilities Act claim; and plaintiff's claims regarding whistleblowing activities were not supported by the record and were therefore rejected by the court. View "Singer v. Harris" on Justia Law

The First Circuit affirmed the order granting summary judgment to Stericycle of Puerto Rico and other defendants on Plaintiff’s claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and dismissing without prejudice Plaintiff’s related Puerto Rico law claims, holding that the district court did not abuse its discretion.Specifically, the Court held that the district court (1) did not err in holding that Defendants were entitled to summary judgment on Plaintiff’s Title VII claim for gender-based disparate treatment; (2) correctly granted summary judgment on Plaintiff’s Title VII claim for retaliation; and (3) did not err in denying Plaintiff’s motion to strike Defendants’ motion for summary judgment pursuant to Fed. R. Civ. P. 56. View "Micheo-Acevedo v. Stericycle of Puerto Rico, Inc." on Justia Law

Mindy Armstrong was employed by The Arcanum Group, Inc., which served as a placement agency to staff federal-government positions. She was placed with the Real Estate Leasing Services Department of the Bureau of Land Management (BLM). After she complained that BLM employees were falsifying lease-related records, the BLM demanded that Arcanum remove her from the placement. Her Arcanum supervisor could not find an alternative placement for Armstrong and accordingly terminated her employment. Armstrong sued Arcanum in federal district court, claiming Arcanum retaliated against her for her falsification complaints, in violation of the antiretaliation provisions of the False Claims Act (FCA) and the National Defense Authorization Act (NDAA). The district court granted Arcanum summary judgment, and Armstrong appealed. Finding that Armstrong did not produce sufficient evidence that her supervisor had knowledge of her complaints before he terminated her, the Tenth Circuit Court of Appeals affirmed summary judgment in favor of the employer. View "Armstrong v. The Arcanum Group" on Justia Law

Plaintiff Marcia Eisenhour worked for 24 years as a court administrator for the Weber County Justice Court. In 2008, she complained to the county attorney about sexual harassment by Judge Craig Storey, the only judge of that court. The matter was referred to Utah’s Judicial Conduct Commission, which found no misconduct. Eisenhour then went public in 2009, and the press reported her allegations. Several months later, three Weber County Commissioners, defendants Craig Deardon, Kenneth Bischoff, and Jan Zogmaister, voted to close the Justice Court and merge it with a similar court in another county. This eventually left Eisenhour without a job. Eisenhour sued Storey, Weber County, and the three commissioners who voted to close the Justice Court, raising a variety of claims. The district court granted summary judgment against Eisenhour on all claims, and she appealed. The Tenth Circuit reversed in part. At the trial on the remanded claims, the jury rendered verdicts for Eisenhour on the equal-protection harassment claim against Storey and the whistleblower claim against the County but found against her on the First Amendment retaliation claims against the County and the commissioners. The district court then granted a motion by the County for a new trial on the whistleblower claim, and it sua sponte ordered a new trial on the retaliation claims against the County and the commissioners. At the retrial on those claims the court granted the commissioners’ motion for judgment as a matter of law under Fed. R. Civ. P. 50(b) on the retaliation claim against them, and the jury found for the County on the whistleblower and retaliation claims against it. Storey raised two issues on appeal: (1) the denial of his motion for judgment as a matter of law because the evidence against him was insufficient; and (2) the admission into evidence of a poem he had written concerning Eisenhour. Eisenhour raised three issues: (1) the judge who presided at the first trial should have recused himself after the jury rendered its verdict in that trial; (2) her second trial was unfair because of the district court’s evidentiary rulings; and (3) at the second trial the district court should not have granted the commissioners a judgment as a matter of law but should have let the claim go to the jury. The Tenth Circuit rejected all challenges by both parties except dismissal of a punitive-damages claim. View "Eisenhour v. Weber County" on Justia Law

Plaintiff, a single-leg amputee, filed suit against his employer, ARE, alleging claims under the Americans with Disabilities Act (ADA). Plaintiff was awarded damages for ARE's failure to accommodate his disability by refusing his request to teach on a lower floor. At issue in this appeal was whether ARE failed to reasonably accommodate plaintiff's disability by refusing his request for a classroom aide, and whether ARE's failures to accommodate his disability created a hostile work environment.The DC Circuit affirmed the district court's conclusion that plaintiff had not proffered sufficient undisputed facts for his hostile-work environment claim to survive summary judgment. However, the court reversed the district court's judgment as to the remaining failure-to-accommodate claim, because plaintiff's allegations presented a triable issue of fact as to whether ARE violated the ADA when it refused his request for a classroom aide. View "Hill v. Associates for Renewal in Education, Inc." on Justia Law

This appeal stemmed from and action brought by three police officers against the Town, alleging claims related to the officers' termination. On appeal, the officers challenged the district court's post trial rulings. The Fourth Circuit held that the district court erred when it concluded that each plaintiff's claim arose out of the "same" wrongful act and, in the alternative, the meaning of "interrelated" was unambiguous, and that under that unambiguous meaning, plaintiffs' claims arose out of "interrelated" acts. Therefore, the Town waived its governmental immunity for up to $1 million per plaintiff for damages resulting from the three wrongful terminations of plaintiffs, subject to the $3 million Annual Aggregate Limit of the Town's insurance policy.The panel also held that although the police chief was not a final policymaker of the Town regarding plaintiffs' terminations, the town manager was a final policymaker. Therefore, Bralley's unconstitutional actions may fairly be characterized as actions of the Town such that the Town may be held liable to plaintiffs for damages under section 1983. The panel reversed the district court's dismissal of plaintiff's First Amendment claims against the Town and remanded with instructions to enter judgment for plaintiffs. Finally, the district court did not abuse its discretion in awarding Plaintiff Medlin 1.75 years of front pay. View "Hunter v. Town of Mocksville" on Justia Law

The Ninth Circuit granted Frimmel's petition for review of the ALJ's final decision and order declining to suppress employment records ICE obtained through an investigation of Frimmel's compliance with employment verification requirements. ICE had initiated an investigation of Frimmel after the Maricopa Sheriff's Office (MCSO) conducted illegal raids of two restaurants and the home of Bret Frimmel, owner of Frimmel.The panel held that MCSO committed knowing or reckless material omissions and distortions in search warrant affidavits that resulted in a search violating the Fourth Amendment, and the violation was egregious because a reasonable officer should have known the conduct was unconstitutional. The panel also held that ICE's investigation was not attenuated from MCSO's illegal raid and ICE's evidence was the fruit of MCSO's illegal raid. Finally, the panel held that MCSO's conduct easily met the flagrancy standards and it had immigration enforcement in its "zone of primary interest." Therefore, the exclusionary rule would serve to deter MCSO from Fourth Amendment violations by the probability that illegally obtained evidence would not be useful to ICE, even in a civil proceeding. The panel reversed the ALJ's ruling that denied suppression of ICE's evidence pursuant to the exclusionary rule, remanding for further proceedings. View "Frimmel Management, LLC v. United States" on Justia Law

In February 2016, the Mayor of Birmingham signed Birmingham Ordinance No. 16-28, which guaranteed plaintiffs and all other wage earners in the city $10.10 per hour. The following day, the Alabama Governor signed the Minimum Wage and Right-to-Work Act into law, which nullified Ordinance No. 16-28, preempted all local labor and employment regulation, and mandated a uniform minimum wage throughout Alabama ($7.25 per hour).The Eleventh Circuit held that plaintiffs have stated a plausible claim that the Minimum Wage Act had the purpose and effect of depriving Birmingham's black citizens equal economic opportunities on the basis of race, in violation of the Equal Protection Clause of the Fourteenth Amendment. The court affirmed the dismissal of the city from the suit, but reversed the district court's holding that plaintiffs lacked Article III standing to assert their claims against the attorney general and the State. On the merits, the court reversed the dismissal of the intentional discrimination claim, holding that a sensitive but thorough examination of plaintiffs' detailed allegations showed that plaintiffs have plausibly stated a claim of disparate impact and discriminatory intent. The court affirmed the dismissal of plaintiffs' remaining claims. View "Lewis v. Governor of Alabama" on Justia Law

Plaintiff, a former government contractor with security clearance, filed suit raising numerous constitutional and security claims after his security clearance was revoked. The district court dismissed 23 counts, partially dismissed Count 21 and granted summary judgment to the government on the remainder of that count, and ordered plaintiff to file a more definite statement about the other six counts (Counts 23-27 and 29). The district court later granted summary judgment for the government as to those six counts.As to the frivolous constitutional claims, they were barred by Department of Navy v. Egan, 484 U.S. 518 (1988). As to the Privacy Act claims, the court affirmed the dismissal of the claims because they failed on the merits. As to the Due Process Claims under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics, 403 U.S. 388 (1971), they were properly dismissed because the officials were entitled to qualified immunity. As to challenges to the DOHA proceeding, the court assumed without deciding that plaintiff had a cognizable liberty interest but that his claim was not viable. As to claims of illegal search and claims under the Store Communications Act, the district court correctly dismissed these counts for failure to state a claim. Finally, as to claims of unlawful interrogation, the district court properly concluded that plaintiff failed to establish personal jurisdiction of the defendants. Accordingly, the court affirmed the district court's judgment. View "Palmieri v. United States" on Justia Law

The Eleventh Circuit affirmed the district court's dismissal of plaintiff's complaint against his employer, the Customs and Border Protection Agency, alleging discrimination in violation of the Rehabilitation Act of 1973. After plaintiff suffered multiple injuries on the job, he returned to work and was erroneously placed in a lesser-paying position. Although the agency quickly corrected the error, plaintiff filed suit for retaliation and disability discrimination. The district court dismissed the complaint for lack of jurisdiction based on the Federal Employees' Compensation Act.The court held that plaintiff waived his claim of retaliation on appeal when he failed to make arguments and cite authorities in support of his position. The court also held that the district court erred in ruling that it lacked jurisdiction where the statutory schemes of the Compensation Act and the Rehabilitation Act concerned different kinds of injuries and thus did not conflict. Therefore, the court could not avoid giving effect to both statutory schemes. Although the district court had jurisdiction to consider plaintiff's claim of disability discrimination, plaintiff failed to present evidence that the nondiscriminatory reasons offered by the agency were a pretext for discrimination. Therefore, the district court properly granted summary judgment as to the disability discrimination claim. View "Center v. Secretary, Department of Homeland Security" on Justia Law