Justia Civil Rights Opinion Summaries

Pamela Manning, who suffers from type I diabetes, resigned from her employment at Kohl’s Department Stores, Inc. after Kohl’s refused to grant her request for a steady work schedule. The Equal Employment Opportunity Commission brought this suit on Manning’s behalf, alleging that Kohl’s refused to provide Manning with reasonable accommodations in violation of the Americans with Disabilities Act (ADA) and constructive discharge. The district court entered summary judgment for Kohl’s. The First Circuit affirmed, holding that because Kohl’s made multiple offers to Manning after her resignation to discuss alternative reasonable accommodations, Manning had neither a claim for ADA discrimination nor a claim for constructive discharge.View "Equal Employment Opportunity Comm’n v. Kohl's Dep’t Stores, Inc." on Justia Law

Respondents, two firefighters, objected to orders from their superiors that they serve as part of the crew of a fire engine in the 2001 Pride Parade. Notwithstanding their objections, Respondents were ordered to cary out the task assigned, and they reluctantly took part in the parade. Thereafter, Respondents sued Petitioners, the former Providence Mayor and former Chief of the Providence Fire Department, as well as the City of Providence, on a variety of state and federal claims. Petitioners moved for summary judgment on two of those claims, invoking the doctrine of qualified immunity from suit. The superior court denied the motion for summary judgment. The Supreme Court quashed the judgment of the superior court, holding that, in view of the facts of this case, it was not necessary to invoke the doctrine of qualified immunity because no constitutional violation occurred. Remanded with instructions that Petitioners’ motion for summary judgment be granted.View "Fabrizio v. City of Providence" on Justia Law

Plaintiff Cynthia Felkins, formerly an emergency dispatcher for the City of Lakewood, alleged she suffered from a condition called avascular necrosis that qualified as a disability under the Americans with Disabilities Act (ADA). She claimed the City refused to accommodate that disability. She brought suit against the City under the Act, but the district court granted the City summary judgment. Upon review, the Tenth Circuit affirmed: Felkins’s claim failed because she presented no expert medical evidence that any of her major life activities have been substantially limited by avascular necrosis.View "Felkins v. City of Lakewood" on Justia Law

Brown, a black female law professor at the University of the District of Columbia School of Law (DCSL), had worked for DCSL in various capacities for more than 20 years when she applied for tenure and promotion. The Faculty Evaluation Committee recommended tenure and transmitted her application to Dean Broderick, who initially recommended that the Committee withdraw its approval due to the sparseness and quality of Brown’s legal scholarship. Once Broderick learned that a law journal agreed to publish another of Brown’s articles, she endorsed the recommendation and forwarded her approval to then–Interim Provost Baxter, who rejected the application. President Sessoms agreed that Brown should not be awarded tenure and did not submit Brown’s application to the Board. Around the same time, the administration considered the tenure application of McLain, a white male. Brown alleges that McLain had “no legal publications” but that Broderick did not insist that he satisfy the three-publication requirement, as Broderick had with Brown’s application. The Board awarded him tenure and a promotion to full professor. Brown sued. The district court dismissed. The D.C. Circuit reversed dismissal of Brown’s D.C. Human Rights Act and 42 U.S.C. 1981 claims and affirmed dismissal of her other claims.View "Brown v. Sessoms" on Justia Law

At issue in these two cases was the applicable scope of Ky. Rev. Stat. 15.520, which sets forth specific procedural rights for police officers who are accused of misconduct and face the disciplinary processes administratively conducted by the police agency that employs them. Appellants in both cases were police officers who were subjected to administrative disciplinary actions that were initiated as a result of allegations that arose from within the police department itself. Both officers requested an administrative review procedure consistent with section 15.520. The requests were denied. Each Appellant sought review of the disciplinary actions in circuit court. The circuit courts concluded that the officers were not entitled to an administrative hearing subject to the due process provisions of section 15.520. The appeals courts affirmed, determining that section 15.520 applies only when the disciplinary action was initiated by a “citizens complaint.” The Supreme Court reversed, holding that section 15.520 applies to both disciplinary proceedings generated by citizen complaints and those initiated by intra-departmental actions. Remanded.View "Pearce v. Univ. of Louisville" on Justia Law

Plaintiff, a longtime steelworker in Lackawanna, New York, endured racial insults, intimidation, and degradation over more than three years, including slurs, evocations of the Ku Klux Klan, statements comparing black men to apes, death threats, and placement of a noose dangling from the plaintiff’s automobile. Supervisorsʹ meager efforts failed to stop the escalating abuse. Managers often appeared to condone or participate in part in the harassment. A jury awarded $1.32 million in compensatory damages for hostile or abusive work environment because of his race and the state tort of intentional infliction of emotional distress. The jury also assessed $24 million in punitive damages, mostly against the employer and its parent company, subsequently reduced to $5 million. The court also awarded the plaintiff substantial attorney fees and costs. The Second Circuit affirmed, but remanded for further reduction of punitive damages, holding that the district court correctly instructed the jury as to employer liability, that the jury could find that the plaintiff’s direct employer and the parent company constituted a single employer, that the jury verdict as to intentional infliction of emotional distress was supported by the evidence, and that the compensatory damages award was proper.View "Turley v. ISG Lackawanna, Inc." on Justia Law

Plaintiff filed suit against his employer, the GPO, alleging unlawful discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The district court granted summary judgment to the GPO. Plaintiff's claims on appeal involve the GPO's alleged discrimination in not promoting him to Second Offset Pressperson and the GPO's alleged retaliation in excluding him from a Georgia training program. The court concluded that plaintiff failed to raise a genuine issue of material fact regarding whether the GPO's legitimate nondiscriminatory reason for not promoting him - he was not qualified for the position he was seeking - was pretextual. Assuming arguendo that plaintiff's exclusion from the training program was sufficiently adverse, he failed to offer evidence demonstrating that the GPO's proffered reason for denying him training - that the decisionmaker thought he did not want it - was pretextual. Accordingly, the court affirmed the judgment.View "Hairston v. Vance-Cooks" on Justia Law

Kristy Sones worked as a nurse for LHC, a home-health company, until she was terminated shortly after she had an epileptic seizure. The EEOC brought an enforcement action on her behalf against LHC under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. The district court subsequently granted summary judgment for LHC on all claims. The court affirmed summary judgment on the EEOC's failure-to-accommodate claim; affirmed partial summary judgment to the extent Sones was a Field Nurse because she was not qualified for that position; but concluded that there were genuine disputes of material fact remaining as to (1) whether Sones was promoted to Team Leader, (2) if so, whether LHC could reasonably accommodate her disability, (3) whether LHC engaged in the required interactive process to seek accommodation, and (4) whether Sones was terminated on account of her disability. The court reversed and remanded for further proceedings as to these issues.View "EEOC v. LHC Group, Inc." on Justia Law

Gloria Daniel was fired from her position as a registered nurse at the Arkansas State Hospital thirteen months after she reported to Charles Smith, the hospital’s administrator, that a patient’s death was attributable to abuse or neglect on the part of the hospital. Daniel filed suit, asserting claims under the Arkansas Whistle-Blower Act, the Arkansas Civil Rights Act, and federal law, naming as Defendants Smith in his individual and official capacities, and Betty Mains in her official and individual capacities as the hospital’s assistant administrator. The circuit court concluded that Daniel’s claim for retaliation was not barred by sovereign immunity and that Defendants were not entitled to qualified immunity. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the circuit court (1) did not err in denying Defendants’ motion for summary judgment based on sovereign immunity; and (2) erred in denying Defendants’ motion for summary judgment to dismiss the individual-capacity claims based on qualified statutory immunity grounds.View "Smith v. Daniel" on Justia Law

Burnside, a sergeant for the Nueces County Sheriff’s Department, was assigned to the patrol division. Burnside also served as chairman of a law enforcement political action committee (PAC). In 2012, Sheriff Kaelin, up for re-election in a contested race, approached Burnside while Burnside was on duty and told him that the PAC should support Kaelin’s re-election bid. Burnside said that he would not treat Kaelin differently from any other candidate and that PAC members would vote on the endorsement. Kaelin told Burnside that Kaelin would move him to jail duty if the PAC did not support Kaelin’s candidacy. Kaelin knew that Burnside personally supported Kaelin’s opponent. That the PAC did not support Kaelin, was common knowledge. Three weeks after the PAC failed to endorse Kaelin, Kaelin transferred Burnside to the “extremely less desirable position” of jail duty. Burnside continued to work at the jail for a year. In 2013, his employment was terminated because of the dissemination of a recording containing Kaelin’s threat against another officer. Burnside sued under 42 U.S.C. 1983. Kaelin was denied the defense of qualified immunity. The Fifth Circuit reversed as to the termination claim and affirmed denial of qualified immunity as to the transfer claim.View "Burnside v. Nueces Cnty." on Justia Law