Justia Civil Rights Opinion Summaries

Plaintiff, a police officer, filed suit against the City, alleging unlawful retaliation under Title VII of the Civil Rights Act, 42 U.S.C. 2000 et seq. After a jury found the City liable and awarded plaintiff damages, both parties appealed. The court affirmed the district court’s judgment on liability because plaintiff produced evidence sufficient to find - under University of Texas Southwestern Medical Center v. Nassar’s but-for standard of causation - that his Crime Reduction Unit (CRU) supervisors, motivated by retaliatory intent, intended to cause and did cause his suspension; affirmed the district court’s order upholding the jury’s past compensatory damages award because plaintiff produced specific evidence that he suffered mental anguish and reputational harm until his suspension was overturned; reversed and remanded the district court’s order vacating the jury’s future compensatory damages award because plaintiff produced sufficient evidence to support his claim of future reputational harm, and instructed the district court on remand to consider remittitur; and affirmed the district court’s order denying the City’s motion for a mistrial because the district court found after a thorough investigation that the discovery of the prior jury’s notes would not affect the jury’s deliberations or the jury’s verdict. View "Zamora v. City of Houston" on Justia Law

Mary Banker filed a retaliatory discharge claim against the University of Louisville Athletic Association, Inc. (ULAA), alleging that ULAA discharged her for engaging in a protected activity under the Kentucky Civil Rights Act. A jury found in favor of Banker and awarded attorney fees. The court of appeals reversed and remanded for dismissal of Banker’s claim, holding that Banker had not met her burden of proof. The Supreme Court reversed, holding (1) the court of appeals injected its interpretation of the facts and did not view the proof in light most favorable to Banker, and the evidence was sufficient to support a reasonable inference that ULAA’s stated reasons for discharging Banker were pretextual; (2) the trial court's award of lost wages was in error; and (3) the trial court’s attorney fee award was reasonable and a proper exercise of its discretion. Remanded. View "Banker v. Univ. of Louisville Athletic Ass’n, Inc." on Justia Law

Plaintiff filed suit against DHS, the Department in which the Coast Guard is housed, under the Rehabilitation Act, 29 U.S.C. 701 et seq., alleging that it had unlawfully denied her accommodations and terminated her in retaliation for requesting those accommodations. The district court granted summary judgment to the Coast Guard. The court affirmed the district court's conclusion that plaintiff was not a qualified individual able to perform her job duties even with reasonable accommodations and that she had produced no evidence that would permit a reasonable jury to find that the Coast Guard retaliated against her. View "Doak v. Johnson" on Justia Law

Plaintiff filed suit against her employer, the Department of Homeland Security, under Title VII of the Civil Rights Act, 42 U.S.C. 1983, alleging that her supervisor took adverse actions against her on account of her race or because she had previously filed a discrimination complaint against the Department. The court affirmed the district court's grant of summary judgment in favor of the Department, concluding that the record in this case could not reasonably support a finding that the Department’s stated reasons were a pretext for discrimination or retaliation. View "Walker v. Johnson" on Justia Law

Plaintiff brought suit against his employers in the District of Puerto Rico, alleging, inter alia, violations of the Age Discrimination in Employment Act. The employers moved to dismiss the complaint, asserting that a forum selection clause in Plaintiff’s separation agreement provided exclusive jurisdiction in the Court of First Instance, San Juan Division. Plaintiff argued that the forum selection clause was invalid because he did not affirmatively waive his Seventh Amendment Right to a jury trial. The district court concluded that the forum selection clause was valid but entered a declaratory judgment stating that the Commonwealth of Puerto Rico must afford civil litigants the Seventh Amendment right to a jury trial. The First Circuit vacated the portion of the district court’s judgment declaring that the Commonwealth must afford civil litigants a jury trial, holding that this action was in contravention of binding Supreme Court precedent. Remanded. View "Gonzalez-Oyarzun v. Commonwealth of P.R." on Justia Law

In 1999, detainees at the Cook County Juvenile Temporary Detention Center claimed that Center personnel abused detainees. Eight years into the certified class action, the court appointed a “Transitional Administrator” to run the Center in compliance with state and federal requirements. State law, effective in 2008, moved the Center’s management from the county’s political branches to the Circuit Court of Cook County, 55 ILCS 75/3(b), and required the Chief Judge to appoint a new head within 180 days. When the case was argued in 2011, the appointment had not been made. In 2009 the Transitional Administrator proposed reorganization, which would terminate about 225 union employees. The union for Center employees intervened. The district court rejected its position that the proposal would violate several statutes and authorized the implementation, stating that collective-bargaining rights must give way, as a matter of Illinois law, when necessary to effective management. The Seventh Circuit reversed, noting that the judge did not find that overriding the right to bargain was essential to solve any constitutional problem at the Center or about the necessity for a particular remedy to cure any violation. The plan has been in effect for years, and restoring union members to their old positions is not possible. View "Doe v. Teamsters Local Union" on Justia Law

Wright retired after working 1982-2007 as a caseworker at the Peoria Field Office of the Illinois Department of Children and Family Services after the Department ordered her to undergo a fitness-for-duty evaluation. The order was a response to an incident in which Wright’s comments to a child apparently caused an outbreak of violence at a unit in a psychiatric facility for children. Wright filed suit alleging, that the Department had violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(d)(4)(A), by causing her constructive discharge. A jury found in favor of Wright on the ADA claim but awarded no compensatory damages. The district court granted the Department’s motion for a new trial. During the second trial, the court granted the department judgment as a matter of law on the ground that Wright had failed to establish that she had been constructively discharged. The Seventh Circuit affirmed. Wright did not establish that the Department’s conduct communicated that her termination was imminent. View "Wright v. Ill. Dept. of Children & Family Servs." on Justia Law

Luis Rodriguez was a gay Hispanic man employed by Delta Airlines, Inc. In November 2010 Rodriguez filed a complaint with the Alaska State Commission for Human Rights, accusing Delta of race-based discrimination. Rodriguez alleged that Delta (1) "did not delete the position of a Caucasian coworker with less seniority," and (2) "recently brought another Caucasian employee with less seniority . . . back from layoff status." After an investigation, the Commission concluded that Rodriguez's racial discrimination allegations were not supported by substantial evidence, and the Commission dismissed the complaint without holding a hearing. The employee appealed to the superior court, and the superior court affirmed the Commission's conclusion that the employee's complaint was not supported by substantial evidence. The employee appealed to the Alaska Supreme Court. Because the Supreme Court agreed that the employee failed to present the Commission substantial evidence of race-based discrimination, it affirmed the superior court's decision affirming the Commission's dismissal. View "Rodriguez v. Alaska Commission for Human Rights" on Justia Law

Heartland employed Thomas as an account liaison from May 2010 until she was terminated in June 2011, at age 53. Thomas claims that Hagen, an administrator for Heartland, had commented “that older people didn’t work as fast or were as productive as younger people,” and about having ‘fresh blood, younger employees.” Hagen referred to Thomas as “the old short blond girl,” and, after Thomas’s discharge,told a Heartland client that “he likes to keep himself surrounded with young people.” A Heartland human resources manager testified that Hagen was “an indirect supervisor” of the account liaison personnel. Duncan, Heartland’s regional manager, had audited three weeks of Thomas’s mileage claims and determined that Thomas had falsified her reimbursement claims. Thomas maintains she responded that she kept records that would explain discrepancies between the claimed mileage and the weekly call plans, but that Hagen dismissed her response by stating that termination “was a decision they had made.” In her suit, alleging violation of the Missouri Human Rights Act, the court granted the defendants summary judgment. The Eighth Circuit reversed, finding that there was a genuine issue of material fact as to whether age was a contributing factor in Thomas’s discharge by Heartland and Hagen. View "Thomas v. Heartland Employment Servs., LLC" on Justia Law

Miller began work as a technician at Polaris Laboratories in Indianapolis in 2009. About eight months later, Miller was fired for repeated failures to meet an average daily quota of 260 samples processed per day. Miller, who is African‐American, asserts that during her employment at Polaris she suffered from racial discrimination that had an effect on her work performance. Miller had complained to supervisors that she had been called “the colored girl’ and about other derogatory remarks. At one point, a supervisor refused to train or even talk to Miller. There was evidence that Miller was given more challenging work than others. She sued Polaris, contending that it violated Title VII and 42 U.S.C. 1981. The district court granted Polaris summary judgment. The Seventh Circuit reversed, finding that Miller established genuine issues of material fact on discrimination and retaliation claims. View "Miller v. Polaris Labs., LLC" on Justia Law