Justia Civil Rights Opinion Summaries

Michael Aronow, an orthopedic surgeon at the University of Connecticut Health Center, filed a grievance with the Health Center Appeals Committee against Jay Lieberman, the chairman of the orthopedic surgery department at the Center, accusing Lieberman of attempted intimidation and harassment. Aronow requested copies of the Committee’s report of its findings regarding Aronow’s grievance as well as the report written by the president emeritus of the University, but the Center denied Aronow’s request, concluding that the reports were exempt from disclosure pursuant to Conn. Gen. Stat. 10a-154a. The Freedom of Information Commission, however, concluded that the reports were not exempt from disclosure under the statute and ordered the center to provide Aronow with a copy of the reports free of charge. The trial court dismissed Lieberman’s appeal, concluding that the Commission properly determined that the reports did not constitute a “record of the performance and evaluation” of a faculty member under section 10a-154a and were therefore not exempt from disclosure. The Supreme Court affirmed, holding that the reports in this case did not constitute a “record of the performance and evaluation” of a state university faculty or professional staff member within the exemption created by section 10a-154a. View "Lieberman v. Aronow" on Justia Law

Plaintiff filed suit under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 623(a)(2), alleging that RJ Reynolds discriminated against him on the basis of his age when it rejected his application for employment. The court held that section 4(a)(2) of the ADEA authorizes disparate impact claims by applicants for employment even though the statute is unclear. The EEOC has reasonably and consistently interpreted the statute to cover such claims and the court deferred to the agency's reading of the statute. The court concluded that, in this case, plaintiff is entitled to equitable tolling of the ADEA's limitations period where plaintiff alleges that he could not have even suspected age discrimination until shortly before he filed his charge of discrimination. Accordingly, the court reversed and remanded. View "Villarreal v. R.J. Reynolds Tobacco Co." on Justia Law

Plaintiff filed suit against officials at the University of Massachusetts at Dartmouth after the university had commenced termination proceedings against him, alleging, inter alia, claims under 42 U.S.C. 1983 for violations of his First and Fourteenth Amendment rights. Plaintiff then filed a second amended complaint along with an amended motion for preliminary injunction requesting that the termination proceedings be halted and Plaintiff be reinstated to his position. Defendants moved to dismiss the amended complaint. The district court granted in part and denied in part the motion to dismiss and sua sponte combined the motion for preliminary injunction with a trial on the merits. The university subsequently terminated Plaintiff. During the pendency of Plaintiff’s interlocutory appeal of the district court’s order combining the preliminary injunction hearing with the trial, the district court proceeded with the case. The First Circuit dismissed the appeal, holding that the Court had no jurisdiction over the underlying decision to consolidate the motion for preliminary injunction with trial. Therefore, the Court also lacked jurisdiction over the district court’s denials of Plaintiff’s motions to reconsider its order. View "Nwaubani v. Grossman" on Justia Law

Plaintiff, an occasional employee of the Federal Emergency Management Agency, which is part of the Department of Homeland Security (DHS), filed an administrative claim of discrimination on the basis of her race, age, and sex. While the suit began as an administrative proceeding within the DHS, it molted into a judicial proceeding. Both the lawsuit and the administrative proceeding were based on Title VII of the Civil Rights Act of 1964. The federal district court granted DHS’s motion for judgment on the pleadings, concluding that Plaintiff had failed to exhaust her administrative remedies by failing to amend her original administrative complaint to add her retaliation claim. The Seventh Circuit reversed, holding that the district court erred in dismissing Plaintiff’s suit because it was the fault of the Equal Employment Opportunity Commission that the retaliation claim did not become part of the original case. Remanded. View "Moreland v. Johnson" on Justia Law

Mathew Neisler worked as a stockman in food service during his incarceration at the Waupun Correctional Institution. Three months after Neisler suffered work-related injury, he was fired for “medical” reasons. Neisler filed suit against defendant prison administrators, alleging that he had been fired because of a disability in violation of Title II of the Americans with Disabilities Act (ADA). Defendants filed motion for summary judgment, arguing, inter alia, that Neisler was not entitled to pursue an employment-discrimination claim under Title II. The district court granted summary judgment in favor of Defendants, concluding that Title II of the ADA covered Neisler’s claim but that no rational finder of fact could find disability discrimination. The Seventh Circuit affirmed but on different grounds, holding that Title II does not apply to a prisoner’s claim of employment discrimination in a prison job. View "Neisler v. Tuckwell" on Justia Law

Plaintiff, an employee of Costco Wholesale Corporation, made two requests for a medical leave under the FMLA. Costco granted both requests. During that time, Plaintiff was demoted from optical manager to cashier. Plaintiff filed this lawsuit against Costco and Gail Hinds, his supervisor, alleging retaliation and interference, both in violation of the FMLA, and discrimination based upon a disability and failure to accommodate, both in violation of the Americans with Disabilities Act. The district court granted summary judgment for Defendants on all of Plaintiff’s causes of action. The Seventh Circuit affirmed, holding that the district court (1) did not abuse its discretion in finding that Plaintiff failed to comply with the requirements of the Northern District of Illinois Local Rule 56.1; (2) properly granted summary judgment in favor of Defendants on Plaintiff’s FLMA retaliation and interference claims; and (3) properly granted summary judgment in favor of Defendants on Plaintiff’s reasonable accommodation claim. Lastly, Plaintiff waived any arguments with regard to disparate treatment. View "Curtis v. Costco Wholesale Corp." on Justia Law

Plaintiff, who is black, filed a complaint against the Chicago Transit Authority (CTA) in federal court, alleging that the CTA fired him because of his race in violation of Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. The CTA responded that Plaintiff was fired because he violated CTA’s policy against sexual harassment. The district court granted the CTA’s motion for summary judgment, concluding that Plaintiff’s evidence was insufficient to create a triable issue under either the direct or indirect methods of proving unlawful discrimination. The Seventh Circuit affirmed, holding that Plaintiff’s case failed under both the direct and indirect methods of proof. View "Smith v. Chicago Transit Auth." on Justia Law

Plaintiff appealed the district court's grant of summary judgment to the Department on his claims of employment discrimination in violation of the Genetic Information Nondiscrimination Act (GINA), 42 U.S.C. 2000ff-1, retaliation in violation of GINA, and national origin discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The court concluded that the district court correctly dismissed the first claim because plaintiff presented no evidence that the Department requested, required, or purchased his genetic information, or discriminated against him on the basis of genetic information; the district court's conclusion that the timeline of events and the Department's submitted evidence showed that its actions were motivated by plaintiff's refusal to take a stress test; and the district court's findings - that the timing of plaintiff's placements on administrative duty showed that the Department’s motive was ensuring compliance with the Wellness Program and furthering its goals, not discriminating against plaintiff because of his national origin - were not erroneous. Accordingly, the court affirmed the judgment. View "Ortiz v. City of San Antonio Fire Dept." on Justia Law

Appellant Matthew Faush was an employee of a temporary staffing agency. He was assigned to Tuesday Morning, Inc., where he claimed he was subjected to slurs and accusations based on his race. Ultimately he was terminated. Appellant filed suit against Tuesday Morning, claiming violations of Title VII of the Pennsylvania Human Relations Act. The district court granted summary judgment to Tuesday Morning on the ground that because appellant was not Tuesday Morning’s employee, Tuesday Morning was not liable for employment discrimination. The Third Circuit reversed, finding that a rational jury, applying the factors announced by the Supreme Court in “Nationwide Mutual Insurance Co. v. Darden,” could have found on these facts that appellant was Tuesday Morning’s employee for purposes of Title VII and the Human Relations Act. The case was remanded for further proceedings. View "Faush v. Tuesday Morning, Inc." on Justia Law

Plaintiff filed suit against her former employer, alleging claims of retaliation after her attempt to rescind her resignation was denied. Plaintiff offered her resignation, but before she finished her employment, she testified against the Executive Director, claiming sexual harassment. Then plaintiff attempted to rescind the resignation but the Executive Director rejected her rescission. The court reversed the district court's grant of summary judgment because rejecting an employee’s rescission of resignation can sometimes constitute an adverse employment action and because plaintiff has demonstrated a substantial conflict of evidence on the question of whether her employer would have taken the action ‘but for’ her testimony. View "Porter v. Houma Terrebonne Hous. Auth." on Justia Law