Justia Civil Rights Opinion Summaries

In a complaint described as “disjointed and murky at best,” Catinella alleged that he worked for Cook County, 1994-2013, and in 2009, was promoted to a supervisory position. In 2013, Catinella was questioned regarding a bidding process and refused to sign documents relating to the probe. During this interview, investigators asked Catinella if he was carrying a weapon. Catinella admitted that he had a knife, which he gave to his lawyer. Months later, Catinella’s coworkers filed a grievance complaining that Catinella was getting extra work privileges. Catinella was placed on emergency leave with pay pending an investigation. Days later he was placed on emergency suspension for unspecified “major causes.” An investigator produced witnesses to an alleged threat by Catinella to “shoot up the workplace.” The witnesses gave inconsistent accounts. Catinella was charged with disorderly conduct and released on bond. A report concluded that Catinella possessed a weapon while at work. At a pre-disciplinary meeting, Catinella was not allowed to confront witnesses. Cook County fired Catinella for possessing a weapon and making a threat of violence. The disorderly conduct charge was dropped. Catinella sued under 42 U.S.C. 1983 alleging violations of procedural and substantive due process and alleging race-based retaliation under 42 U.S.C 1981 and 1983. The Seventh Circuit affirmed dismissal. The complaint does not show how this “whirlwind of alleged unfairness” violates any federal constitutional or statutory provision. View "Catinella v. Cook County" on Justia Law

The Supreme Court affirmed the order of the district court awarding summary judgment to the Missoula County Detention Facility and the Missoula County Sheriff’s Office (collectively, the County) on Plaintiff’s claim that the County had illegally discriminated against him based on his disability. Plaintiff initially filed a complaint with the Human Rights Bureau (HRB), which found no reasonable cause to believe that the County had discriminated against Plaintiff. The district court agreed. The Supreme Court Supreme Court affirmed, holding (1) the district court did not err in declining to consider evidence arising after Plaintiff filed his HRB complaint; and (2) the district court correctly granted summary judgment for the County. View "Borges v. Missoula County Sheriff’s Office" on Justia Law

Plaintiff filed suit against Stony Brook under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., alleging discrimination and retaliation when he was terminated from his employment as an electrician. The Second Circuit affirmed the district court's grant of summary judgment on the issue of whether plaintiff was an employee of Stony Brook. The court held, according to precedent, that a trial court did not commit error by submitting the question of whether plaintiff was defendant's employee to the jury, whether by general verdict or by special question. The court rejected plaintiff's contention that the district court erred when it instructed the jury to use the factors in Cmty. for Creative Non‐Violence v. Reid, 490 U.S. 730, 751–52 (1989), to determine whether plaintiff was a Stony Brook employee. The court held that the evidence presented disputed issues of fact regarding several of the Reid factors, and the balancing of those factors and others that pointed both in favor of and against employee status also presented a disputed issue requiring resolution by the fact‐finder. The court rejected plaintiff's remaining arguments. View "Knight v. State Univ. of N.Y. at Stony Brook" on Justia Law

The First Circuit affirmed the judgment of the trial court, entered after a jury trial, ruling in favor of Plaintiff on both her gender-based hostile work environment discrimination and retaliation claims. The court awarded Plaintiff emotional and front pay damages. Defendant, the City of Providence, appealed from the denial of its motion for judgment as a matter of law, making numerous arguments as to why the jury verdict should be set aside or, in the alternative, why the judge’s front pay award should be stricken. The First Circuit affirmed, holding that Defendant’s arguments and assignments of error were unavailing. View "Franchina v. Providence Fire Department" on Justia Law

A notice of termination may be an adverse employment action independent of an actual termination under the Utah Protection of Public Employees Act (UPPEA).Plaintiff filed suit against Employer, claiming infringement of her free speech rights under the Utah Constitution and under the UPPEA. Employer moved for summary judgment, arguing, inter alia, that the UPPEA claim was time-barred because Plaintiff suffered an “adverse employment action” triggering the 180-day filing requirement under the UPPEA. The United States District Court certified three questions for the Utah Supreme Court’s review. The Supreme Court declined to exercise its discretion to resolve the first two questions and instead answered only the third question. The court answered the question as set forth above and set forth an analytical framework for assessing whether such employment actions are independent of each other under the UPPEA. View "Zimmerman v. University of Utah" on Justia Law

After complaints about his professionalism, Indiana University Hospital required Dr. Hamdan, a U.S. citizen of Palestinian descent, to participate in a peer-review process, which resulted in disciplinary letters. Hamdan successfully appealed. The hospital ultimately voided the letters. Nonetheless, Hamdan resigned and relinquished his hospital privileges. Hamdan sued the hospital for discriminating against him based on race. Hamdan was not a hospital employee and could not sue under Title VII, so he sued under 42 U.S.C. 1981, part of the Civil Rights Act of 1866, intended to protect the ability of newly-freed slaves to enter and enforce contracts. Hamdan alleged discrimination in his contractual relationship with the hospital. The Seventh Circuit affirmed a verdict for the hospital, rejecting an argument that the district court erred in allowing the hospital to ask Hamdan impeachment questions relating to his prior work at other hospitals. The court noted Hamdan’s testimony that his reputation was “untarnished” before he received the disciplinary letters. The Seventh Circuit also rejected an argument that the court erred in permitting the hospital to try to impeach him with questions about matters that were confidential under the peer-review statutes of Indiana, Louisiana, and Michigan. Even if the state laws applied, the judge did not abuse his discretion in allowing impeachment questions about incident reports. View "Hamdan v. Indiana University Health North Hospital, Inc." on Justia Law

An employee brought claims under provisions of the Idaho Human Rights Act, claiming: (1) the employer unlawfully discriminated against him based on race. He also alleged (2) breach of employment contract and the implied covenant of good faith. Furthermore, the employee (3) sought to disqualify the trial judge for cause based upon perceived bias. The district court denied the employee’s disqualification motion and granted summary judgment for the employer on all of the employee’s claims. Finding no reversible error, the Idaho Supreme Court affirmed judgment entered in favor of the employer. View "Mendez v. University Health Svcs BSU" on Justia Law

Plaintiffs Richard Tabura and Guadalupe Diaz were Seventh Day Adventists. Their religious practice of not working Saturdays conflicted with their job schedules at a food production plant operated by Defendant Kellogg USA, Inc. (“Kellogg”). Eventually Kellogg terminated each Plaintiff for not working their Saturday shifts. Plaintiffs alleged that in doing so, Kellogg violated Title VII of the Civil Rights Act by failing to accommodate their Sabbath observance. Both sides moved for summary judgment. The district court denied Plaintiffs’ motion and granted Kellogg summary judgment, concluding as a matter of law both that Kellogg did reasonably accommodate Plaintiffs’ religious practice and, alternatively, that Kellogg could not further accommodate their Sabbath observance without incurring undue hardship. The Tenth Circuit concluded after review of the district court record that the district court erred in granting Kellogg summary judgment; however, on the same record, the district court did not err in denying Plaintiffs summary judgment. View "Tabura v. Kellogg USA" on Justia Law

Plaintiff-appellant William Bustos sued his former employers, defendants-respondents Global P.E.T., Inc. and Global Plastics, Inc. (collectively, Global) for discrimination. A jury found that Bustos’s physical condition or perceived physical condition was “a substantial motivating reason” for his termination, but nevertheless returned defense verdicts on each of his claims. After trial, Bustos sought an award of attorney fees under the Fair Employment and Housing Act, citing the holding of Harris v. City of Santa Monica, 56 Cal.4th 203 (2013) that “a plaintiff subject to an adverse employment decision in which discrimination was a substantial motivating factor may be eligible for reasonable attorney’s fees and costs expended for the purpose of redressing, preventing, or deterring that discrimination,” even if the discrimination did not “result in compensable injury” for that particular plaintiff. In this appeal, Bustos challenges the trial court’s ruling denying his motion for attorney fees. The Court of Appeal affirmed the trial court, finding the record did not support Bustos’ contention that the trial court ignored “Harris:” the trial court explicitly acknowledged Harris in its remarks regarding its tentative ruling. The trial court correctly recognized, moreover, that even under Harris, the award of attorney fees pursuant to Government Code section 12695 was discretionary, and it appropriately exercised that discretion. View "Bustos v. Global P.E.T" on Justia Law

The Second Circuit reversed the district court's dismissal of plaintiff's third amended complaint against the Department and others. Plaintiff alleged that he was subjected to discrimination and retaliation after he filed complaints against the Department with OSHA. The court held that the district court erred in holding that administrative exhaustion must be pleaded in the complaint. Rather, administrative exhaustion under Title VII was an affirmative defense. Accordingly, the court remanded for further proceedings. View "Hardaway v. Hartford Public Works Department" on Justia Law