Justia Civil Rights Opinion Summaries

This case concerned three retirement plans established by the Montana Legislature under the Montana Public Employee Retirement System (PERS). Plaintiffs, who elected to participate in the Defined Contribution Retirement Plan (DC Plan) and Montana University System Retirement Plan (University Plan), filed suit against the State and PERS, alleging that they were treated unequally from similarly-situated participants in the Defined Benefit Retirement Plan (DB Plan) and that requiring State employers of DC and University Plan participants to contribute to the trust that funds the retirement benefits of all DB Plan participants (DB Trust) violates Plaintiffs’ substantive due process rights. The district court granted summary judgment to Defendants, concluding (1) participants in the DB Plan, DC Plan, and University Plan are not members of similarly situated classes under an equal protection analysis, and (2) employer contributions to the DB Trust that are calculated based on the salaries of DC and University Plan participants do not violate substantive due process. The Supreme Court affirmed, holding that the district court did not err in its judgment. View "Wrzesien v. Mont. Pub. Employee Ret. Admin." on Justia Law

Cole, an African-American has worked for Northern Illinois University in the Building Services Department since 1998. He alleges that beginning with his 2009 promotion to sub-foreman, he experienced race discrimination, retaliation, and a hostile work environment, including the discovery of a hangman’s noose in his workspace. In 2011, he was again promoted. Cole was the only African-American sub-foreman or foreman. He believed that others with the same title were paid more or given more authority and that he was the subject of surveillance. In 2012, Cole filed an ethics complaint with the university about various alleged unethical practices. Cole was later demoted and twice subjected to discipline. He sued, asserting violations of Title VII of the Civil Rights Act, 42 U.S.C. 2000e, and the Equal Protection Clause. The Seventh Circuit affirmed summary judgment in favor of the defendants. The hostile work environment claim presented the closest question, but Cole did not show a basis for employer liability for the alleged harassment. Cole did not offer evidence that would allow a reasonable trier of fact to find that he was subjected to disparate treatment based on his race. His retaliation claim failed because he offered no evidence that he engaged in protected activity. View "Cole v. Bd. of Trs. of N. Ill. Univ." on Justia Law

Plaintiff, a trooper with the Nebraska State Patrol, was an applicant for a lateral transfer to the position of “Executive Protection Trooper.” After another applicant was awarded the position, Plaintiff filed a public records request under Neb. Rev. Stat. 84-712 seeking records relating to the interview and selection process for the Executive Protection Trooper position. The State Patrol denied Plaintiff’s request. Plaintiff sought a writ of mandamus in the district court again seeking the records that were the subject of his public records request. The trial court denied Plaintiff’s petition, concluding that the records could be withheld under section 84-712.05(7). The Supreme Court affirmed, holding that the district court did not err in denying Plaintiff’s petition for writ of mandamus because the records Plaintiff sought to view were exempted under section 84-712.05(7). View "Steckelberg v. Nebraska State Patrol" on Justia Law

Plaintiff, the City's former chief of police, filed a First Amendment retaliation suit alleging that he was terminated for suing the mayor. The district court granted summary judgment for the City. The court concluded that although plaintiff spoke as a citizen, his suit against the mayor in his personal capacity was not on a matter of public concern and thus was not protected speech. The court also concluded that plaintiff's state-law claim of malicious interference with employment (MIE) against the mayor is barred because plaintiff failed to bring notice of the claim before suing as required by state law. View "Gibson v. Kilpatrick" on Justia Law

Ernst and four other women, all experienced paramedics from public and private providers of emergency medical services, sought employment as paramedics with the Chicago Fire Department. All five women were denied jobs because they failed Chicago’s physical-skills entrance exam. The test had first been implemented in 2000 and had a disparate impact on women. The five filed a Title VII gender-discrimination lawsuit against the city, arguing that Chicago had a discriminatory motive against women and that that improper statistical methods were used to establish the skills test. Both arguments were unsuccessful. The Seventh Circuit reversed and remanded. On the disparate impact claims, the jury should have been instructed on the plaintiffs’ burden of proving that Chicago was motivated by anti-female bias, when it created the exam that; instead, jurors were instructed on a different burden, which failed to address Chicago’s motive for creating the test. The physical-skills study was neither reliable nor validated under federal law; the skills that Chicago paramedics learn on the job are different than what was tested. Even if they were the same, the physical-skills entrance exam is significantly more difficult than the actual job workers perform. View "Ernst v. City of Chicago" on Justia Law

After the City terminated plaintiff, he filed suit alleging disability discrimination claims. The district court granted summary judgment to the City. The court concluded that the district court correctly held that plaintiff failed to raise an issue of material fact as to whether the City terminated him because of his disability where there is no evidence that the City’s reliance on his history of misconduct and poor performance was pretextual or blended with discriminatory motives. The court saw no basis for concluding that the City failed to engage in good faith by not finding him a new position after he had shown no desire to try and succeed in the first position. The court concluded that, given the undisputed evidence that plaintiff did not make an honest attempt to succeed in the new position, he cannot make out a claim placing blame for the breakdown in the accommodation process on the City. Accordingly, the court affirmed the judgment. View "Dillard v. City of Austin" on Justia Law

The EEOC filed suit against CMS, alleging that the company's conduct discriminated on the basis of a black job applicant's race in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2(a)(1) & 2000e-2(m). When the applicant said that she would not cut her dreadlocks, she was told by a CMS human resources manager that the company would not hire her. The district court dismissed because the complaint did not plausibly allege intentional racial discrimination by CMS against the applicant. The court concluded that the EEOC conflates the distinct Title VII theories of disparate treatment (the sole theory on which it is proceeding) and disparate impact (the theory it has expressly disclaimed); the court's precedent holds that Title VII prohibits discrimination based on immutable traits, and the proposed amended complaint does not assert that dreadlocks - though culturally associated with race - are an immutable characteristic of black persons; the court is not persuaded by the guidance in the EEOC’s Compliance Manual because it conflicts with the position taken by the EEOC in an earlier administrative appeal, and because the EEOC has not offered any explanation for its change in course; and no court has accepted the EEOC’s view of Title VII in a scenario like this one, and the allegations in the proposed amended complaint do not set out a plausible claim that CMS intentionally discriminated against the applicant on the basis of her race. Accordingly, the court affirmed the judgment. View "EEOC v. Catastrophe Mgmt. Solutions" on Justia Law

After plaintiff was terminated from her job at ABM, she filed suit against her former employer, alleging that she was unlawfully terminated based on age in violation of the Minnesota Human Rights Act, Minn. Stat. 363A.08. The court concluded that, viewing the evidence in the light most favorable to plaintiff, the district court did not err in granting summary judgment to ABM. In this case, plaintiff did not meet her burden of establishing a genuine issue of material fact that ABM’s proffered legitimate reason for her termination was pretext for age discrimination. View "Haggenmiller v. ABM Parking Serv." on Justia Law

Mancini, a former Northampton County, Pennsylvania assistant county solicitor, filed a 42 U.S.C. 1983 action against Northampton County, County Executive Brown, and County Solicitor Scomillio, in connection with their termination of her employment. Mancini, a Democrat, alleged that she was a protected career service employee and that the newly elected Republican administration wrongfully dismissed her in violation of the Fourteenth Amendment Due Process Clause and the First Amendment. The elimination of her position was the only ground Northampton provided for Mancini’s dismissal. Although the county held an informal hearing on her grievance after her termination, no decision was ever announced. A jury found that Northampton County, but not Brown or Scomillio, violated Mancini’s procedural due process rights and awarded her $94,232 in damages. The Third Circuit affirmed. A claimed “reorganization exception” to the constitutional procedural due process requirement cannot apply, as a matter of law, if there is a genuine factual dispute about whether the reorganization was a pretext for an unlawful termination. Northampton did not provide Mancini the meaningful process she was due and the jury could have reasonably concluded that the reorganization of the Solicitor’s Office was a pretext for unlawfully terminating Mancini. View "Mancini v. Northampton County" on Justia Law

Plaintiff filed suit against Trigg seeking rescission of the settlement agreement in Suarez I based on Trigg’s fraudulent concealment of the prospects for sale of the company, and quantum meruit. Trigg filed a special motion to strike pursuant to the anti-SLAPP statute, Civil Procedure section 425.16, asserting that plaintiff's claims arise out of communications that occurred during the course of Suarez I. The trial court dismissed the action without leave to amend. The court agreed with the trial court's finding that plaintiff's causes of action arose from litigation activities protected by the anti-SLAPP statute - the right of free speech - and that he failed to make a showing of likelihood of success on the merits. Accordingly, the court affirmed the judgment. View "Suarez v. Trigg Labs." on Justia Law