Justia Civil Rights Opinion Summaries

Plaintiff, a black nurse who was disciplined and ultimately fired by her employer, Public Health Trust of Miami-Dade County—appealed the district court’s entry of summary judgment on her Title VII and state-law claims alleging (1) employment discrimination, (2) hostile work environment, and (3) retaliation. Harris contends that the district court erred in rejecting all three claims.   The Eleventh Circuit affirmed. The court wrote that Public Health Trust says that several incidents that occurred at Jackson Reeves shouldn’t be considered because they weren’t caused by Plaintiff’s race. The court wrote that it agreed with Public Health Trust that three of the incidents weren’t caused by Harris’s race and, accordingly, shouldn’t be considered as part of the hostile-work-environment calculus. Further, the court reasoned that even considering Plaintiff’s limited evidence in the light most favorable to her, these are not, given the totality of the circumstances, sufficiently severe or pervasive to alter the terms and conditions of her employment and create an abusive working environment. View "Mary E. Harris v. The Public Health Trust of Miami-Dade County" on Justia Law

Plaintiff resigned from her tenured professorship at the Thurgood Marshall School of Law at Texas Southern University (TSU) in August 2020. She then sued TSU and several TSU employees for Title VII constructive discharge, Equal Pay Act (EPA) retaliation, and civil rights violations under 42 U.S.C. Section 1983. The district court dismissed all her claims, holding that res judicata barred her Section 1983 claims and that she failed to state Title VII and EPA claims.   The Ffith Circuit affirmed. The court wrote that Plaintiff alleges that TSU investigated her for discrimination but found no evidence that Plaintiff discriminated, that defendant “threw her hair into Plaintiff’s face in the law school lobby,” and that defendant yelled at Plaintiff that she couldn’t park in a church parking lot. But no facts suggest that these were more than personal disputes between the parties. Indeed, their parking lot confrontation was not even on school property. Plaintiff also alleges that defendant “has made comments about [her] race,” but she does not identify the comments or their context. The court explained that Plaintiff does not allege conduct by TSU that plausibly—not just possibly—states a constructive discharge claim. Further, the court held that Plaintiff fails to allege that Defendant acted under color of state law and thus fails to state a Section 1983 claim. View "Sacks v. Texas Southern University" on Justia Law

Petitioner was employed at Office Depot as a senior financial analyst. He was responsible for, among other things, ensuring data integrity. One of Ronnie’s principal duties was to calculate and report a metric called “Sales Lift.” Sales Lift is a metric designed to quantify the cost-reduction benefit of closing redundant retail stores. Petitioner identified two potential accounting errors that he believed signaled securities fraud related to the Sales Lift. Petitioner alleged that after he reported the issue, his relationship with his boss became strained. Eventually, Petitioner was terminated at that meeting for failing to perform the task of identifying the cause of the data discrepancy. Petitioner filed complaint with the Department of Labor’s Occupational Safety and Health Administration (OSHA), and OSHA dismissed his complaint. Petitioner petitioned for review of the ARB’s decision.
The Eleventh Circuit denied the petition. The court explained that Petitioner failed to allege sufficient facts to establish that a reasonable person with his training and experience would believe this conduct constituted a SOX violation, the ARB’s decision was not arbitrary or capricious, an abuse of discretion, or otherwise not in accordance with the law. The court wrote that Petitioner’s assertions that Office Depot intentionally manipulated sales data and that his assigned task of investigating the discrepancy was a stalling tactic are mere speculation, which alone is not enough to create a genuine issue of fact as to the objective reasonableness of Petitioner’s belief. View "Chris Ronnie v. U.S. Department of Labor" on Justia Law

Plaintiff is a black female educator and school administrator who works for the Brookhaven School District (the “School District”). Plaintiff sought to attend the Mississippi School Board Association Prospective Superintendent’s Leadership Academy, a training program for prospective superintendents. According to Plaintiff, the School District “established a precedent of paying for every employee’s fees after the employee was accepted to attend the program.” Plaintiff asked the Deputy Superintendent, if the School District would pay for her to attend the Leadership Academy. Once the program accepted Plaintiff, the School District’s Superintendent reneged and refused to pay for her to attend at that time. But Plaintiff’s spot was for the upcoming class, so she paid the fees herself. Plaintiff sued, alleging that the School District violated Title VII and 42 U.S.C. Section 1981 by refusing to pay for her to attend the Leadership Academy but agreeing to pay for similarly situated white males to attend. The district court dismissed Plaintiff’s claims under Federal Rule of Civil Procedure 12(c).   The Fifth Circuit reversed. The court held that Plaintiff set forth a plausible Title VII claim under Rule 12 because plausibly alleged facts that satisfy both adverse employment action prongs and the adverse employment action element was the only element in dispute. The court explained, taking Plaintiff’s allegations as true—that the School District (1) agreed to pay for similarly situated white males’ fees to attend the Leadership Academy; (2) promised to pay her fees (a promise she relied on); and (3) reneged on that promise—Plaintiff plausibly stated a Title VII disparate treatment claim. View "Harrison v. Brookhaven Sch Dist" on Justia Law

Plaintiff was hired as a Law Enforcement Officer by the Sisseton, South Dakota, Police Department. Plaintiff and the City signed a Sisseton Police Department Employment Contract (the “Contract”) requiring Plaintiff to reimburse the City for the cost of her training if she left the Department before completing 36 months of employment. In January 2022, Defendant, the City’s Chief of Police, informed Plaintiff that the Police Commission had lost confidence in her, and Defendant asked Plaintiff to resign, which she did. Plaintiff filed this 42 U.S.C. Section 1983 action, asserting, along with other claims, that the City and numerous individual defendants violated her Fourteenth Amendment procedural and substantive due process rights. The district court granted Defendants’ motion. Plaintiff appealed only the dismissal of her due process claims.   The Eighth Circuit affirmed. The court agreed with the district court the Supreme Court of South Dakota would rule that the Contract did not change an at-will employment relationship. The court explained that for Plaintiff’s claim against the City to survive a motion to dismiss, her complaint must contain “enough facts to state a claim to relief that is plausible on its face.” The court agreed with the district court that the Complaint “failed to allege any unconstitutional policy or custom that enabled” Defendants to deprive Plaintiff of her alleged federal due process rights. Counsel for Plaintiff could only respond that the Complaint plausibly alleged the practice of violating the three-year term in the City’s employee reimbursement contracts. That practice was not alleged in the Complaint and, in any event, is nothing more than a “facially lawful municipal action.” View "Samantha LaCoe v. City of Sisseton" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the determination of the district court that the underlying First Amendment retaliation claim brought under 42 U.S.C. 1983 was time-barred, holding that the continuing violation doctrine did not apply to toll the statute of limitations.Plaintiff brought this action alleging that Defendant, the City of Duluth, retaliated against him in violation of his rights under the First Amendment by making false statements and engaging in other negative conduct toward him. In dismissing the claim, the trial court rejected Plaintiff's reliance on the continuing violation doctrine. The court of appeals reversed and reinstated Plaintiff's section 1983 retaliation claim against the City, concluding that the continuing violation doctrine did not apply because the acts Plaintiff alleged as retaliation were discrete acts that were actionable when committed and therefore did not constitute a continuing violation that tolled the statute of limitations. The Supreme Court affirmed, holding that the continuing violation doctrine did not apply in this case. View "Ringsred v. City of Duluth" on Justia Law

Plaintiff-appellee Gary Waetzig filed an age discrimination lawsuit against his former employer, Halliburton Energy Services, Inc. Because he was contractually bound to arbitrate his claim, he voluntarily dismissed his suit without prejudice under Federal Rule of Civil Procedure 41(a) and filed for arbitration. The arbitrator sided with Halliburton. Dissatisfied with the outcome, Waetzig returned to federal court. But instead of filing a new lawsuit challenging arbitration, he moved to reopen his age discrimination case and vacate the arbitration award. Relying on Rule 60(b), the district court concluded it had jurisdiction to consider Waetzig’s motion, reopened the case, and vacated the award. The Tenth Circuit found the district court erred: the district court could not reopen the case under Rule 60(b) after it had been voluntarily dismissed without prejudice. Under Federal Rules of Civil Procedure 41(a) and 60(b), a court cannot set aside a voluntary dismissal without prejudice because it is not a final judgment, order, or proceeding. View "Waetzig v. Halliburton Energy Services" on Justia Law

Plaintiff was the Chief Meteorologist at CBS46, an Atlanta news station. But during his tenure, female colleagues raised repeated complaints that he engaged in inappropriate conduct and sexual harassment—including “compliments” about appearance, sexually charged language, requests for nude photos, and more. Plaintiff, who is white, alleges that he was terminated because of his race in violation of 42 U.S.C. Section 1981. The sexual harassment justification, he says, was just a pretext. The district court granted summary judgment to Defendants.   The Eleventh Circuit affirmed. The court wrote that the ultimate question in any discrimination case is whether the defendant intentionally discriminated against the plaintiff based on race. Here, Plaintiff failed to show that a reasonable jury could conclude that Defendant terminated his employment because he was white.   The court explained that Plaintiff notes that the station’s new meteorologist is a Hispanic woman. However, Plaintiff mostly argued that the existence of race data on the corporate form meant that he was fired because he was white. The court explained Plaintiff lacked direct evidence of discrimination, he lacked evidence that Defendant treated his race as a factor favoring his termination, and he lacked evidence that Defendant treated similarly situated non-white employees more favorably. On the other hand, Defendant has produced extensive evidence of Plaintiff’s sexual harassment, which is a valid, nondiscriminatory reason for his termination. The court explained that on this record, no reasonable jury could infer that Defendant’s justification was pretext for race discrimination. View "Paul Ossmann v. Meredith Corporation" on Justia Law

Gnutek alleged that he was unlawfully terminated from his position as a Gaming Senior Special Agent with the Illinois Gaming Board in violation of Title VII, the First Amendment under 42 U.S.C. 1983, and the Illinois Ethics Act. His termination followed his arrest after Gnutek assaulted another driver. The district court dismissed the Illinois Ethics Act claims against the Board and individual defendants in their official capacities. Gnutek voluntarily dismissed the claims against two individual defendants. The district court then granted summary judgment in favor of the Board and three other individuals on the remaining claims.The Seventh Circuit affirmed. Other than the fact that he has previously engaged in prior litigation against the defendants, Gnutek presented no evidence from which a trier of fact could infer that his termination was retaliatory nor did he establish that he was treated less favorably than similarly situated individuals. View "Gnutek v. Illinois Gaming Board" on Justia Law

A school bus driver filed an action under 42 U.S.C. Section 1983 against two public-sector unions and her employer, the New Hartford Central School District, alleging that their continued deduction of union fees from her paycheck following her resignation from both unions violated her First and Fourteenth Amendment rights under Janus v. Am. Fed’n of State, Cnty., and Mun. Emps., Council 31, 138 S. Ct. 2448 (2018). She appealed the dismissal of her claims, arguing that the district court erred by prematurely dismissing her claims against the unions for, among other things, failing to adequately plead state action.   The Second Circuit affirmed. The court concluded that because Appellant voluntarily became a union member and affirmatively agreed to pay union dues through payroll deductions for a set period, the district court properly dismissed her claims. The court explained that New York’s Taylor Law guarantees public employees the right to choose whether to join the union as members, N.Y. Civ. Serv. Law Section 202 and prohibits any union or public employer from “interfering with, restraining or coercing public employees in the exercise of their rights.” Here,  it is undisputed that Appellant voluntarily joined the Unions and authorized dues deductions from her wages when she signed the Membership Agreement in 2018. View "Wheatley v. New York State United Teachers, et al." on Justia Law