Justia Civil Rights Opinion Summaries

Plaintiff appealed the district court's dismissal of his original complaint against DIL and his amended complaint against DIL's wholly-owned subsidiary, Daikin America. Plaintiff, a white male of United States origin, alleged that DIL and Daikin discriminated against him on the basis of his race and national origin. Plaintiff claimed that, for discriminatory reasons, Daikin America did not consider terminating any of the Japanese rotational employees or any employees of Japanese national origin who had been hired directly by Daikin America. The court concluded that, under the standards articulated in Cook v. Arrowsmith Shelburne, Inc., plaintiff sufficiently alleged that DIL was part of a "single integrated enterprise" with Daikin America to be properly named as a codefendant; plaintiff plausibly alleged a claim of race and national origin discrimination against both defendants; and, therefore, the court vacated and remanded for further proceedings. The court affirmed the judgment of the district court dismissing plaintiff's breach of contract claim because he failed to allege that either defendant maintained a written policy of terminating employees only for cause. View "Brown v. Daikin America Inc." on Justia Law

Plaintiff filed a 42 U.S.C. 1983 suit against the County and the sheriff after he was terminated as deputy sheriff. The court concluded, under the Pickering/Connick balancing test, that at least some of plaintiff's campaign speech does not merit First Amendment protection; that even if plaintiff's speech was fully protected by the Constitution, the sheriff could have reasonably believed that the speech would be at least potentially damaging and disruptive of the discipline and harmony of and among coworkers in the sheriff's office and detrimental to the close working relationships and personal loyalties necessary for an effective and trusted local policing operation; considering North Dakota law and well-established federal and state jurisprudence, the sheriff could have logically and rationally believed that his decision to terminate plaintiff was well within his duties as a public official; and that the sheriff was entitled to qualified immunity to shield him from any liability. Accordingly, the court reversed the district court's denial of the sheriff's motion for summary judgment. View "Nord v. Walsh County, et al." on Justia Law

Plaintiff filed suit against defendants after she was temporarily removed from the office of the Clinton County Election Commissioner during her candidacy for Beekmantown Town Justice. Plaintiff alleged that her removal from office under Clinton County Local Law No. 1 was an unconstitutional retaliation for the exercise of her First Amendment rights in running for elective office. The court agreed with the district court that plaintiff's evidence failed to show a genuine issue of material fact supporting her claim of unconstitutional retaliation. The court affirmed the district court's judgment insofar as it dismissed her federal claim. The court vacated, however, the district court's grant of summary judgment for defendants on plaintiff's claim seeking a declaratory judgment that Local Law No. 1 is void under New York state law. The timing of the claim raises a substantial question whether the claim was moot. Therefore, the court remanded to the district court to consider the question of mootness in the first instance. View "Castine v. Zurlo" on Justia Law

Plaintiff, an African-American woman who was serving in the United States Coast Guard Housing Office at Air Station Cape Cod, filed an employment discrimination action against the Secretary of Homeland Security, asserting that the Secretary failed to promote her to the position of housing manager because of her race and gender. The district court granted summary judgment in favor of the Secretary, concluding that Plaintiff failed to generate a genuine issue of material fact as to whether the Secretary’s non-discriminatory reason for choosing another candidate was pretextual. The First Circuit Court of Appeals affirmed, holding (1) the district court acted within the bounds of its discretion in denying Plaintiff’s motion to reopen discovery shortly after retaining counsel; and (2) the Secretary was entitled to summary judgment because Plaintiff failed to generate a genuine issue of material fact on the issue of pretext. View "Hicks v. Napolitano" on Justia Law

When control of the Puerto Rican government changes parties, the political party assuming office often terminates the employment of public employees affiliated with the party going out of power and fills the vacancies with its own members. Plaintiff, a Popular Democratic Party (PDP) activist, was employed with a trust position at Puerto Rico’s State Insurance Fund Corporation (SIFC) while the PDP was in power. Plaintiff was moved into a career position at the SIFC when it became clear the opposing party would win an upcoming election. Had Plaintiff remained in a trust position, his employment could have been terminated without violating the First Amendment. A subsequent audit of employees performed by the new administration revealed that Plaintiff’s appointment did not conform with Puerto Rican law. Plaintiff’s reclassification to a career position was subsequently annulled, and he was dismissed. Plaintiff filed suit against SIFC and other defendants, alleging that he was terminated because of his political association in violation of the First and Fourteenth Amendments. The district court concluded that Defendants were entitled to summary judgment under the Mt. Healthy doctrine. The First Circuit affirmed, holding that Plaintiff failed to produce any evidence that undermined Defendants’ proffered nondiscriminatory reasons for his reclassification and later termination. View "Reyes-Perez v. State Ins. Fund Corp." on Justia Law

In 2011, the Michigan City Area Schools hired Nichols as a temporary, substitute janitor. Nichols worked at Joy Elementary School without incident. He then went to Springfield Elementary School as a replacement until a permanent janitor could be found for a recently retired janitor. He claims that employees there spoke to him in a mocking tone, tried to entrap him into taking a purse because he is African-American, and acted in a “bullying” manner. Other employees claimed that they felt threatened by Nichols’s strange behavior, which included taking pictures of one of them. Nichols was told that the custodial position had been filled with a permanent employee and that they would call him if they needed his services, but they never did. Nichols filed a pro se complaint asserting racial harassment and discrimination. The district court granted Michigan City summary judgment, finding that the complained-of conduct did not give rise to Title VII liability. The Seventh Circuit affirmed. View "Nichols v. MI City Plant Planning Dep't" on Justia Law

Lane, Director of CITY, a program for underprivileged youth operated by Central Alabama Community College (CACC), discovered that Schmitz, a state representative on CITY’s payroll, had not been reporting for work. Lane terminated her employment. Federal authorities later indicted Schmitz on charges of mail fraud and theft concerning a program receiving federal funds. Lane testified, under subpoena, regarding the events that led to Schmitz’s termination. Schmitz was convicted. Meanwhile, CITY experienced significant budget shortfalls. CACC’s president, Franks, terminated Lane and 28 others, citing those shortfalls. Franks rescinded all but two (Lane and another) of the terminations days later. Lane sued Franks in his individual and official capacities under 42 U.S.C. 1983, alleging retaliation for testifying against Schmitz. The district court granted Franks summary judgment, finding the individual-capacity claims were barred by qualified immunity and the official-capacity claims barred by the Eleventh Amendment. The Eleventh Circuit affirmed, reasoning that Lane acted pursuant to his official duties when he investigated and terminated Schmitz. A unanimous Supreme Court reversed in part, first holding that Lane’s sworn testimony outside the scope of his ordinary job duties was protected by the First Amendment. Lane’s testimony was speech as a citizen on a matter of public concern. The critical question is whether the speech at issue is itself ordinarily within the scope of an employee’s duties, not whether it merely concerns those duties. Corruption in a public program and misuse of state funds involve matters of significant public concern; the form and context of the speech, sworn testimony in a judicial proceeding, fortify that conclusion. There is no government interest that favors Franks: there was no evidence that Lane’s testimony was false or erroneous or that Lane unnecessarily disclosed confidential information. Franks is entitled to qualified immunity in his individual capacity. Based on existing Eleventh Circuit precedent, Franks reasonably could have believed that a government employer could fire an employee because of testimony given outside the scope of his ordinary job responsibilities. View "Lane v. Franks" on Justia Law

Plaintiff filed suit against his employer, alleging that the employer violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601, by terminating him based on his diagnoses of alcoholism. The court agreed with the employer that plaintiff was not qualified under DOT regulations to drive a commercial truck because he had a current clinical diagnosis of alcoholism. Because the court determined that plaintiff was not entitled to drive a commercial truck under the DOT regulations, the court need not address whether the employer's company policy also supported that determination. Accordingly, the court affirmed the district court's grant of summary judgment in favor of the employer on the ADA claim. In regards to the FMLA claims, the court agreed with the district court's determination that plaintiff's interference claim failed because the employer would have discharged plaintiff regardless of his FMLA leave, and plaintiff's retaliation claim failed because he could not show that the employer's decision to terminate him was causally related to his FMLA leave. Accordingly, the court affirmed the district court's grant of summary judgment as to the FMLA claims. View "Jarvela v. Crete Carrier Corp." on Justia Law

Plaintiff filed suit alleging that defendant reduced and ultimately terminated plaintiff's consulting work as a forensic psychologist for the Broward County Public Defender's office in retaliation for plaintiff's constitutionally protected testimony about a Florida state court judge. The court vacated the judgment of the district court granting summary judgment to defendant where a reasonable fact-finder could find that defendant was subjectively motivated to reduce and did reduce plaintiff's work because of his testimony and plaintiff's testimony was also a motivating factor behind defendant removing him from the wheel rotation system; affirmed the judgment of the district court granting qualified immunity to defendant in his individual capacity where there was evidence of both lawful and unlawful motivations for defendant's actions and preexisting law did not dictate that the merits of the case must be decided in plaintiff's favor; and remanded for further proceedings. View "Brannon, et al. v. Finklestein" on Justia Law

Plaintiff filed suit against his former employer, the school district, asserting claims of national origin discrimination, retaliation, and intentional infliction of emotional distress. On appeal, plaintiff challenged the removal of his suit from Texas state court and the dismissal of his entire suit. The court held that removal was proper where plaintiff's complaint included claims under Title VII. However, because the district court gave no notice to plaintiff before its sua sponte dismissal of his state law discriminatory termination claim, the court vacated the dismissal of the claim and remanded. View "Davoodi v. Austin Indep. Sch. Dist." on Justia Law