Justia Civil Rights Opinion Summaries

Appellant, the manager of the Dubois branch of the Fremont County Library System (FCLS), used an FCLS account to order books for the Dubois school system. The FCLS executive director terminated Appellant, determining that Appellant had improperly used FCLS funds to purchase books for the District. The FCLS Board of Trustees upheld the termination based upon an erroneous belief that Appellant had violated Wyo. Stat. Ann. 9-13-105. The district court affirmed, concluding that the Board misread section 9-13-105 but that because Appellant’s employment was at-will, Appellant’s employment may be terminated at any time with or without cause. The Supreme Court affirmed, holding that, as an at-will employee, Appellant did not have a property interest in continued employment or a right to a contested case hearing. View "Sabatka v. Bd. of Trs. of the Fremont County Pub. Library Sys." on Justia Law

Greengrass sued her former employer, IMS, alleging that IMS retaliated against her for filing a complaint with the U.S. EEOC against the company by naming her in its annual SEC filings and casting her complaint as “meritless.” The district court granted summary judgment in favor of IMS on the ground that Greengrass lacked evidence showing a causal link between her EEOC filing and the alleged retaliatory act. The Seventh Circuit reversed. Greengrass made out a prima facie case of retaliation by demonstrating that she engaged in a statutorily protected activity when she filed her EEOC charge, that IMS engaged in an adverse employment action when it listed her name in its SEC filings, and that there was sufficient evidence for a rational trier of fact to find that IMS listed her name because Greengrass filed the EEOC charge. View "Greengrass v. Int'l Monetary Sys., Ltd." on Justia Law

Gibson, an African-American male, was hired by the IRS on January 1, 2008, as a full-time seasonal tax examiner, subject to completion of a one-year probationary period. Gibson's work leader was an African-American female. Gibson's first-level supervisor was Butler, an African-American female; Gibson's second-level supervisor was Hunter, an African-American female. Gibson's third-level supervisor was Vermillion, a Caucasian female. In his unit, there were 32 employees; 18 were probationary. Of the 18, four were African-Americans, 12 were Caucasian, and two were Hispanic. Six were female and 12 were male. Gibson was the only African-American male. During his probation, Gibson was observed to not be editing entire bundles of returns, mislabeling bundles, recording working hours he was not present, and improperly altering a government document. Butler prohibited Gibson from working overtime. Gibson claimed he was being unfairly targeted by Butler. Gibson's work product, subject to 100% review, revealed an unacceptable error rate. In April, Gibson delivered a letter to Jones, titled "Sexual Harassment, Retaliation, Harassment, and Creating a Hostile Environment, by Manager Ms. Felecia Butler." Hunter reported that the letter’s allegations were unfounded. Vermillion terminated Gibson based on Gibson's failure to attain successful performance during his probation. The Seventh Circuit affirmed summary judgment in favor of the IRS, rejecting race and sex discrimination and retaliatory termination claims. View "Gibson v. Geithner" on Justia Law

In 2007 Pedersen began working for BMA dialysis clinics. She became a registered nurse. On April 17, 2012, clinic manager Ince talked to Pedersen about Pedersen’s aggression and patient care performance issues; Pedersen was to be transferred to another clinic with more experienced staff. Pedersen yelled at Ince. Later that day, the two met with nephrologists to discuss patient care planning. Pedersen informed the nephrologists about mispackaging of blood samples a week earlier. Ince discussed how the incident had been handled. Following the meeting, Pedersen contacted regional manager Kienzle and others to report the mispackaging. Kienzle informed them that the incident had been investigated and no samples were affected. On April 19, a patient reported that Pedersen had slapped her arms; others complained that Pedersen had impersonated a manager and had inappropriately documented patient treatment. BMA investigated. Pedersen went on medical leave. BMA determined Pedersen could return under a corrective plan. Pedersen did not return. BMA offered Pedersen employment as a technician due to Pedersen’s long absence and new policies; she could be retrained as an RN. Pedersen refused to return unless BMA met her conditions. After several months, BMA terminated Pedersen’s employment, characterizing her failure to return as voluntary resignation. Pedersen sued, alleging retaliation and violation of the Minnesota Whistleblower Act. The district court granted BMA summary judgment. The Eighth Circuit affirmed. View "Pedersen v. Bio-Med. Applications of Minn." on Justia Law

Plaintiff filed suit against his former employer under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-634. Plaintiff alleged discrimination and retaliation under the Act, but defendant never answered or defended the suit. After the district court entered a default judgment against defendant, defendant filed a motion to set aside the default judgment. The court concluded that evidence adduced at a default judgment "prove-up" hearing cannot cure a deficient complaint. In this case, plaintiff's complaint contained very few factual allegations, but his testimony at the damages hearing provided evidence on the elements of his claim that were absent from his pleadings. Accordingly, the court vacated the entry of default judgment and remanded. View "Wooten v. McDonald Transit Assoc, Inc." on Justia Law

In 2007, Carlos Bassatt was accused by a school district employee of masturbating in the parking lot of a Denver high school during school hours. Bassatt was terminated from his student teaching placement with School District No. 1 of the City and County of Denver for misconduct. Although the Denver District Attorney’s Office chose not to prosecute Bassatt, West’s principal terminated him from his student teaching placement with the District out of concern for student safety. Bassatt filed a discrimination complaint with the Colorado Civil Rights Commission. Bassatt later filed a lawsuit alleging retaliatory discharge in the federal district court. Bassatt died while district court proceedings were still pending, and his estate was substituted as the plaintiff. The district court granted summary judgment for the District, finding that the Estate failed to show that the principal’s reason for firing Bassatt was pretextual. The Estate appealed the district court’s finding (required in a Title VII retaliation claim), arguing that there were sufficient facts on the issue of pretext to create a triable issue of material fact, thus precluding summary judgment. Finding no reversible error, the Tenth Circuit affirmed the district court's judgment.View "Estate of Bassatt v. School District No. 1" on Justia Law

Plaintiff filed suit against the TWC under Title VII of the Civil Rights Act, 42 U.S.C. 2000e-2(a), alleging that the TWC discriminated against him when it appointed another person to a management position over him. The court concluded that plaintiff failed to show that he was clearly better qualified for the position or that the TWC's bases for its decision were otherwise affected by his national origin. Accordingly, the court affirmed the judgment, concluding that the district court properly adopted the magistrate's Report and Recommendation granting summary judgment in favor of the TWC.View "Martinez v. Texas Workforce Comm'n" on Justia Law

Plaintiff filed suit against her former employer, alleging claims of a sexually hostile work environment and retaliation. On appeal, plaintiff challenged the district court's grant of summary judgment to the employer. The court concluded that the totality of the record creates too close a question as to whether her coworkers' behavior created an objectively hostile or abusive work environment to be decided on summary judgment. Therefore, the court reversed the district court's grant of summary judgment on this claim. The court concluded, however, that plaintiff failed to produce evidence creating a triable issue as to whether the employer's proffered explanation for terminating plaintiff was pretext for retaliation and, therefore, affirmed the district court's grant of summary judgment on this claim.View "Walker v. Mod-U-Kraf Homes, LLC" on Justia Law

Plaintiff-appellant Alphonso Myers was injured on the job. He received social security benefits due to his inability to work. While claiming benefits, he applied for a job as an armed guard with defendant-appellee Knight Protective Service. On his job application, plaintiff made no mention of his prior injury. Supervisors at Knight noticed that plaintiff appeared to be in pain. Plaintiff then admitted that he had undergone a series of surgeries from the prior workplace injury. Concerned that this pain might interfere with his duties as an armed guard, Knight required plaintiff to submit to a physical exam before resuming his duties as a guard. Plaintiff waited months for the exam - long enough that plaintiff considered the delay as an effective termination from his job. Plaintiff then filed suit, arguing that he had been discriminated against on the basis of his race and disability. The district court granted summary judgment to Knight, and plaintiff appealed. Finding no reversible error, the Tenth Circuit affirmed the district court's judgment.View "Myers v. Knight Protective Service" on Justia Law

EEOC sued CRST in its own name, under Title VII, 42 U.S.C. 2000e, alleging that CRST subjected Starke and 270 similarly situated female employees to a hostile work environment, in its Driver Training Program. For two years, EEOC failed to identify the women comprising the putative class; the court ordered EEOC to make all class members available for deposition or risk a discovery sanction. EEOC filed updated lists of allegedly aggrieved individuals, but failed to make all of them available for deposition before the deadline. The court barred EEOC from pursuing relief for any individual not made available for deposition before the deadline. EEOC then listed 155 individuals for whom it was still pursuing relief and 99 individuals, allegedly sexually harassed, but for whom EEOC was not pursuing relief based on the order. Following remand, the court dismissed, but for one claim, which settled for $50,000, and awarded CRST $92,842.21 in costs, $4,004,371.65 in attorneys' fees, and $463,071.25 in out-of-pocket expenses. The Eighth Circuit held that CRST is not entitled to attorneys' fees for claims dismissed based on EEOC's failure to satisfy pre-suit obligations and a purported pattern-or-practice claim. On remand, the court must individually assess each claim for which it granted summary judgment on the merits and explain why it deems each to be frivolous, unreasonable, or groundless.View "Equal Emp't Opportunity Comm'n v. CRST Van Expedited, Inc." on Justia Law