Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's grant of summary judgment for Rock-Tenn in a civil rights action alleging religion and sex discrimination. The Eighth Circuit held that Title VII did not impose a legal obligation to provide an employee an articulated basis for dismissal at the time of firing, and an employer was certainly not bound as a matter of law to whatever reasons might have been provided; rather, it was well-established that a employer may elaborate on its explanation for an employment decision; and, in this case, there was no contradiction between the explanation given to plaintiff at the time of his termination and the non-discriminatory reasons for termination that Rock-Tenn articulated during this litigation. The court also held that plaintiff failed to show sufficient evidence that Rock-Tenn's proffered reasons for firing him -- poor performance -- were pretexts for discrimination. View "Rooney v. Rock-Tenn Converting Co." on Justia Law

Plaintiff-appellant, J. Brent Arave, brought several claims under the California Fair Employment and Housing Act (FEHA) against his former employers, Merrill Lynch, Pierce, Fenner & Smith, Inc. (Merrill Lynch), Bank of America (BoA), his supervisor Joseph Holsinger, and a human resources supervisor, Katherine Anderson (collectively, defendants). He sought to recover damages caused by discrimination, harassment, and retaliation based on his membership in the Church of Jesus Christ of Latter-day Saints. He also sought damages for nonpayment of wages, and whistleblower retaliation. A jury returned a verdict in favor of defendants on all counts that had survived summary judgment and dismissal. The trial court denied Arave’s post-trial motions and awarded defendants, as prevailing parties, costs, expert witness fees, and attorney fees incurred defending against Arave’s wage claim. Arave appealed, alleging numerous alleged evidentiary errors, issues with the trial court’s jury instructions, counsel misconduct, and related claims that he maintained, warranted reversal of the outcome against him. Defendants cross-appealed, contending the trial court abused its discretion when it determined Arave’s FEHA claims were not frivolous and denied them attorney fees on those claims. After careful consideration, the Court of Appeal affirmed the trial court in all respects but two. The Court concluded the trial court erred by awarding $83,642.68 in costs and expert witness fees though it found Arave’s FEHA claims were nonfrivolous, and therefore reversed the order making the award. However, because a portion of the award could be attributable to Arave’s wage claim, and the trial court erred by awarding $97,500 in attorney fees on the wage claim without determining whether that claim was frivolous, the matter was remanded for the trial court to make those apportionments, as appropriate. View "Arave v. Merrill Lynch, Pierce, etc." on Justia Law

A jury rejected an employment-discrimination claim against JetStream Ground Services, Inc. filed by several Muslim women and the Equal Employment Opportunity Commission (EEOC) who alleged that JetStream discriminated against the women on religious grounds by refusing to hire them because they wore hijabs. Plaintiffs’ sole argument on appeal was that the district court abused its discretion by refusing to impose a sanction on JetStream (either excluding evidence or instructing the jury that it must draw an adverse inference) because it disposed of records contrary to a federal regulation purportedly requiring their preservation. The Tenth Circuit found no abuse of discretion: plaintiffs’ argument that the exclusion sanction should have been applied was waived in their opening statement at trial. And the district court did not abuse its discretion in refusing to give an adverse-inference instruction after Plaintiffs conceded that destruction of the records was not in bad faith. View "EEOC v. JetStream Ground Services" on Justia Law

The Ninth Circuit affirmed the denial of defendant's renewed motion for judgment as a matter of law on a claim of disability discrimination under the Americans with Disabilities Act and Oregon state law and the grant in part of plaintiff's motion for an award of attorney's fees. The panel held that the district court's instructional error by conflating the elements of plaintiff's disparate treatment and failure to accommodate claim was harmless where it was more probable than not that the jury's verdict was not affected. The panel also held that, construed in the light most favorable to plaintiff, the evidence supported the jury's verdict. In this case, the record reflected that plaintiff satisfied her burden to prove the existence of reasonable accommodations that would enable her to perform the essential job functions of her position. Finally, the district court adequately explained and calculated the attorney fee award and did not abuse its discretion. View "Dunlap v. Liberty Mutual Products, Inc." on Justia Law

The Fifth Circuit reversed the district court's denial of summary judgment to the administrators of a university on their immunity defenses. Plaintiff filed suit alleging that he was deprived of his property interest in his job without due process and tortious interference with his employment contract. The court held that the district court erred in denying the administrators qualified immunity against the section 1983 claim because plaintiff did not have a clearly established property right. Furthermore, state law compelled a similar result on the tortious interference claim. Accordingly, the district court should have granted immunity to the administrators. View "Wilkerson v. University of North Texas" on Justia Law

The Eleventh Circuit reversed the district court's grant of summary judgment to defendants in an action alleging that plaintiff was unlawfully discharged from the police department based on disability and/or racial or gender discrimination. The court held that plaintiff's evidence was insufficient to meet her prima facie burden that she was actually disabled, but was sufficient on whether she was regarded as disabled. The court also held that the district court erred in holding that plaintiff failed to produce sufficient evidence that she was a qualified individual. The court reasoned that, in this case, there was significant evidence that cuts against Union City's contention that exposure to OC spray and Taser shocks were essential functions of the job of police detective. The court also held that plaintiff met her prima facie burden of demonstrating that the City discriminated against her because of her perceived disability. Plaintiff had produced sufficient evidence that she was not a direct threat, the differing treatment of plaintiff's white colleagues, in combination with the rest of the evidence, was part of a mosaic of circumstantial evidence sufficient to create a triable issue of material fact on whether the police department's actions were discriminatory on the basis of race and/or gender. Finally, the court rejected plaintiff's claim of municipal liability. View "Lewis v. Union City, Georgia" on Justia Law

Fallon was terminated by his employer, Mercy Catholic Medical Center, because he refused to be inoculated against flu. He opposed the vaccine because he believed that it might do more harm than good. Mercy required its employees to receive the vaccine unless they qualified for a medical or religious exemption. Fallon sought the exemption on religious grounds. Mercy ruled that he did not qualify and terminated him when he continued to refuse the vaccine. Fallon sued under Title VII of the Civil Rights Act, arguing that his termination constituted religious discrimination. The district court dismissed his case with prejudice because his beliefs, while sincere and strongly held, were not religious in nature. The court considered the full text of an essay that was partially quoted in Fallon’s complaint but not submitted in full until Mercy attached it to a reply brief with its motion to dismiss. The Third Circuit affirmed. Fallon’s beliefs do not occupy a place in his life similar to that occupied by a more traditional faith. His objection to vaccination is therefore not religious and not protected by Title VII. The court rejected Fallon’s argument that only the portions of the essay, which were quoted in the complaint, should have been considered. View "Fallon v. Mercy Catholic Medical Center" on Justia Law

The Seventh Circuit affirmed the district court's grant of summary judgment for Morgan Stanely in a civil rights action. Plaintiff alleged that she was terminated on the basis of her sex and that Morgan Stanley allowed her coworkers to create a hostile work environment. The court held that plaintiff was not entitled to a trial on her discrimination claim because she presented no evidence that her sex influenced the decision to terminate her and she presented no evidence of discrimination based on the cat's paw theory. The court also held that plaintiff was not entitled to a trial on her hostile work environment claim because the statute of limitations restricted the allegations that the court could consider as part of her claim and the remaining conduct did not create a hostile work environment. View "Milligan-Grimstad v. Morgan Stanley" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff’s complaint against the Federal Deposit Insurance Corporation challenging its decision to terminate his employment for lack of subject matter jurisdiction. The district court concluded that Plaintiff did not have a “mixed” case because of his failure to reinstate or prosecute his associational disability discrimination before the Merit Systems Protection Board, despite being given the right to do so, after expressly withdrawing the claim with prejudice. The First Circuit held (1) Plaintiff’s original complaint, which alleged a claim of discrimination that was later withdrawn, was not sufficient to create a mixed case, and therefore, the district court lacked subject matter jurisdiction; and (2) the district court did not err in denying Plaintiff’s motion for reconsideration or, in the alternative, to transfer the case to the Court of Appeals for the Federal Circuit. View "Jonson v. Federal Deposit Insurance Corp." on Justia Law

Plaintiff filed a pro se complaint in district court, alleging sex, race, and age discrimination in violation of Title VII of the Civil Rights Act and the Age Discrimination in Employment Act. The Eighth Circuit found that plaintiff likely adequately exhausted her remedies, and her pleadings indicated this prerequisite, especially on a motion to dismiss. Even if the lack of an initial verified charge would have indicated lack of exhaustion, the documents plaintiff supplied with her objections, including a copy of the verified charge mailed on July 28 and received by the EEOC, plus the Notice of Right to Sue, indicated she had cured any deficiency in the exhaustion requirements. Finally, the district court's failure to conduct a de novo review after plaintiff filed timely and specific objections was reversible error. Accordingly, the court reversed and remanded with directions to allow plaintiff to amend her pleadings. View "Rush v. Arkansas DWS" on Justia Law