Justia Civil Rights Opinion Summaries

This appeal involved complaints of a racially hostile work environment at a shipyard in Mobile, Alabama, owned by Austal. At issue on appeal was whether an employee may rely on evidence of racial harassment of which he is not personally aware to prove that his work environment was objectively hostile. The court held that an employee alleging a hostile work environment cannot complain about conduct of which he was oblivious for the purpose of proving that his work environment was objectively hostile. In this instance, the court concluded that seven of the employees presented sufficient evidence that their work environments were objectively hostile, and vacated the summary judgment against them. The court affirmed the summary judgment against the remaining six employees and affirmed the two jury verdicts. View "Adams, et al. v. Austal, U.S.A., L.L.C." on Justia Law

Gonzalez sued his former employer, the Waterfront Commission of the New York Harbor, a bi-state instrumentality of New Jersey and New York that was created in 1953 to investigate, deter, combat, and remedy criminal activity in the Port of New York-New Jersey. He sought to enjoin disciplinary proceedings initiated by the Commission as a violation of his rights under Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act, and the First Amendment. The Commission had determined that Gonzalez, an employee (detective) since 1999 had made false statement in an affidavit concerning another employee’s discrimination suit. The district court denied Gonzalez’s motion and ultimately stayed and administratively terminated the suit, finding that the Younger abstention doctrine precluded federal interference with the ongoing state disciplinary proceedings. While appeal was pending, the Supreme Court issued its 2013 decision, Sprint Communications, Inc. v. Jacobs, clarifying the abstention inquiry and defining the outer boundaries of the abstention doctrine. The Third Circuit affirmed, concluding that the decision to abstain was appropriate under the Sprint decision. View "Gonzalez v. Waterfront Comm'n of NY Harbor" on Justia Law

Salt Lake County employee Michael Barrett helped a colleague pursue a sexual harassment complaint against her boss. According to Barrett, his superiors began a campaign to have him discharged or demoted. After he was demoted Barrett filed suit alleging that the county violated Title VII by retaliating against him for helping a coworker vindicate her civil rights. The jury found for Barrett. At trial the county argued that it disciplined Barrett because he was a poor worker. But the evidence showed that Barrett's fourteen years working for the county were marked only by promotions and positive reviews until he helped draw attention to his colleague's plight. On appeal, the county asks the Tenth Circuit to reverse the jury's verdict, but finding no error, the Tenth Circuit affirmed the district court judgment. View "Barrett v. Salt Lake County" on Justia Law

In 2007 Huang, a systems and software engineer, had worked for CNA commercial insurance for eight years. In March, Huang was transferred to a new, four-member team. CNA required every member of Huang’s team to be on “pager duty” every fourth weekend, carrying a pager at home and being available to respond 24 hours a day throughout the assigned weekend. Huang repeatedly refused pager duty, citing family obligations, even after his supervisor and human resources reminded him that he could be fired for refusing. Huang offered to work from the office on Sundays in exchange for having Mondays off but refused pager duty. Around this time, Huang’s supervisor stated, for reasons unrelated to pager duty, that Huang was “pissing [him] off.” Huang emailed the human resources department to complain. Two years earlier, Huang had complained about another supervisor’s “favoritism.” Four months after Huang’s first refusal of pager duty, Huang’s supervisor and a human resources agent gave him one final opportunity to comply. When he refused, CNA discharged him. Consistent with CNA’s practice, it asked Huang for a list of his belongings so that someone could retrieve them from his desk. When Huang refused and demanded to return to his work station, human resources called security. Police escorted Huang out and arrested him. CNA did not press charges. After pursuing administrative remedies, Huang filed suit, claiming discrimination based on race and national origin (42 U.S.C. 1981 and Title VII of the Civil Rights Act, 42 U.S.C. 2000e–2000e-17) and that by firing him and having him arrested, CNA unlawfully retaliated for his earlier complaints. The district court granted CNA summary judgment. The Seventh Circuit affirmed. View "Huang v. Cont'l Cas. Co." on Justia Law

According to the 2010 Census, Hazel Crest was 85.2% black and 10.2% white, but had no black supervisory police officers until 2005. Garofalo and Peers, both white, were sergeants on the police force and were among four front-runners considered for a deputy police chief position, which ultimately went to a black officer who was not one of those four candidates. They claimed that the village discriminated against them by promoting a black officer they contend is unqualified and sued under Title VII of the Civil Rights Act, 42 U.S.C. 2000e, and 42 U.S.C. 1981, 1983, and under Illinois state law. The district court entered summary judgment in favor of the defendants. The Seventh Circuit affirmed. Garofalo and Peers failed to present sufficient evidence to permit a reasonable jury to find that they were the object of unlawful discrimination. Defendants offered evidence that Garofalo suffered from a lack of leadership and deficiencies in decision-making abilities. Peers had a reputation for a “volatile and unstable personality,” and did not have the respect of the men he supervised. Garofalo and Peers did not present evidence to counter that explanation and permit a finding of pretext. View "Garofalo v. Vill. of Hazel Crest" on Justia Law

Plaintiff appealed the district court's grant of Southern Nuclear's motion for summary judgment as to his claim of discrimination based on the misuse of information obtained during a required medical evaluation, in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(d)(3)(C). The court joined the Seventh and Tenth Circuits in holding that an individual seeking relief under section 12112(d)(3)(C) must demonstrate that he is a qualified individual with a disability. Here, plaintiff admitted at oral argument that he could not demonstrate that he is an individual with a disability. Accordingly, the court affirmed the judgment of the district court. View "Wetherbee v. Southern Nuclear Operating Co." on Justia Law

The Chippewa County Highway Department employed Kvapil as a seasonal employee, 2006-2008. When he was hired, Kvapil completed a New Employee Orientation for Limited Term Employees Form that advised him of work rules. Kvapil acknowledged receiving the Employment Handbook by signing a receipt that stated that all county employees are employees at will; the Handbook also contained a provision entitled “At Will Employment.” Kvapil owns property in the Town of Wheaton, Chippewa County. From 2000 until 2008, Clary, the County Planning and Zoning Administrator, contacted Kvapil about Kvapil storing unlicensed and inoperable vehicles on that property. During the zoning dispute, Kvapil made threats of violence to Clary. After Kvapil failed to comply, a warrant issued and officers searched the Wheaton property. The county issued a citation. Kvapil visited the Planning and Zoning Department’s Office demanding documents and became hostile, tore up the warrant, threw it at Clary, and said “you’re going down.” After a series of emails discussing the county’s “zero tolerance policy towards any violence or threat,” Kvapil was suspended for one day. A letter notified Kvapil that further infractions would subject him to more severe discipline, including discharge. Subsequently, there was a report that Kvapil had run a private citizen off the road. After his termination, Kvapil filed suit, alleging a property interest in his seasonal work, absent commission of an infraction specified in the handbook. The district court rejected the argument. The Seventh Circuit affirmed. View "Kvapil v. Chippewa Cnty." on Justia Law

Plaintiff filed suit against his employer, alleging race discrimination and retaliation. The court concluded that plaintiff was unable to show a prima facie case of discrimination because he failed to show circumstances which would give rise to an inference of discrimination. Plaintiff also failed to show direct or inferential evidence his employer engaged in retaliation. Accordingly, the court affirmed the district court's grant of summary judgment. View "Young v. Builders Steel Co." on Justia Law

Plaintiff filed suit against her employer, CBE, under 42 U.S.C. 1981, alleging claims of race discrimination, hostile work environment, retaliation, and constructive discharge. The district court granted summary judgment in favor of CBE. The court concluded that, even considering the otherwise time-barred acts that were similar to the acts that occurred within the limitations period, plaintiff failed to set forth sufficient evidence to survive summary judgment on her hostile work environment claim. The twelve incidents of alleged harassment that occurred after March 1, 2007, as well as the similar acts that occurred before then, taken together are not sufficiently severe or pervasive to show that plaintiff's work environment was objectively offensive. Having affirmed the district court's decision on the hostile work environment claim, the court need not further address plaintiff's constructive discharge claim. Accordingly, the court affirmed the judgment of the district court. View "Clay v. Credit Bureau Enterprises, Inc." on Justia Law

Shayn Proler, a firefighter with the Houston fire department, filed an administrative grievance seeking reassignment to a fire suppression unit under the terms of a collective bargaining agreement. After a hearing, Proler was reassigned to fire suppression. The City appealed, and Proler counterclaimed for disability discrimination. The trial court granted Proler’s plea to the jurisdiction. After a trial, the trial court entered judgment in favor of Proler on his disability claim. The court of appeals (1) reversed the order granting Proler’s plea to the jurisdiction insofar as the City claimed the hearing examiner exceeded his jurisdiction by awarding overtime compensation and insofar as the City requested declaratory judgment relief on this issue; and (2) affirmed the trial court’s judgment awarding injunctive relief and attorney fees to Proler on his disability discrimination claim. The Supreme Court (1) affirmed the court of appeals’ judgment reversing the order granting Proler’s plea to the jurisdiction; and (2) reversed the court of appeals’ judgment insofar as it affirmed the trial court’s judgment granting injunctive relief and attorney fees to Proler on his disability discrimination claim, as there was no evidence Proler was discriminated against on account of a disability. View "City of Houston v. Proler" on Justia Law