Justia Civil Rights Opinion Summaries

Plaintiff’s employment as a deputy sheriff was terminated following the reelection of Defendant to the office of Sheriff of Mecklenburg County. Plaintiff filed suit alleging wrongful termination in violation of N.C. Gen. Stat. 153A-99 and N.C. Const. art. I, 14 and 36. The trial court granted summary judgment in favor of Defendants. The Court of Appeals affirmed, concluding that Plaintiff could not establish a claim for wrongful termination in violation of section 153A-99 and that Plaintiff’s state constitutional claims lacked merit. The Supreme Court affirmed, holding (1) Plaintiff was not a county employee as defined in section 153A-99, and therefore, Plaintiff was not entitled to the protections provided in that statute; and (2) Defendant’s actions did not violate Plaintiff’s right to freedom of speech. View "Young v. Bailey" on Justia Law

After Plaintiff was terminated from her employment with Puerto Rico’s Vocational Rehabilitation Administration, she filed a federal-court suit alleging that Defendants discriminated against her because of her disability, age, and politics. Plaintiff’s complaint alleged various violations of federal and local law. The district court dismissed Plaintiff’s 42 U.S.C. 1983 claim for failure to exhaust administrative remedies and then dismissed the remaining claims without explanation. The First Circuit affirmed the district court’s judgment in every respect, except that the Court reversed the dismissal of Plaintiff’s Americans with Disabilities Act (ADA) claim, holding (1) the district judge erred in concluding that Plaintiff’s section 1983 claim was barred for failure to exhaust administrative remedies, but Plaintiff’s section 1983 was time-barred; (2) because Defendants agreed that Plaintiff’s ADA claim should not have been dismissed on failure-to-exhaust grounds, the reversal is dismissed; (3) Plaintiff’s age discrimination claim was correctly dismissed for failure to exhaust; and (4) because the dismissal of the ADA claim is reversed, the judge on remand must reinstate the local-law claims as well. View "Martinez-Rivera v. Commonwealth of P.R." on Justia Law

Plaintiff filed suit against her former employer, alleging that it violated Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e(k), by terminating her employment because she was pregnant. Plaintiff also alleged that the employer violated the Fair Labor Standards Act (FLSA), 29 U.S.C. 207(a), by failing to pay her overtime. The district court entered judgment in favor of the employer. The court affirmed the judgment as to the FLSA claim, concluding that the district court did not clearly err in holding that the employer did not have notice, whether actual or constructive, that plaintiff was working overtime during the period at issue. The court also affirmed as to the Title VII claim, concluding that the employer was entitled to judgment as a matter of law after it established legitimate, nondiscriminatory reasons for plaintiff's termination. In this case, the record demonstrated that plaintiff had a contentious relationship with her manager, she caused problems regarding store morale and customer service, and she repeatedly had performance-related problems. View "Fairchild v. All American Check Cashing, Inc." on Justia Law

Sedgwick is a claims management services company. Bagwe, who was born in India, began working in Sedgwick’s Chicago office in 2001. She was promoted to Assistant Manager II in 2005. She was asked to serve as Interim Operations Manager in 2007 and was promoted to Operations Manager. A Managing Director made the promotion decision. Bagwe’s direct supervisor, counseled against promoting Bagwe, indicating that Bagwe had poor leadership skills and had not provided sufficient direction to subordinates. In the following months, one of Bagwe’s subordinates asked to be reassigned; Bagwe repeatedly complained about her compensation; Bagwe had confrontations with and made accusations against coworkers; and Bagwe was the subject of performance improvement plan. In 2009 she was terminated with statements that she had a “continuing lack of trust” that had “become a distraction to the business.” Her replacement was a white, American male. Bagwe filed claims under the Civil Rights Act, 42 U.S.C. 1981, Title VII of the Civil Rights Act, 42 U.S.C. 2000e, and the Illinois Human Rights Act, claiming that Sedgwick had paid her a comparatively low salary because of her race and national origin and that she was terminated for retaliatory and racially discriminatory reasons. The Seventh Circuit affirmed summary judgment for the defendants, noting that Bagwe had not identified a similarly-situated employee who was paid more. View "Bagwe v. Sedgwick Claims Mgmt. Servs., Inc." on Justia Law

Plaintiff filed this action alleging that she was stripped of various job duties and eventually terminated from her job at the Puerto Rico Highway and Transportation Authority due to her affiliation with the Popular Democratic Party. The district court granted summary judgment in favor of Defendants on Plaintiff’s First Amendment political discrimination claims, concluding that there was insufficient evidence that the stripping of Plaintiff’s job functions constituted adverse employment actions, and absent any political discrimination, Plaintiff would have in any event been terminated for nondiscriminatory reasons. The First Circuit reversed, holding (1) Plaintiff made out a prima facie case of political discrimination; and (2) a genuine dispute existed as to whether Defendants would have fired Plaintiff regardless of her political affiliation. Remanded. View "Reyes-Orta v. P. R. Highway and Transp. Auth." on Justia Law

Plaintiff, a white man, filed suit against officials of the St. Louis Police Department, alleging race discrimination and conspiracy to discriminate when an African-American woman was chosen for the position in which plaintiff applied. A jury found in favor of plaintiff on his claims against three of his superiors (Defendants Muxo, Harris, and Isom). Defendants appealed. The court concluded that materially different working conditions provided sufficient evidence to support the conclusion that plaintiff suffered an adverse employment action. Because there were “probative facts to support the verdict,” the district court did not err by denying defendants' motion for judgment as a matter of law on plaintiff’s discrimination claims. The court also concluded that a reasonable jury could find evidence of a conspiracy to deprive plaintiff of his constitutional claims. Accordingly, the court affirmed the judgment. View "Bonenberger v. St. Louis Metro. Police Dept." on Justia Law

The Vermont Human Rights Commission and three female employees of the Vermont Department of Corrections (DOC) filed suit against the State (the DOC and the Vermont Department of Human Resources (DHR)) claiming that the DOC violated the Vermont Fair Employment Practices Act (VFEPA) by paying a male employee in the same position as the female plaintiffs as much as $10,000 more annually without a legally defensible, gender-neutral reason. The trial court granted summary judgment to the State, concluding that although plaintiffs established a prima facie case, the undisputed facts established that the wage disparity was due to legitimate business reasons and not gender-based. After review, the Supreme Court found no reversible error and affirmed dismissal of plaintiffs' case. View "Vermont Human Rights Comm'n v. Vermont" on Justia Law

Plaintiff filed suit under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., against JFS after JFS revoked its employment offer for a field engineer position at a mining site after learning that plaintiff had a rotator cuff impairment that prevented him from lifting his right arm above the shoulder. The district court granted summary judgment in favor of JFS. The court concluded that the district court's finding that plaintiff could not prove that he was disabled or a qualified individual was erroneous becuase it ignored Congress's expansion of the definition of disability when it amended the ADA in 2008. Under this more relaxed standard, the court concluded that evidence exists supporting a finding either that plaintiff is disabled or was regarded as disabled. Because a factual dispute exists on these issues, the court reversed the district court's grant of summary judgment and remanded. View "Cannon v. Jacobs Field Servs." on Justia Law

Jaburek, a woman of Mexican descent, began working for the Federal Aviation Administration (FAA) at its Des Plaines, Illinois, office in 1987. After various promotions and raises, followed by reassignment to her earlier position, there was a dispute about her responsibilities. She filed suit, alleging that the FAA paid her less than other employees who did the same work that she did but did not share her protected class status, and that the FAA retaliated against her for complaining about such discrimination, asserting: failure to promote in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e.; violation of the Equal Pay Act, 29 U.S.C. 206(d); and a Title VII retaliation claim. The Seventh Circuit affirmed summary judgment in favor of the FAA, stating that Jaburek failed to produce the necessary evidence to establish prima facie claims for any of her causes of action. View "Jaburek v. Foxx" on Justia Law

In 2000, Kubiak, a Chicago patrol officer for 14 years, was detailed to the Office of News Affairs, as a media liaison. In 2012, Zala, another media liaison, allegedly ran toward Kubiak, screaming, “Who the fuck do you think you are, you stupid bitch?” He swung his hand back as if to strike her. Officer Perez tried to calm Zala. Kubiak called Director Stratton, stating that Zala had previously directed similar outbursts toward her. During the call, Zala continued to berate and intimidate her. Kubiak alleges that Zala has a history of violence. Stratton told Kubiak that she had spoken with Zala and would not discuss the incident further. Kubiak’s supervising Lieutenant also declined to discuss the incident. Kubiak initiated an Internal Affairs Division investigation, which was “sustained.” Within days, Kubiak was reassigned as a patrol officer on a midnight shift in an allegedly dangerous neighborhood. Perez was also reassigned to patrol. Kubiak, the most senior ONA member, and Perez were the only officers reassigned although others had requested transfer. Kubiak alleges that Zala was never reprimanded. The Seventh Circuit affirmed dismissal of Kubiak’s 42 U.S.C. 1983 claims, concluding that Kubiak’s speech was not constitutionally protected since Kubiak did not speak as a private citizen and did not speak on a matter of public concern. View "Kubiak v. City of Chicago" on Justia Law