Justia Civil Rights Opinion Summaries

Loyd, an African-American woman, began working as a hospital security guard in 1986. In 2001 Loyd had a written warning for failing to help restrain a patient because she questioned the authority of the medical staff to have the patient restrained. Loyd received a warning in 2004 for refusing to work overtime. In 2010 Loyd left work due to illness without first obtaining permission, and, another time, was found on the porch of a nearby house while on duty. The hospital placed Loyd on final-written-warning status. Loyd was dispatched on June 16, 2011 to a room containing a combative female psychiatric patient. Instead of helping to restrain the patient, according to the hospital, Loyd told the patient that she could leave if she had been admitted for a drug-related or alcohol-related (not psychiatric) reason and demanded to see the admissions paperwork. Loyd’s actions agitated the patient, who tried to pull an IV out of her arm. Other guards restrained the patient. Loyd admits much of the incident, but denies that she failed to assist. The hospital conducted an internal investigation, after which it terminated Loyd’s employment. Loyd filed a union grievance, which was denied. The union declined to seek arbitration. The hospital hired a 39-year-old African-American woman for the position. After filing charges of discrimination with the EEOC and Michigan Department of Civil Rights, Loyd filed suit. The district court granted the hospital summary judgment on all claims. The Sixth Circuit affirmed.View "Loyd v. Saint Joseph Mercy Oakland" on Justia Law

Moultrie, who began working at Penn Aluminum in southern Illinois in1990 and held various positions, was demoted from his position as a forklift operator in 2009. Before his demotion, he had filed a grievance concerning a work assignment. That grievance did not allege racial discrimination. He filed another grievance, after the demotion, again not mentioning race. After his claims were rejected by the Illinois Department of Human Rights and the EEOC, Moultrie sued. Penn asserted that Moultrie was demoted because of performance problems that caused delays and other problems and about which he was repeatedly warned. Moultrie, attributed Penn’s decision to racial discrimination and retaliation and claimed that Penn’s conduct violated the collective-bargaining agreement. The district court dismissed an Illinois state-law claim as time barred and entered summary judgment against Moultrie on all remaining claims. The Seventh Circuit affirmed. Moultrie failed to provide sufficient evidence to support his discrimination and retaliation claims. View "Moultrie v. Penn Aluminum Int'l, LLC" on Justia Law

In 2006, after coworkers made offensive comments, orally and in graffiti, about Muhammad’s race and perceived sexual orientation, Muhammad complained to management. Caterpillar responded. Walls were repainted and employees were warned that anyone caught defacing the walls would be fired. Six weeks later, Muhammad left his work station during non-break time to use the restroom, and checked the bid board before returning to work. Supervisor Edwards confronted him about use of work time to check the board. Edwards contends that Muhammad responded with disrespectful comments and walked away. Muhammad claimd that he did not act disrespectfully, but did not want to discuss it without a union representative present. Edwards suspended Muhammad and walked him out of the plant, allegedly for insubordination. After an internal investigation, the suspension was deemed appropriate. Muhammad filed a grievance through his union and was allowed to return to work. He was suspended again and later terminated based on his conduct upon his return. Following settlement of his grievance of the termination, he returned to work. He was later laid off in a reduction in force. He was subsequently rehired and remains employed at Caterpillar. Based on the 2006 incidents, Muhammad filed charges of harassment and retaliation with the EEOC. After receiving a right-to-sue letter, he sued, claiming hostile work environment and retaliation. The district court entered summary judgment for Caterpillar. The Seventh Circuit affirmed, reasoning that the company reasonably responded to complaints of harassment and no evidence suggested that Caterpillar suspended Muhammad because he complained. View "Muhammad v. Caterpillar, Inc." on Justia Law

Annex, Stuart Lind, and Tom Janas filed suit challenging HHS' contraceptive mandate under the Religioous Freedom Restoration Act (RFRA), 42 U.S.C. 2000bb-1(a). Lind, a controlling shareholder of Annex, opposed insurance coverage of contraceptives for Annex's employees. The district court denied Annex and Lind's motion for a preliminary injunction respecting the contraceptive mandate's enforcement. The court concluded that Janas lacks standing to appeal because he did not join the preliminary injunction motion which forms the basis of the appeal; the mandate does not apply to Annex because Annex has fewer than fifty full-time employees and has no government-imposed obligation to offer health insurance of any kind; the only alleged injury is that independent third parties - private health insurance companies not involved in this case - are unable to sell Annex a health insurance plan that excludes healthcare inconsistent with Lind's religious relief; and, ultimately, it is unclear whether Annex's alleged injury is caused by the government defendants and redressable by the federal courts. Accordingly, the court vacated the district court's denial and remanded for the district court to conduct more fact-finding to determine whether subject matter jurisdiction exists. View "Annex Medical, Inc., et al. v. Sebelius, et al." on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of his former employers, BoA, on his claim of age discrimination under the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. 621 et seq., and breach of contract. Under the McDonald Douglas Corp v. Green framework, assuming arguendo that plaintiff met his burden of demonstrating a prima facie case of age discrimination, the court agreed with the district court that BoA has satisfied its burden to articulate a legitimate, nondiscriminatory reason for plaintiff's termination. BoA has explained that plaintiff's employment was terminated as part of a company-wide reduction in force; two months prior to his termination, plaintiff received a negative mid-year performance review; and as of September 2010, plaintiff was ranked 136th across all BoA sales personnel for the year and his performance was the worse of all employees in his group. In regards to the breach of contract claim, the district court correctly determined that plaintiff was an at-will employee and that although annual bonuses were discretionary, there is no record evidence, or even an allegation, indicating that plaintiff was promised a mid-year bonus. Accordingly, the court affirmed the judgment of the district court. View "Delaney v. Bank of America Corp." on Justia Law

Plaintiff filed suit against the City under 42 U.S.C. 1981 and Title VII of the Civil Rights Act, 42 U.S.C. 2000e-1, for racial discrimination. The district court dismissed the complaint for failure to allege an adverse employment action under Rule 12(b)(6). The court concluded that, viewing the factual allegations in the light most favorable to plaintiff, plaintiff plausibly alleged that he was subject to the equivalent of a demotion. Accordingly, the court reversed and remanded for further proceedings. View "Thompson v. City of Waco, TX" on Justia Law

Plaintiff appealed a judgment in favor of his former employer and against his complaint of racial discrimination and retaliation. At issue was whether the district court erred when it entered a judgment as a matter of law based on inconsistent jury verdicts. The court held that, to determine whether to grant a judgment as a matter of law, the district court should have considered only the sufficiency of the evidence in support of the verdict, not the consistency of that verdict with another. Accordingly, the court vacated and remanded for the district court to reinstate the jury verdict against the employer for retaliation. The court affirmed summary judgment against plaintiff's claim of discrimination against plaintiff's supervisor. View "Connelly v. Metropolitan Atlanta Rapid Trans., et al." on Justia Law

Plaintiff, who suffered from Crohn’s disease, brought suit against the University of Puerto Rico, her former employer, and Marisol Gomez-Mouakad (Gomez), her former supervisor, alleging that the defendants did not renew her employment contract in retaliation for her complaining about disability-discrimination. Plaintiff filed a retaliation against both defendants under the Americans with Disabilities Act and asserted a First Amendment free-speech retaliation claim against Gomez under 42 U.S.C. 1983. The district court granted summary judgment for the defendants. The First Circuit affirmed, holding (1) Plaintiff failed to show that the defendants’ legitimate, nonretaliatory reasons for not renewing her contract were pretextual; and (2) Plaintiff failed to show that her speech was both protected and a substantial or motivating factor in the defendants’ adverse-employment decision. View "Collazo-Rosado v. Univ. of P.R." on Justia Law

Scheick was hired as Principal of Tecumseh High School in 2004, at 51 years of age, and continued in that position until 2010. For the first three years, Scheick was employed directly by TPS. Then, by agreement, the 54-year-old Scheick formally retired from TPS and was hired by the staffing firm PESG to continue working as principal under a three-year contract between TPS and PESG. Under that arrangement, Scheick began receiving pension and health care benefits from the retirement system, and TPS avoided more than $29,000 in payroll and benefit costs per year. The next year, several other TPS employees entered into similar arrangements as cost-saving measures. In early 2010, when Scheick was almost 57 years of age, TPS decided not to renew the contract. Scheick claimed that the contract was not renewed because of his age and filed suit against TPS after receiving a right-to-sue letter from the EEOC. The district court entered summary judgment, rejecting claims under the Age Discrimination in Employment Act, 29 U.S.C. 623(a)(1), and Michigan’s Elliott-Larsen Civil Rights Act, Mich. Comp. Laws 37.2202(1)(a). The Sixth Circuit reversed and remanded, finding a genuine issue of material fact.View "Scheick v. Tecumseh Pub. Schls." on Justia Law

Olendzki is a psychologist at an Illinois state prison. After he was elected to his union’s Executive Board, Olendzki began to advocate for fellow union members and to voice concerns to management. Olendzki believes that this advocacy led to hostile relationships with his superiors and caused them to retaliate against him by removing him from a hostage crisis team; ordering him to meet with mentally ill inmates without guard supervision in the same room; relocating his office; increasing his workload; filing a harassment claim against him; not providing a written justification to Olendzki’s request for advance leave time, which resulted in the denial of the request; and revising institutional directives that affected Olendzki’s job duties without Olendzki’s input. Olendzki was never fired, disciplined, or denied an employment opportunity. He sued six of his superiors under 42 U.S.C. 1983, claiming that they retaliated against him for his union advocacy, a violation of his First Amendment rights. The district court granted the defendants summary judgment. The Seventh Circuit affirmed, finding that Olendzki was acting as a union official, not as a public employee, when he made the statements at issue, so that they were not protected under the First Amendment. View "Olendzki v. Rossi" on Justia Law