Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the superior court granting judgment as a matter of law in favor of Defendants in this employment discrimination action.Plaintiff, a former employee of the Town of Lincoln School Department, filed a complaint against the Town of Lincoln, Lincoln School Committee, and the Town’s Finance Director, alleging that she was discriminated against because she advocated for education services for her disabled son, who was a student in the Lincoln school system. The case went to trial. After both sides rested, the trial justice granted Defendants’ motion for judgment as a matter of law. The Supreme Court affirmed, holding that Plaintiff failed to provide sufficient evidence such that a reasonable jury could find that Lincoln’s actions were retaliation for Plaintiff’s advocacy efforts for her son. View "Azar v. Town of Lincoln" on Justia Law

The First Circuit affirmed the district court’s grant of summary judgment in favor of the City of Quincy, Massachusetts, the former employer of Plaintiff, on Plaintiff’s federal and pendent state claims of employment discrimination, retaliation, and constructive discharge. The First Circuit held (1) because Plaintiff was unable to rebut the City’s proffered legitimate, nondiscriminatory basis for its actions with evidence of pretext and discriminatory motive; (2) the record lacked evidence showing that the City retaliated against Plaintiff; and (3) Plaintiff did not meet her burden to show she was constructively discharged. View "Cherkaoui v. City of Quincy, Massachusetts" on Justia Law

Marybeth Lauderdale served as acting superintendent and superintendent for the Illinois School for the Deaf (ISD), 2006-2010. During her last year as superintendent, she was paid a total of $88,048. Reggie Clinton was superintendent for the School for the Visually Impaired (ISVI), 1998-2003 and again, 2008-2010. When Clinton returned to ISVI in 2008, he received a 1.9% salary increase from his most recent salary at the Arcola School District. He was paid, at the end of his tenure at ISVI, $121,116 per year. After Clinton resigned, the Illinois Department of Human Services, which oversees ISD and ISVI, created one combined superintendent role to cover both schools and offered Lauderdale the role. Lauderdale wanted to be paid as much or more than Clinton had been paid but eventually accepted a salary of $106,500. Lauderdale sued, alleging sex discrimination under the Equal Pay Act, Title VII of the Civil Rights Act of 1964, and 42 U.S.C. 1983. The district court concluded no reasonable juror could find the pay discrepancy was a product of sex discrimination and that the discrepancy resulted from budget concerns and from the application of the Illinois Pay Plan. The Seventh Circuit affirmed, agreeing that the record indicated that the pay discrepancy was not based on sex. View "Lauderdale v. Illinois Department of Human Services" on Justia Law

Marybeth Lauderdale served as acting superintendent and superintendent for the Illinois School for the Deaf (ISD), 2006-2010. During her last year as superintendent, she was paid a total of $88,048. Reggie Clinton was superintendent for the School for the Visually Impaired (ISVI), 1998-2003 and again, 2008-2010. When Clinton returned to ISVI in 2008, he received a 1.9% salary increase from his most recent salary at the Arcola School District. He was paid, at the end of his tenure at ISVI, $121,116 per year. After Clinton resigned, the Illinois Department of Human Services, which oversees ISD and ISVI, created one combined superintendent role to cover both schools and offered Lauderdale the role. Lauderdale wanted to be paid as much or more than Clinton had been paid but eventually accepted a salary of $106,500. Lauderdale sued, alleging sex discrimination under the Equal Pay Act, Title VII of the Civil Rights Act of 1964, and 42 U.S.C. 1983. The district court concluded no reasonable juror could find the pay discrepancy was a product of sex discrimination and that the discrepancy resulted from budget concerns and from the application of the Illinois Pay Plan. The Seventh Circuit affirmed, agreeing that the record indicated that the pay discrepancy was not based on sex. View "Lauderdale v. Illinois Department of Human Services" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment for Defendants in this action filed by Plaintiff claiming that Defendants discriminated against her based on her gender and sexual preference and exposed her to a hostile work environment and retaliation in violation of Title VII of the Civil Rights Act of 1964 and various provisions of Puerto Rico law. The district court ultimately dismissed all of the claims. On appeal, Plaintiff argued that the district court erred in concluding that Plaintiff failed to show a genuine factual dispute as to whether she experienced a hostile work environment based on gender and retaliatory motivation and erred in finding those claims to be untimely. The Supreme Court affirmed the grant of summary judgment for Defendants on Plaintiff’s hostile work environment claims under both federal and Commonwealth law, holding that Plaintiff failed to meet her burden to produce competent evidence showing that any of the work conditions she encountered within the statute of limitations period amounted to harassment on the basis of the improper motivations she alleged. View "Maldonado-Catala v. Municipality of Naranjito" on Justia Law

Golla, who has a law degree, alleged, under the Civil Rights Act, 42 U.S.C. 2000e-2(a)(1) and 42 U.S.C. 1983, that the Office of the Chief Judge engaged in intentional reverse racial discrimination by paying Taylor, an African‐American male, a significantly higher salary than Golla, a white male, despite working in the same department and performing the same duties under essentially the same title. Golla started working in the Office in 1983. He was fired in 1995 but reinstated 10 months after he filed a complaint with the EEOC. Under a settlement agreement, Golla was reinstated at a pay position and title, Law Clerk I, which he retained until he resigned in 2013. When asked during his deposition whether anyone in the workplace made racial comments toward him, Golla answered, "nothing direct racial." He claimed his African-American supervisor made comments that were demeaning. The district court rejected Golla’s claim, finding no direct evidence of reverse racial discrimination that resulted in the pay disparity and that Golla failed to establish a prima facie case of reverse racial discrimination under the indirect method of proof. The Seventh Circuit affirmed. The evidence as a whole was insufficient for a reasonable jury to conclude that Golla was paid at a lower pay grade than Taylor because of his race View "Golla v. Office of the Chief Judge of Cook County" on Justia Law

A question of Washington law was certified to the Washington Supreme Court on whether prospective employers are free to engage in retaliatory discrimination in the hiring process. Waterville School District No. 209 hired Jin Zhu as a math teacher in 2006. In 2010, Waterville issued a notice of probable cause for Zhu's discharge, which he appealed. The hearing officer determined that there was not probable cause for discharge and restored Zhu to his position. Zhu then sued Waterville in federal district court, alleging that Waterville had subjected him to racially motivated disparate treatment, a hostile work environment, and retaliation in violation of 42 U.S.C. sections 1983, 2000e-2, and 2000e-3. His complaint alleged that he filed multiple grievances with Waterville regarding hostile and abusive actions by his students; instead of attempting to remedy the situation, Zhu alleged Waterville took retaliatory actions against him for filing the grievances, including attempting to discharge him without probable cause. After the district court denied Waterville's motion for summary judgment dismissal, the parties settled and Zhu resigned from Waterville in March 2012. Three months after resigning from Waterville, Zhu applied for a position as a "Math-Science Specialist" with ESD 171. Zhu was one of three candidates interviewed, but ESD 171 ultimately hired a different candidate, whom Zhu claims was far less qualified for the position. Zhu sued ESD 171 in federal district court, alleging that it refused to hire him in retaliation for his prior lawsuit against Waterville, thereby violating WLAD's antiretaliation statute, RCW 49.60.210(1), as well as other state and federal laws. The Washington Supreme Court held that in accordance with the plain language of the Washington Law Against Discrimination (WLAD), chapter 49.60 RCW, retaliatory discrimination against job applicants by prospective employers was prohibited. Therefore, plaintiff Jin Zhu's claim that defendant North Central Educational Service District - ESD 171 (ESD 171) refused to hire him because of his opposition to his former employer's racial discrimination stated a valid cause of action. View "Zhu v. N. Cent. Educ. Serv. District" on Justia Law

Defendant James Woods, a detective in the Cottonwood Heights Police Department, was informed by Utah’s Unified Fire Authority (“UFA”) that medications, including opioids and sedatives, were missing from several UFA ambulances. Detective Woods accessed a state database and searched the prescription drug records of 480 UFA employees in an effort to “develop suspect leads of those who have the appearance of Opioid dependencies.” Consistent with Utah law at the time, Woods did not obtain a search warrant before accessing the Database. Based on the information Woods obtained from the Database search, he developed suspicions about Plaintiffs Ryan Pyle and Marlon Jones. Neither Plaintiff, however, was ever prosecuted for the thefts from the ambulances. Plaintiffs brought separate lawsuits pursuant to 42 U.S.C. 1983, each challenging Defendants’ conduct as violative of the Fourth Amendment and the Fair Credit Reporting Act (“FCRA”). In both suits, the district court dismissed the claims against Defendant Woods, concluding Woods was entitled to qualified immunity because the law governing warrantless access to prescription drug information by law enforcement was not clearly established. The district court also dismissed the FCRA claims because Defendants’ actions fit within an exemption set out in the Act. In Jones’s suit, the district court dismissed the constitutional claims against the city of Cottonwood Heights with prejudice because Jones’s complaint failed to state a claim for municipal liability plausible on its face. In Pyle’s suit, the district court dismissed the constitutional claims against Cottonwood Heights without prejudice, concluding Pyle failed to notify the Utah Attorney General of those claims as required by Rule 5.1 of the Federal Rules of Civil Procedure. Pyle and Jones each appealed. Exercising jurisdiction pursuant to 28 U.S.C. 1291, and finding no reversible error, the Tenth Circuit Court of Appeals affirmed the district court’s judgments. View "Pyle v. Woods" on Justia Law

In this civil rights action brought of a Town of Hull police officer, the First Circuit affirmed the dismissal of Plaintiff’s 42 U.S.C. 1983 claim, affirmed the district court’s holding that Plaintiff’s Mass. Gen. Laws ch. 149, 185(b)(3) claim was waived, and vacated the entry of summary judgment as to Plaintiff’s state claim under Mass. Gen. Laws ch. 149, 185(b)(1) and directed the district court to dismiss this claim without prejudice.When Plaintiff, a decade-long veteran of the police department, was passed over for a promotion, he brought suit alleging that the Town of Hull and its then chief of police alleging that Defendants intentionally let his application lapse and did not promote him, in retaliation for exposing the police chief’s professional misconduct. The district court granted summary judgment for the Town. The First Circuit largely affirmed, holding (1) the district court correctly held that Plaintiff failed to raise a genuine dispute as to whether the Town’s Board of Selectmen ratified the alleged retaliation; (2) Plaintiff waived his section 185(b)(3) claim; and (3) the court declines to exercise jurisdiction over Plaintiff’s remaining state law claim based on section 185(b)(1) of the Massachusetts Whistleblower Act. View "Saunders v. Town of Hull" on Justia Law

The Fifth Circuit treated plaintiff's petition for rehearing en banc as a petition for panel rehearing and denied the petition for panel rehearing. The court withdrew its prior opinion and substituted the following opinion.The court affirmed the district court's grant of summary judgment against plaintiff on his failure to accommodate and hostile work environment claims. The court held that plaintiff's failure to accommodate claim could reasonably be expected to, and in fact did, grow out of his charge of discrimination; there was insufficient evidence to prove defendants' knowledge of plaintiff's disability where defendants did not attribute plaintiff's limitation -- sensitivity to noise -- to a physical or mental impairment; a jury could find that the harassment plaintiff experienced was sufficiently severe or pervasive to alter the terms and conditions of his employment; but, because plaintiff did not challenge on appeal the district court's determination that he unreasonably failed to avail himself of the procedures set forth in the anti-harassment policies maintained by defendants, he forfeited his objection to this determination. View "Patton v. Jacobs Engineering Group" on Justia Law