Justia Civil Rights Opinion Summaries

Crugher, a Michigan Department of Corrections (MDOC) employee working at the Ionia Correctional Facility (ICF), sued Prelesnik, the warden of the ICF, claiming that Crugher was retaliated against, subjected to harassment and intimidation, and ultimately terminated after he took time off under the self-care provision of the Family Medical Leave Act (FMLA), 29 U.S.C. 2612(a)(1)(D). Crugher sought reinstatement. The district court dismissed on the grounds that the claim is barred by sovereign immunity or, alternatively, was untimely under the two-year limitations period in the FMLA. The Sixth Circuit affirmed, holding that an action by a state employee seeking prospective injunctive relief (reinstatement) against a state official under the FMLA’s self-care provision is subject to the limitations period contained in the FMLA. In addition, Crugher failed to state a willful violation of the FMLA; allowing Crugher to amend his complaint to allege willfulness, to take advantage of an extended three-year limitations period, would be futile. View "Crugher v. Prelesnik" on Justia Law

Madison Teachers, Inc. and Public Employees Local 61 sued Governor Walker and three commissioners of the Wisconsin Employment Relations Commission challenging several provisions of Act 10, a budget repair bill that significantly altered Wisconsin’s public employee labor laws. Plaintiffs (1) alleged that certain aspects of Act 10 violate the constitutional associational and equal protection rights of the employees they represent; and (2) challenged Wis. Stat. 62.623, a separate provision created by Act 10, as a violation of the home rule amendment to the Wisconsin Constitution, and argued, in the alternative, that section 62.623 violates the constitutionally protected right of parties to contract with each other. The circuit court invalidated several provisions of Act 10, including the collective bargaining limitations, annual recertification requirements, and the prohibitions of fair share agreements and on payroll deductions of labor organization dues. The Supreme Court reversed and upheld Act 10 in its entirety, holding (1) Plaintiffs’ associational rights argument is without merit; (2) Act 10 survives Plainiffs’ equal protection challenge under rational basis review; (3) Plaintiffs’ home rule amendment argument fails because section 62.623 primarily concerns a matter of statewide concern; and (4) Plaintiffs’ Contract Clause claim fails. View "Madison Teachers, Inc. v. Walker" on Justia Law

Michael Dunn worked for Boston University (BU) from 1992 until 2010, at which time Dunn’s job was allegedly eliminated due to restructuring. Dunn brought suit against BU in Massachusetts superior court, claiming age discrimination in violation of both state and federal law. BU removed the case to federal district court. The district court granted summary judgment in favor of BU, concluding that Dunn had not made out a prima facie case that he was laid off because of his age. The First Circuit affirmed without ruling on the sufficiency of Dunn’s prima facie showing, holding that, even assuming that Dunn made a prima facie showing of age discrimination, Dunn failed to demonstrate a genuine issue of material fact as to whether BU’s stated reasons for discharging him were a pretext for unlawful discrimination. View "Dunn v. Trs. of Boston Univ." on Justia Law

The Alaska Workers' Compensation Board denied a death benefit claim filed by the decedent's same-sex partner because the death benefit statute grants benefits only to a worker’s "widow or widower" as defined by statute. The Board construed these terms by applying the Marriage Amendment to the Alaska Constitution, which defined marriage as "only between one man and one woman," thus excluding a decedent's same-sex partner. Because this exclusion lacked a fair and substantial relationship to the purpose of the statute, the Supreme Court concluded that this restriction on the statutory definition of "widow" violated the surviving partner's right to equal protection under the law. View "Harris v. Millennium Hotel" on Justia Law

Plaintiff filed suit against his former employer, Cablevision, alleging claims of race discrimination and retaliation under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq. On appeal, plaintiff challenged the district court's grant of summary judgment for Cablevision on both claims and the district court's dismissal of plaintiff's pendant state law claims. The court concluded that the district court overlooked evidence raising a genuine factual dispute as to whether Cablevision's justifications for firing plaintiff were a pretext for race discrimination and retaliation, and a rational jury could find that Cablevision discriminated against plaintiff and fired him in violation of Title VII. Accordingly, the court vacated and remanded for trial. View "Kirkland v. Cablevision Systems" on Justia Law

Plaintiff filed suit against Verizon, alleging that the company discriminated against her, subjected her to a sexually hostile work environment, retaliated against her, and paid her less than her male colleagues for equal work. On appeal, plaintiff challenged the district court's grant in part of Verizon's motion to dismiss and motion for summary judgment, and denial of plaintiff's motion to compel production of documents. The court concluded that the district court erred when it refused to consider all allegations in the complaint in their totality, including those that were not sexually offensive in nature; the district court abused its discretion when it denied plaintiff's motion to compel documents related to Verizon's Reduction in Force events; and the district court erred when it refused to consider a witness's statements in an affidavit that contradicted prior deposition testimony. Accordingly, the court vacated the district court's judgment and remanded for further proceedings. View "Moll v. Telesector Resources Group, Inc." on Justia Law

Plaintiffs filed suit under Title VII of the Civil Rights Act, 42 U.S.C. 2000e-3, against the Department, alleging claims of retaliation for their complaints of racial harassment to the EEOC. Plaintiffs had shaved their heads to demonstrate solidarity with one of the plaintiffs who had cancer and lost his hair as a result of chemotherapy. The Department subsequently investigated complaints that plaintiffs were "skinheads." The court held that the Department's initiation and conduct of an investigation into the white plaintiffs' claims of racial harassment alleged to have been generated by an African American officer, and a complaint against plaintiffs for filing false reports with the EEOC of such harassment, were not adverse employment actions. The court also held that threats by the Department to charge plaintiffs with making a false report to the EEOC established a prima facie case of illegal retaliation but that the Department has shown a non-retaliatory purpose, and plaintiffs have presented no evidence of pretext. Accordingly, the court affirmed the district court's dismissal of plaintiffs' retaliation claims. View "Cox v. Onondaga Cnty. Sheriff's Dep't." on Justia Law

In 2002, Elizabeth “Betsy” Baumgart was appointed to be the administrator of the Montana Tourism and Promotion Division of the Department of Commerce (DOC). In 2010, after Dore Schwinden was appointed as DOC director, Schwinden terminated Baumgart’s employment, citing a lack of management competencies and sufficient understanding of the Division’s budgeting process. Baumgart sued the DOC and Schwinden, individually and as DOC’s agent, alleging that DOC wrongfully discharged her and discriminated against her on political grounds because she was a Republican and Schwinden was a Democrat. The district court granted DOC’s motion for summary judgment as it pertained to Baumgart’s political affiliation discrimination claims and all claims against Schwinden. The Supreme Court affirmed, holding (1) because Baumgart failed to establish a prima facie case for political discrimination, the district court did not err in granting DOC’s motion for summary judgment on this issue; (2) the district court correctly dismissed the individual claims against Schwinden, as Schwinden was entitled to statutory immunity under the circumstances of this case; and (3) the district court correctly concluded that the DOC had good cause to terminate Baumgart. View "Baumgart v. Dep't of Commerce" on Justia Law

In 2006, Matthews, an African-American woman, applied for two open positions in Waukesha County: Economic Support Specialist and Economic Support Supervisor. She was not hired, and filed suit, alleging that she was discriminated against on the basis of race, in violation of Title VII, 42 U.S.C. 1981, and 42 U.S.C. 1983.Matthews dismissed her claim related to the Supervisor position. With respect to the Specialist position, the district court granted the defendants summary judgment. The Seventh Circuit affirmed, stating that the county articulated a legitimate, nondiscriminatory basis for its hiring decision. View "Matthews v. Waukesha Cnty." on Justia Law

Bell was employed as a substance abuse counselor at an Indiana maximum security prison. An investigator, looking for security breaches, discovered that night-shift employees were having sex on Bell’s desk and told her that he was not concerned about night-shift staff having sex but suggested she wash her desk every morning. The superintendent said that, as long as inmates were not involved, he was not concerned. Immediately thereafter, the superintendent discovered that Bell was having an affair with the Major in charge of custody (allegedly involving sex on his desk) and both were terminated. The prison settled the Major’s appeal to the State Employees’ Appeals Commission and called him to testify against Bell at her appeal. Major was able to keep his benefits, including his pension, to quickly get unemployment benefits, and to subsequently begin working at the prison as a contractor. Bell was not afforded similar benefits and opportunities and filed suit, alleging Title VII claims of sex discrimination, retaliation, and hostile work environment. The district court granted summary judgment to the state, concluding that Bell was not similarly situated to the Major, that she failed to prove retaliation, and that the sexual tenor of the prison’s work environment was not severe or pervasive enough to qualify as hostile. The Seventh Circuit reversed with regard to the discrimination and hostile environment claims, but affirmed with regard to her retaliation claims. View "Orton-Bell v. State of Indiana" on Justia Law