Justia Civil Rights Opinion Summaries

After graduating from the FAA Academy, Huynh became a trainee air traffic controller. Huynh, the only Asian American in his training class, reported problems with his instructors. He was assigned a different team. The new team reported that Huynh was performing poorly. Huynh was granted 42 additional training hours above the180 target hours. After he completed those hours, Huynh moved on to the second of 12 required certifications. He was again reported as performing poorly. Huynh's team provided many opportunities to improve, beyond the 180t hours. Superiors reported that Huynh did not have command of basic air traffic terminology and geography and was defensive when trainers noted mistakes. Huynh was the only member of his class suspended for poor performance on a skill check. Huynh applied for reassignment, but no other facilities offered to hire him. A review board concluded that Huynh had been given comprehensive training, but had failed to progress. A manager nonetheless continued Huynh's training. Huynh received additional instruction and several weeks to refresh his learning. Shortly after Huynh returned to training, he reported problems with his supervisors and classmates. He declined reassignment. Problems continued; Huynh was terminated. The court granted the FAA summary judgment. The Eighth Circuit affirmed, rejecting claims of racial discrimination under 42 U.S.C. 2000e and the Minnesota Human Rights Act, finding that the stated reasons for termination were not pretextual. View "Huynh v. Dep't of Transp." on Justia Law

Swanson resigned from the Village of Flossmoor’s police department after suffering two strokes in 2009, six weeks apart, the second of which left him unable to perform as a detective. Swanson claimed that the Village failed to reasonably accommodate him—in violation of the Americans with Disabilities Act—upon his return to work from his first stroke by not permitting him to work exclusively at a desk. He also claimed that the Village violated Title VII of the Civil Rights Act by discriminating against him on the basis of his race and national origin, citing instances in which Village employees made racially offensive comments to him during his employment. He claimed that the Village excluded him from criminal investigations after his first stroke and then contemplated the possibility of moving him out of the investigations division entirely after his second stroke. The district court granted the Village summary judgment and the Seventh Circuit affirmed, finding the Title VII claims time-barred because Swanson failed to lodge a formal charge with the Equal Employment Opportunity Commission within 300 days after the alleged discrimination and finding the ADA claim deficient in view of his doctor’s recommendation that Swanson work “part-time” following his first stroke. View "Swanson v. Village of Flossmoor" on Justia Law

Initially hired in 1987, Schaffhauser worked as a Plant Engineering Manager from 2007-2012. He received training on UPS’s anti-harassment, anti-discrimination, and ADA policies. The company prohibits unprofessional and discourteous actions, even if those actions do not constitute unlawful harassment. In 2012, Schaffhauser was at work chatting with Sharkey, Goodwin, and Williams (all African-Americans). Goodwin said, “I wish Rodney Barefield would take a swing at me and I would knock that motherf**r out.” Schaffhauser commented, “If he ever hit me, I would hit him back so hard it’d knock the black off him.” He admits making the comment, that it could be racist, and that it was a mistake, but claims he was just joking and did not intend it to be racist. In his report to human resources, Schaffhauser claimed that his medical condition was a “contributing factor in [his] poor choice of words.” Schaffhauser was demoted from manager to supervisor. Schaffhauser sued UPS, alleging reverse race discrimination and failure to accommodate a disability (he had received a steroid shot). The district court granted summary judgment to UPS. The Eighth Circuit affirmed. Schaffhauser did not request accommodation or inform UPS of the relevant details of his disability. UPS had a legitimate, nondiscriminatory reason for its action View "Schaffhauser v. United Parcel Serv., Inc." on Justia Law

In 2002, knowing that Plaintiff‐Appellant Natasha Davis was a Type I diabetic, Defendant‐Appellee Bombardier Transportation Holdings (USA) Inc. hired her as a Customer Service Agent (later renaming the position as an Air Train Agent or "ATA"). In 2007, Davis went on disability leave for diabetic retinopathy. Davis underwent at least six eye surgeries during her leave. In August, Davis notified Bombardier that she was prepared to return to work, and submitted to a physical. Bombardier informed Davis that she failed the physical and eye exams, but Davis contended she passed. Bombardier thereafter determined that Davis could no longer operate as an "ATA II." On September 1, 2007, Bombardier “demoted” Davis to the ATA I position, which paid 75 cents less per hour than the ATA II position. Davis filed suit against Bombardier, bringing claims of disability-based employment discrimination and retaliation. The district court granted Bombardier's motion for summary judgment, finding (in relevant part) that Davis' demotion-based claim was time barred. On appeal, Davis argued that the Lilly Ledbetter Fair Pay Act of 2009 applied to and revived her claims. The Ledbetter Act made it unlawful to apply a discriminatory compensation decision to an employee and starts a new statute of limitations clock with each paycheck that reflected that decision. Davis argued that Bombardier’s demotion decision was made with disability‐based discriminatory intent and, as a result, reduced her compensation. Thus, she contended that her claim was timely when measured from her last paycheck and not the date of her demotion. After review, the Second Circuit Court of Appeals affirmed judgment in favor of Bombardier, concluding that the Ledbetter Act did not encompass a claim of a discriminatory demotion decision that results in lower wages where, as here, the plaintiff had not offered any proof that the compensation itself was set in a discriminatory manner. A plaintiff must plead and prove the elements of a pay-discrimination claim to benefit from the Ledbetter Act’s accrual provisions. View "Davis v. Bombardier Transp. Holdings" on Justia Law

In Sprint Commc’ns, Inc. v. Jacobs, the Supreme Court revisited the doctrine of abstention enunciated in Younger v. Harris. That doctrine requires federal courts, in the absence of extraordinary circumstances, to refrain from interfering with certain state proceedings. In this case, David Knight, an employee of Sirva Relocation, LLC, filed a charge of discrimination with the Massachusetts Commission Against Discrimination (MCAD) alleging that Sirva and Aetna Life Insurance Company (together, Appellants) had discriminated against him on the basis of disability in violation of Mass. Gen. Laws ch. 151B and the Americans with Disabilities Act (ADA). Appellants filed a federal complaint against the Commonwealth of Massachusetts, the MCAD, its commissioners, and Knight, asking the court to enjoin the MCAD proceeding on the basis that ERISA preempted the chapter 151B claim. The MCAD and Knight moved to dismiss the complaint, entreating the district court to abstain. While the case was pending, the Supreme Court decided Sprint. The district court dismissed the federal court action, concluding that Younger abstention was appropriate in this case. The First Circuit affirmed the district court’s decision to abstain and further clarified its own case law concerning the exception to the Younger doctrine for facially conclusive claims of preemption. View "Sirva Relocation, LLC v. Golar Richie" on Justia Law

Appellant suffered a workplace injury to his back and applied for permanent partial disability. The Workers’ Compensation Division denied benefits. Appellant requested a contested case hearing. During discovery, the Division served interrogatories and requests for production requesting information regarding Appellant’s work history since the time of his injury. Appellant objected to a number of the interrogatories and requests, asserting his Fifth Amendment right against self-incrimination. The hearing examiner compelled Appellant to answer the discovery, but Appellant continued to invoke his Fifth Amendment right against self-incrimination. The hearing examiner dismissed the contested case as a discovery sanction. The district court affirmed. The Supreme Court reversed, holding (1) Appellant was justified in asserting his Fifth Amendment privilege against self-incrimination because he reasonably believed his answers to the discovery requests could be used in a criminal prosecution against him; and (2) the hearing examiner abused his discretion by acting arbitrarily and capriciously in dismissing the case as a discovery sanction without engaging in the proper balancing of Appellant’s and the Division’s conflicting interests. View "Debyah v. State, ex rel., Dep’t of Workforce Servs." on Justia Law

Plaintiff, a sales representative for Wyndham Vacation Resorts, Inc., brought this claim of retaliation under Title VII of the Civil Rights Act of 1964 alleging that her supervisor subjected her to a hostile work environment on the basis of race and national origin and that Wyndham retaliated against her for complaining about the supervisor’s conduct. The magistrate judge recommended that the district court grant summary judgment for Wyndham. The district court summarily affirmed the recommendation. The First Circuit affirmed, holding that Plaintiff did not present sufficient evidence to establish a retaliation claim under Title VII. View "Planadeball v. Wyndham Vacation Resorts, Inc." on Justia Law

Plaintiff was a supervisor at the Programmatic Area of the Department of Education’s Special Education Center in Bayamon when the New Progressive Party came to power in Puerto Rico. Plaintiff claimed that, as a result of his membership in the Popular Democratic Party, he was subject to impermissible political discrimination when he was reassigned to a new position, a diminution of his supervisory responsibilities, and other adverse employment actions. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding (1) Plaintiff failed to generate facts that would allow a rational jury to conclude that Plaintiff’s reassignment was an act of political discrimination or that his job responsibilities were diminished in his new position; and (2) Plaintiff’s remaining allegations of workplace discrimination were insufficient to constitute adverse employment actions. View "Santiago-Diaz v. Rivera-Rivera" on Justia Law

St. Francis hired Shirrell, who is Jewish, as a nurse in 1995. Shirrell resigned in 2000. In 2001, St. Francis re-hired Shirrell. In early 2012, Miller, who is not Jewish, commented to a co-worker that she was going to try to “Jew down” a seller to a lower price. Shirrell informed her supervisor, who talked to Miller, posted a copy of the harassment policy, and sent an email reminding nurses to be careful with their words and actions. Six weeks later, Shirrell informed her supervisor that her work environment had become hostile, alleging that co-workers gave her the cold shoulder and that Miller accused Shirrell of trying to get Miller in trouble. St. Francis later promoted Miller, who brought two patient complaints concerning Shirrell to the attention of her supervisor. By late May 2012, Shirrell had accumulated five unscheduled absences within a 12-month period. Subsequent incidents were described as reluctance, disinterest, or neglect in carrying out responsibilities. Based on Shirrell’s accumulate disciplinary points, her employment was terminated. She filed suit, alleging religious discrimination and retaliation in violation of Title VII and the Missouri Human Rights Act. The Eighth Circuit affirmed summary judgment in favor of the defendant; St. Francis terminated Shirrell pursuant to policy for accumulation of disciplinary points. View "Shirrell v. St. Francis Med. Ctr." on Justia Law

Plaintiff filed suit against his employer, NOV, after he was terminated, alleging claims of age discrimination and retaliation in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621, et seq., and the Texas Commission on Human Rights Act (TCHRA), Tex. Lab. Code Ann. 21.051, 21.055. ROA. 22–28. The district court granted summary judgment in favor of NOV and plaintiff appealed. The court concluded that the evidence plaintiff has identified was sufficient to allow a finding that age discrimination was the cause of his termination in violation of the ADEA. However, in regards to the retaliation claim, the court concluded that plaintiff was unable to establish the causal link in light of the temporal gap of 8–10 months between plaintiff’s complaint to HR and the adverse employment action and the absence of evidence that the supervisor even knew of the complaint to Human Resources about the “old farts” comment. Accordingly, the court affirmed as to the retaliation claim but reversed the discrimination claim. The court remanded for further proceedings. View "Goudeau v. National Oilwell Varco, L.P." on Justia Law