Justia Civil Rights Opinion Summaries

Wharf Resources, Inc., a mining company, terminated Lisa Davis for “disruptive behavior in the workplace.” Several months later, Davis filed a gender discrimination claim and a retaliatory discharge claim with the South Dakota Department of Labor, Division of Human Rights (Department). The Department concluded that there was no probable cause for Davis’s claims. The circuit court affirmed. The Supreme Court affirmed, holding that the circuit court did not err by (1) affirming the Department’s finding of no probable cause; (2) determining that Davis was terminated for permissible factors; and (3) affirming the findings of fact and conclusions of law submitted by the Department. View "Davis v. Wharf Res. (USA), Inc." on Justia Law

Plaintiff, who suffers from Multiple Sclerosis (MS), filed suit against her former employer, TEFCU, for wrongful termination in violation of the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq.; the District of Columbia Human Rights Act (DCHRA), D.C. CODE 2-1401.01 et seq.; and Section 510 of the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1140. Plaintiff alleged that the cost of treating her MS was causing the monthly healthcare insurance premium to rise and that TEFCU dismissed her to reduce its health care costs. TEFCU claimed that plaintiff's termination was due to her poor performance as an employee. The district court granted TEFCU's motion for summary judgment and plaintiff appealed. The court concluded that no reasonable jury could infer that TEFCU dismissed plaintiff because of the costs associated with insuring her. The court also concluded that the district court did not abuse its discretion in denying plaintiff's motion for sanctions where plaintiff provides no citation to authority or to the record demonstrating that the district court's denial was premised upon an erroneous conclusion of law, an erroneous factual finding, or that it was otherwise unreasonable. Accordingly, the court affirmed the judgment. View "Giles v. Transit Emp. Fed. Credit Union" on Justia Law

Boyd and Smith, both Caucasians, alleged that their former employer, Boeing, discriminated against them on the basis of their race, in violation of 42 U.S.C. 1981, when it terminated their employment after they appeared in a photograph taken at work with a third employee looking like members of the KKK. The district court granted Boeing summary judgment, finding that Boyd and Smith failed to establish a prima facie case of race discrimination because they were not similarly situated to Kenta Smith, the African-American employee who took the photograph and reported the incident. The Third Circuit affirmed, agreeing that “[e]ven if a jury could somehow find that the evidence met the prima facie threshold,” “[t]here is no evidence that could lead a reasonable jury to conclude that Boeing did not really fire the plaintiffs for posing as the KKK, or that a more likely cause was Boeing’s animus toward” Caucasians. View "Barker v. Boeing Co" on Justia Law

Yazdian is a first-generation Iranian American and nonpracticing Muslim, who worked as a territory manager for ConMed for five years. During his tenure at ConMed, Yazdian received awards, promotions, and praise, but had interpersonal problems with his manager, Sweatt. In 2010, Yazdian complained that Sweatt was creating a hostile work environment and discriminating against him; within six weeks, ConMed terminated Yazdian. Yazdian filed suit, alleging that ConMed terminated him in retaliation for opposing an unlawful employment practice and because of his national origin and religion in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e. The district court granted summary judgment for ConMed. The Sixth Circuit reversed as to the retaliation claim. Yazdian produced enough evidence from which a reasonable jury could conclude that he made multiple complaints about a hostile work environment before he knew that his job was in jeopardy. If ConMed wants to argue that Yazdian wrongfully complained about discrimination to save his job, it may make that argument to the jury. The court affirmed as to the discrimination claim, stating that no reasonable jury could find that ConMed terminated Yazdian because of his national origin or religion. View "Yazdian v. ConMed Endoscopic Tech., Inc." on Justia Law

Burks and Jones were hired as Union Pacific “Signal Helpers.” During orientation in January 2011, they were informed that they would be employed through December 2015, or until the company “moved in a different direction.” The position carried a 90-day probationary period; they were subject to a collective bargaining agreement. They were the only African-American members of their class. On February 9, 2011, Burks was told that “it wasn’t working out.” Burks lodged a complaint with Schop in Union Pacific’s Equal Employment Opportunity department alleging racial discrimination. Schop found no evidence that Burks was fired because of his race, but concluded that he had not been given an opportunity to improve and offered reinstatement in exchange for a general release with a new 90-day probationary period. Burks signed and returned to work. Burks worked for seven days before requesting a transfer. He was transferred and completed his probationary period, but was later notified that Union Pacific abolished the Signal Helper position, effective October 2011. Jones had similar experiences. The district court granted summary judgment, rejecting claims that Union Pacific denied an opportunity to take a test that was required for promotion, based on impermissible retaliation for complaints of discrimination. The Seventh Circuit affirmed, finding no evidence that positions within the seniority district became available during the relevant period. View "Burks v. Union Pac. R.R. Co." on Justia Law

After the Fire District suspended Anzaldua, a paramedic and firefighter, for failing to respond to a directive issued by Chief Farwell, Anzaldua emailed a newspaper reporter expressing concerns about the District and about Farwell. The email “shocked” and “angered” his co-workers. Battalion chiefs noted it “fostered division between Anzaldua and his co-workers," and between firefighters and Farwell. The District terminated Anzaldua, who sued, alleging that the District and the individuals involved in his termination violated his First Amendment rights by retaliation and that Farwell and Anzaldua’s ex-girlfriend violated federal and state computer privacy laws by accessing his email account and obtaining his emails. The district court allowed some First Amendment claims to proceed but dismissed all other claims and denied leave to amend the computer privacy law claims. The court granted defendants summary judgment on Anzaldua’s First Amendment claims, citing qualified immunity. The Eighth Circuit affirmed summary judgment on Anzaldua’s First Amendment claims and denial of leave to amend federal computer privacy law claims, but reversed denial of leave to amend state computer privacy law claims. View "Anzaldua v. Northeast Ambulance & Fire" on Justia Law

Plaintiff-Appellant Susan Bennett appealed the district court’s grant of summary judgment in favor of her employer, defendant-appellee Windstream Communications, Inc. Windstream acquired the company that had employed Bennett for twelve years, Paetec Communications, Inc. At the time of the acquisition, Bennett was a Fiber Optic Tech III, responsible for locating fiber optic cable, repairing, splicing, and testing it, and performing routine weekly and monthly maintenance at various sites. After the acquisition, Bennett’s pay and benefits remained the same. A few months after Windstream assumed Paetec’s operations, Todd Moore became Bennett’s supervisor. Moore instituted a policy requiring all technicians, including Bennett, to check in to an assigned manned office each morning at 8 a.m. unless they had tasks to perform at other worksites. Bennett was assigned to check in at the Tulsa office, which was the closest manned office to her home in Gore, Oklahoma. Given the distance between Gore and Tulsa, Bennett was required to commute a total of almost four hours each day. A Human Resources specialist, testified that the check-in policy, though not written, was standard Windstream practice. Bennett understood that she was required to report to the Tulsa office each morning at 8 a.m., yet she often arrived at the Tulsa office more than two hours late. On a number of occasions, she did not report to the Tulsa office at all or left several hours early to drive home, rather than working until 5 p.m. as required. Bennett was disciplined for her tardiness and absences. Concurrently with the discipline, Bennett complained of chest pains and made a workers' compensation claim for "work related stress." Bennett failed to return to work following her medical leave, and she was "separated" from the company. Bennett brought several claims alleging gender discrimination and retaliation under Title VII of the Civil Rights Act of 1964, age discrimination under the Age Discrimination in Employment Act (ADEA), violation of the Oklahoma Antidiscrimination Act (OADA), and constructive discharge in violation of Oklahoma public policy and federal law. Finding no reversible error, the Tenth Circuit affirmed the district court's order. View "Bennett v. Windstream Communications" on Justia Law

Fischer worked for Minneapolis Public Schools as a Janitor Engineer, 2008-2010, and performed satisfactorily. After being laid off for fiscal reasons, he was told that he was eligible for reinstatement, conditioned on his possession of a boilers license and his completion of a strength test created by Cost Reduction Technology that measured the “maximum force-producing capability of muscles.” Fisher did not pass the test. Fischer alleged that District employees told him that he was not reinstated because of his back, that he was “incapable of pulling, carrying, pushing, or lifting a heavy load,” and that his employment would “create[] a substantial risk of injury in the work place.” The District denied his request for a retest. Fischer sued, claiming violation of the Americans with Disabilities Act and the Minnesota Human Rights Act by refusing to reinstate him. The Eighth Circuit affirmed summary judgment in favor of the district. The District’s belief that Fischer was capable of performing the physical labor of a medium strength worker is not equivalent to a belief that Fischer suffered a physical impairment such as a physiological disorder, cosmetic disfigurement, anatomical loss, or disease as defined by the ADA, 42 U.S.C. 12102(1). View "Fischer v. Minneapolis Pub. Schs" on Justia Law

Plaintiffs, investigators with the Department, filed suit against the District under the D.C. Whistleblower Protection Act, D.C. Code 1-615.51 et seq., alleging that they were unlawfully reassigned to a less desirable position in retaliation for disclosures they allegedly made accusing their superiors of gross mismanagement and racial discrimination in the workplace. The unrebutted explanation the District has offered is that the Department reassigned plaintiffs because District prosecutors refused to work with either of them and not because they had filed Equal Employment Opportunity complaints with the Department alleging racial discrimination. Because plaintiffs failed to rebut this explanation, the court held that they have failed to demonstrate a genuine issue of disputed fact sufficient to survive summary judgment on their claim. Accordingly, the court affirmed the district court's grant of summary judgment to the District. View "Bowyer v. District of Columbia" on Justia Law

Plaintiff filed suit against three officials of the AO, in their official capacities, claiming that their refusal to consider her job application violated her right to travel protected by the Constitution of the United States. The district court granted summary judgment to defendants. The court held that the AO’s decision to limit its applicant pool to employees of the federal judiciary and individuals who lived in the Washington metropolitan area did not violate plaintiff’s right to travel, whether that right is considered under the Privileges and Immunities Clause of Article IV because it does not constrain the powers of the federal government; the equal protection component of the Due Process Clause of the Fifth Amendment because the geographical limitation does not implicate the component of plaintiff's right to travel; or the essential structure of the Constitution. Further, the court concluded that the district court did not abuse its discretion by denying plaintiff’s request for discovery before entering summary judgment for defendants. View "Pollack v. Duff" on Justia Law