Justia Civil Rights Opinion Summaries

Plaintiff filed suit under the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A et seq., alleging that the County discriminated her based on her sex and her age when they terminated her employment. Plaintiff also claimed that the County retaliated against her after she took leave under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601. On appeal, plaintiff challenged the district court's grant of summary judgment on her MHRA discrimination claims. The court concluded that the County offered a non-discriminatory, legitimate justification for its conduct - plaintiff was terminated based on her repeated record-keeping errors - and plaintiff failed to show that the County's reasons for firing her was pretextual. Therefore, the court affirmed the district court's grant of summary judgment on plaintiff's sex discrimination claim. Further, plaintiff failed to present sufficient evidence to create a genuine issue of material fact as to her sex-plus age discrimination claim where her two male co-workers of comparable age did not engage in sufficiently similar misconduct or have a similar disciplinary history. Accordingly, the court affirmed the judgment of the district court. View "Doucette v. Morrison County, Minnesota" on Justia Law

The EEOC and Adam Breaux, a terminated employee of PFI, appealed the district court's adverse grant of summary judgment in favor of PFI. Breaux asserted that PFI discriminated against him based on his right shoulder injury and the district court erred in granting summary judgment on this claim. The court concluded that the year-long period that PFI accommodated Breaux's injury negated causation; and the casual, somewhat ambiguous conversation that took place in August 2009, does not establish a causal connection between Breaux's termination and his disability. Even if a prima facie case was established, because PFI has advanced a legitimate nondiscriminatory reason for terminating Breaux - poor performance - the burden shifted back to the EEOC and Breaux to show that PFI's proffered reason is pretext for intentional discrimination. In this case, the EEOC and Breaux failed to show pretext. Therefore, the district court correctly granted summary judgment on the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), discrimination claim. Further, the district court properly granted summary judgment on the ADA failure-to-accommodate claim where Breaux failed to prove that he requested an accommodation. Because the district court properly dismissed the discrimination and retaliation claims, the court affirmed its dismissal of the successor liability claim. Accordingly, the court affirmed the judgment of the district court. View "EEOC v. Product Fabricators, Inc., et al." on Justia Law

Over several years, Douglas sexually abused the dead bodies of murder victims held at the Hamilton County Morgue. His abuse of a body in 1982 led to a false rape conviction. Douglas’s actions were discovered in 2007 after his DNA was matched to semen found in the bodies. Douglas admitted to the abuse. He was under the influence of alcohol, marijuana, or cocaine every time he abused the bodies. Douglas was supervised by Kersker, the morgue director. Kersker admitted having concerns about Douglas’s tardiness and dependability as early as 1980. A co-worker testified that he often smelled alcohol on Douglas before, during, or after his shift. Douglas testified that his cocaine addiction was so bad by 1992 that he could not perform his duties due to heavy shaking. Douglas’s former wife testified that she called Kersker to complain that Douglas was drinking at work. Kersker hung up on her. Kersker may have known that Douglas was often having sex with live women at the morgue. Kersker knew about a domestic violence charge and DUIs because Douglas requested vacation time for incarceration. Douglas testified that he told Kersker about his suicide attempt, his psychiatric hospital stay, and his alcoholism. Kersker’s supervision of Douglas never changed. Relatives sued Douglas, who was also convicted of gross abuse of a corpse, and his supervisors, under 42 U.S.C. 1983. The district court rejected the claims. The Sixth Circuit affirmed. A jury could find that the defendants recklessly and wantonly failed to supervise Douglas despite the known risks he posed to the bodies, so the court properly denied Ohio statutory immunity. The relatives, however, cannot establish a constitutional violation, despite the special nature of their relationship to their deceased relatives.View "Range v. Douglas" on Justia Law

Plaintiff filed suit against defendant, individually and in his official capacity as a circuit judge, alleging violations of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., the Rehabilitation Act, 29 U.S.C. 701 et seq., and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq, as well as statutory violations. Plaintiff contended that defendant unlawfully discriminated against him on the basis of a disability, his back injury, by terminating him and by failing to accommodate his disability, and retaliated against him for requesting an accommodation. The court concluded that no genuine issue of material fact exists for trial regarding whether defendant discriminated against plaintiff on the basis of his disability; the record demonstrated that defendant accommodated all of plaintiff's known limitations during the period of his employment at issue; and defendant did not violate the ADA and the Rehabilitation Act by retaliating against him for requesting accommodation for his disability where plaintiff failed to establish a genuine issue for trial regarding a causal connection; and plaintiff failed to make a submissible case of interference with his FMLA rights. Accordingly, the court affirmed the judgment of the district court. View "Withers v. Johnson, et al." on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of Prairie Ethanol on his claim of disability discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12201 et seq. Assuming, without deciding, that plaintiff established a prima facie case of disability discrimination, Prairie Ethanol has offered a legitimate, non-discriminatory justification for terminating his employment - plaintiff's overly aggressive style of operating the plant, which resulted in the plant machinery swinging on three occasions and nearly losing the plant on one of those three occasions. Prairie Ethanol's performance-related concern constituted a legitimate, non-discriminatory justification for discharging plaintiff. Accordingly, the court affirmed the district court's judgment. View "Cody v. Prairie Ethanol, LLC" on Justia Law

Plaintiff, employed as an attorney advisor for the BVA, filed suit against the Secretary of the VA, claiming that the BVA had violated her rights under the Rehabilitation Act of 1973, 29 U.S.C. 701 et seq., by failing to accommodate her disability. Plaintiff also claimed that she was constructively discharged because the failure to accommodate her disability left her no choice but to resign. In regards to the failure to accommodate claim, no reasonable jury could find that plaintiff's accommodation request was denied in light of the BVA's continuing good-faith dialogue with plaintiff to determine an appropriate accommodation, which dialogue was cut short by plaintiff's sudden resignation. Consequently, plaintiff's constructive discharge claim also failed. Accordingly, the court affirmed the district court's grant of summary judgment to the Secretary on both claims. View "Ward v. McDonald" on Justia Law

Plaintiff, a nursing home activities aide, filed suit against her employer, Woodland, under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., after she was discharged because she refused to pray the Rosary with a patient. Plaintiff alleged that Woodland discharged her for exercising her religious beliefs. The court found that there was no evidence in the record that Woodland knew of plaintiff's beliefs before discharging her and held that a reasonable jury would not have had a legally sufficient basis to find that Woodland violated Title VII by discharging her. Accordingly, the court reversed the district court's denial of Woodland's motion for judgment as a matter of law, vacated the judgment, and remanded for entry of judgment. View "Nobach v. Woodland Village Nursing Ctr., et al." on Justia Law

Plaintiff filed suit against her employer, alleging violations of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601; the Equal Pay Act, 29 U.S.C. 206; Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq.; and the Consolidated Omnibus Budget Reconciliation Act (COBRA), 29 U.S.C. 1161 et seq. Plaintiff's claims stemmed from her employer's denial of her request to take FMLA leave after the birth of her child. The court held that the district court correctly awarded summary judgment to the employer with respect to plaintiffs' claims under Title VII and the Equal Pay Act, and did not abuse its discretion by assessing a statutory COBRA penalty against the employer; the district court erred by dismissing plaintiff's FMLA claim and by refusing to consider her additional litigation-related expenses as part of an attorney's fee award; and, therefore, the court affirmed in part, vacated in part, and remanded in part. View "Evans v. Books-A-Million" on Justia Law

Plaintiff filed suit against her employer, alleging claims of retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. Plaintiff also alleged that her employer and several managers retaliated against her in violation of the Family Medical Leave Act (FMLA), 28 U.S.C. 2601 et seq. The district court granted summary judgment in favor of defendants. The court rejected the idea that the passage of a particular amount of time between protected activity and retaliation can bar the claim as a matter of law. In this case, plaintiff has offered evidence of other retaliatory behavior between her 2003 sexual harassment complaint and the 2006 reorganizations and demotion that bridged the gap between the two events, leaving the issues of causation for a jury. Accordingly, the court reversed and remanded for trial. View "Malin v. Hospira, Inc., et al." on Justia Law

Plaintiff appealed the district court's order of summary judgment rejecting her claim of workplace racial discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The court concluded that plaintiff failed to identify evidence from which a reasonable jury could find that her non-promotion was racially discriminatory. Accordingly, the court affirmed the judgment of the district court. View "Mulrain v. Castro" on Justia Law