Justia Civil Rights Opinion Summaries

Barbara Lindsay, the former Director of Workforce Development and Career Services at Emily Griffith Technical College (EGTC), sued Denver Public Schools (DPS) and Stephanie Donner, EGTC's Executive Director, for retaliation. Lindsay claimed that her termination was motivated by her opposition to racist comments made during the hiring process for the Executive Director position and her assistance to a candidate in filing employment discrimination charges. The United States District Court for the District of Colorado granted summary judgment in favor of DPS and Donner. Lindsay appealed to the United States Court of Appeals for the Tenth Circuit, which affirmed the lower court’s decision. The Court of Appeals held that there was insufficient evidence to prove a causal relationship between Lindsay's protected activity (opposition to racist comments and assistance in filing discrimination charges) and her termination. The Court determined that there was no evidence that those who decided to terminate Lindsay's employment were aware of her protected activity. The court further noted that Lindsay failed to show that anyone at DPS knew that she had assisted in bringing discrimination charges before she was fired. Therefore, Lindsay's claim that she was terminated in retaliation for protected activities could not be substantiated. View "Lindsay v. Denver Public Schools" on Justia Law

In this case heard before the United States Court of Appeals for the Sixth Circuit, the plaintiff, Christina Littler, a bus driver for a school district, appealed a grant of summary judgment in favor of the defendant, Ohio Association of Public School Employees (OAPSE), a union she had joined. Littler had filed a 42 U.S.C. § 1983 action alleging the wrongful deduction and retention of union dues. She claimed that she had withdrawn her union membership and therefore her dues deduction authorization too, but OAPSE had continued to deduct dues from her paycheck. On remand from an earlier appeal, the district court held that Littler had failed to show that OAPSE was a state actor under § 1983, and thus granted OAPSE summary judgment on Littler’s § 1983 claim.The Sixth Circuit affirmed the district court’s judgment. It held that Littler had failed the first prong of the "state action" test under § 1983, as she could not show that the alleged deprivation was caused by any governmental policy or decision. Instead, the conduct she complained about was inconsistent with the collective bargaining agreement and violated her agreement with OAPSE. This conduct was attributed to a private actor—OAPSE—acting contrary to any rule of conduct imposed by the state, and therefore could not be attributed to the state. The court also rejected Littler's argument that the deprivation was caused by the terms of the collective bargaining agreement and the school district’s compliance with the union’s request to withhold dues from her paycheck. Instead, the court held that the specific conduct complained about was OAPSE’s failure to process Littler’s withdrawal pursuant to the membership application and remove her name from the deduction list. This was not governed by a state-imposed rule of conduct but rather by a private individual or organization’s policy. Thus, the court concluded that the challenged conduct could not be fairly attributable to the state. View "Littler v. Ohio Ass'n of Pub. Sch. Emps." on Justia Law

In this case heard by the United States Court of Appeals For the Seventh Circuit, Kimberly Barnes-Staples applied for a Real Estate Director position with the General Services Administration (GSA). However, the GSA hired another candidate. Barnes-Staples subsequently sued the GSA, alleging that the interview process discriminated against her because of her race and sex in violation of Title VII of the Civil Rights Act. The district court granted summary judgment in favor of the GSA.Barnes-Staples argued that the GSA did not follow its internal anti-discrimination procedures, which she claimed allowed the GSA to hire a less qualified candidate. She also contended that she was the superior candidate, so the GSA's assertion that the other candidate was more qualified was pretextual. Furthermore, Barnes-Staples asserted that there was a systemic practice of discrimination against Black candidates and employees within the GSA.The Appeals Court, however, found that Barnes-Staples was not "clearly better qualified" than the candidate who was hired. It also found no evidence that the GSA created interview questions to favor the other candidate, nor was there evidence that the GSA violated its own guidelines during the interview process. The court also noted that while Barnes-Staples presented data on promotion and employment rates within the GSA, she failed to provide sufficient context or detail for this data to support her claim of systemic discrimination.The Appeals Court affirmed the district court's grant of summary judgment in favor of the GSA. Additionally, it found that Barnes-Staples had waived her sex discrimination claim as she did not properly develop this argument before the district court. View "Barnes-Staples v. Carnahan" on Justia Law

Craig Price, a Black man, filed a lawsuit against his former employer, Valvoline LLC, alleging that his employment was terminated due to his race and he was subjected to a hostile work environment. Valvoline operated on an attendance policy, and Price had been repeatedly warned about his absenteeism, with his employment eventually terminated after he missed a shift due to food poisoning. Price also alleged that discriminatory comments had been made by his supervisors. The United States Court of Appeals for the Fifth Circuit affirmed the district court's summary judgment in favor of Valvoline. The Appeals Court found that Price's employment was terminated due to his repeated absenteeism, not because of his race. Furthermore, the court concluded that the allegedly race-motivated comments were not objectively severe or pervasive enough to create a hostile work environment. The court also noted that Price could not demonstrate that the alleged harassment he experienced was frequent or that it interfered with his work performance. Therefore, Price's claims of race discrimination and a hostile work environment were rejected. View "Price v. Valvoline" on Justia Law

In this case, the Virginia Supreme Court ruled in favor of Peter Vlaming, a high school French teacher who was terminated by the West Point School Board for refusing to use a transgender student's preferred pronouns. Vlaming had chosen to use the student's preferred name but avoided using any third-person pronouns to refer to the student as it conflicted with his religious beliefs. The School Board fired Vlaming for not complying with its policy to use government-mandated pronouns.Vlaming sued the School Board, alleging that his termination violated his constitutional, statutory, and breach-of-contract rights. The Circuit Court dismissed Vlaming's claims, holding that they failed to state legally viable causes of action. The Supreme Court of Virginia, however, reversed the decision and remanded the case for further proceedings. The Court concluded that Vlaming's complaint sufficiently alleged that the School Board substantially burdened his right to free exercise of religion under the Virginia Constitution and that his claims under the Virginia Religious Freedom Restoration Act should not have been dismissed. Moreover, the Court held that Vlaming has alleged a viable compelled speech claim under the free speech provision of the Virginia Constitution. The Court rejected the School Board's argument that it could compel Vlaming's speech as part of his official duties as a teacher. The Court concluded that Vlaming's refusal to use certain pronouns did not interfere with his duties as a French teacher or disrupt the school's operations.The Court's decision reaffirmed the fundamental right to free speech and the free exercise of religion under the Virginia Constitution, emphasizing that these rights extend to public school teachers in their interactions with students. It clarified that although the government has a legitimate interest in ensuring non-discrimination and respect for all students, this interest must be balanced against individual rights to free speech and the free exercise of religion. The Court also clarified that a public school teacher's speech in the classroom is not entirely within the control of the school board and that teachers cannot be compelled to express views that conflict with their sincerely held religious beliefs. View "Vlaming v. West Point School Board" on Justia Law

This case concerns an appeal by the Florida Department of Juvenile Justice (the "Department") against a jury's verdict in favor of Lawanna Tynes, a former employee. Tynes had sued the Department for race and sex discrimination under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1981, after she was terminated from her position as the superintendent of the Broward Regional Juvenile Detention Center. The Department argued on appeal that Tynes failed to establish a prima facie case of discrimination, as required under the evidentiary framework set by the McDonnell Douglas Corp. v. Green case, because the comparator employees she presented were not similarly situated in all material respects.However, the United States Court of Appeals for the Eleventh Circuit affirmed the district court's judgment. The appellate court ruled that the Department's focus on the McDonnell Douglas framework and the adequacy of Tynes's comparators missed the ultimate question in a discrimination case, which is whether there is enough evidence to show that the reason for an adverse employment action was illegal discrimination. The jury found that the Department had intentionally discriminated against Tynes, and the Department did not challenge the sufficiency of the evidence for that conclusion on appeal. Therefore, the Department's arguments regarding the adequacy of Tynes's comparators and the insufficiency of her prima facie case were irrelevant and did not disturb the jury's verdict.The Department also challenged the jury's verdict on Tynes's § 1981 claim, arguing that her complaint did not adequately plead the § 1981 claim and that she did not prove that race was a but-for cause of her termination. However, the appellate court found that the Department had forfeited both arguments because it failed to challenge the district court's authority to allow an amendment to the pleadings during the trial under Rule 15(b)(1) of the Federal Rules of Civil Procedure and did not argue that Tynes failed to prove that race was a but-for cause in its post-trial motion.Therefore, the appellate court affirmed the district court's judgment in favor of Tynes on both her Title VII and § 1981 claims. View "Tynes v. Florida Department of Juvenile Justice" on Justia Law

Plaintiff employees who opted out of their union and employer-sponsored health plans received a monetary credit, part of which was deducted as a fee that was then used to fund the plans from which plaintiffs had opted out. Plaintiffs argue that this opt-out fee should be treated as part of their “regular rate” of pay for calculating overtime compensation under the Fair Labor Standards Act (FLSA).   The Ninth Circuit affirmed the district court’s grant of summary judgment. The panel held that the opt-out fees were not part of the employees’ “regular rate” of pay, but rather were exempted as “contributions irrevocably made by an employer to a trustee or third person pursuant to a bona fide plan for providing” health insurance under 29 U.S.C. Section 207(e)(4). View "ANTHONY SANDERS, ET AL V. COUNTY OF VENTURA" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of the U.S. Department of Veterans Affairs (VA) in this lawsuit alleging disability discrimination, hostile work environment, and other claims, holding that there was no error in the proceedings below.Plaintiff filed this action claiming disability discrimination under the Rehabilitation Act (RA), hostile work environment under the RA and Americans with Disabilities Act, retaliation in violation of Title VII, and failure to accommodate under the RA. The district court granted summary judgment in favor of the VA on all counts. The First Circuit affirmed, holding that the district court (1) correctly concluded that 5 U.S.C. 8461(d) did not bar its review of Plaintiff's claims at summary judgment; (2) did not err in rejecting Plaintiff's preclusion claim; and (3) did not err in granting summary judgment. View "Dixon-Tribou v. McDonough" on Justia Law

California State University’s (CSU) hired Plaintiff as the director of university communications of California State University at Northridge’s Marketing and Communications Department (the Department). The VP testified that after speaking with employees while investigating complaints against Plaintiff, he determined that Plaintiff could not be an effective department leader because he disregarded CSU’s direction regarding professionalism; staff could not work with him; and subordinates were intimidated and threatened by him. Plaintiff filed a complaint against CSU alleging gender, race, color, and sexual orientation discrimination under the Fair Employment and Housing Act (FEHA); race, gender, and sexual orientation harassment; and failure to prevent harassment and discrimination. CSU filed a motion for summary judgment or summary adjudication. The trial court entered the order granting summary judgment to Defendants and Plaintiff appealed.   The Second Appellate District affirmed. The court found that the trial court correctly granted summary judgment on Plaintiff’s discrimination claims. The court explained that CSU established a legitimate reason for the termination. Moreover, the court held that Plaintiff failed to submit evidence that creates a dispute of material fact as to pretext. Similarily, the court explained that Plaintiff has not established a dispute of fact regarding whether CSU’s internal investigation was pretextual. The court wrote that Plaintiff failed to produce substantial evidence of any bias in the E&D investigation, and his statistical evidence is not probative of discriminatory motive. Further, Plaintiff’s evidence of CSU’s commitment to diversity does not create a triable issue of discriminatory motive. View "Martin v. Board of Trustees of the Cal. State University" on Justia Law

In 2020, Bennett, a nursing student completing a clinical rotation at Hurley, requested that her service dog, Pistol, be permitted to accompany her. Pistol recognizes the symptoms Bennett exhibits just before a panic attack and alerts her so that she can take Ativan. Hurley agreed. Its Service Animal Policy largely tracks regulations implementing the ADA, 42 U.S.C. 12131. When Bennett brought Pistol to the hospital, one staff member and one patient reported allergic reactions. Hurley revoked Bennett’s ability to have Pistol with her at all times, stating the hospital remained “open to continued dialogue” and would provide space for a crate for Pistol on another floor and “make every effort to accommodate” unscheduled breaks. Hurley concluded that relocating staff and patients could compromise patient care. Moving nurses would be difficult; Hurley nurses are union members and the hospital was short-staffed during the pandemic. There were concerns about having a dog on a floor with immunocompromised or unconscious patients. Bennett finished her Hurley rotation without Pistol and without experiencing a panic attack. Bennett completed rotations at other hospitals with PistolThe Sixth Circuit affirmed the rejection of Bennett’s claims under the ADA, the Rehabilitation Act, 29 U.S.C. 794, and Michigan law. Hurley’s concerns were with Pistol, not with Bennett’s medical condition. Hurley reasonably decided that Pistol posed a direct threat to the health and safety of patients and that the accommodations necessary to mitigate the risk were not reasonable. View "Bennett v. Hurley Medical Center" on Justia Law