Justia Civil Rights Opinion Summaries

Appellant was a temporary employee at the University of Nebraska. After the University considering terminating Appellant’s employment, human resources completed a “threat assessment” in relation to the termination, which noted Appellant’s criminal record and history of becoming upset over discussion of work performance. When the University decided to terminate Appellant, an e-mail was circulated warning coworkers to alert campus police and lock their doors if they saw Appellant. Appellant filed this action under 42 U.S.C. 1983 against the University Board of Regents and two of its managers, making a “stigma plus” claim that he was deprived of a liberty interest in his good name without due process of law. The district court granted summary judgment in favor of Defendants, concluding (1) there was no genuine issue of material fact that Appellant had not sufficiently suffered a constitutional violation; (2) the Board of Regents was shielded by sovereign immunity; and (3) the individual defendants were protected by qualified sovereign immunity because the alleged violation was not clearly established. The Supreme Court affirmed, holding that the district court did not err in its judgment. View "Potter v. Bd. of Regents of Univ. of Neb." on Justia Law

Plaintiff filed sex- and pregnancy-based employment discrimination claims against Nationwide under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and the Iowa Civil Rights Act (ICRA), Iowa Code 216.6. The court concluded that plaintiff failed to meet her burden of demonstrating constructive discharge, where, even if her supervisor's comment that it was best that plaintiff go home with her babies might support a finding of intent to force plaintiff to resign, plaintiff did not give Nationwide a reasonable opportunity to address and ameliorate the conditions that she claimed constituted constructive discharge. The court also concluded that plaintiff waived her argument that she was actually discharged because she did not raise it in the district court. Accordingly, the court affirmed the district court's grant of summary judgment to Nationwide. View "Ames v. Nationwide Mutual Ins. Co., et al." on Justia Law

Laster is an African American male who worked as a Public Safety Officer for the KDPS for 23 years. He alleges that KDPS subjected him to heightened scrutiny, selectively enforced policies, and was complicit when individual employees harassed and discriminated against him, and that the disparate treatment was attributable to race or to his complaints about discrimination. He specifically cited a 2006 performance evaluation downgrade, followed by a grievance and reversal; denials of a request to attend outside training and of other requests; reprimands; and tampering with his Obama screensaver. Laster filed two charges with the EEOC. While those were pending, Laster was involved in a conflict with other KDPS officers at an event during which President Obama was present. Information about the incident was released to a newspaper. Laster resigned and filed suit under Title VII, 42 U.S.C. 2000e-3(a), Michigan’s Civil Rights Act, and 42 U.S.C. 1983. The district court analyzed the claims for “Race Discrimination” and “First Amendment Retaliation” and dismissed. The Sixth Circuit remanded, stating that activity protected by the First Amendment is different than the type of activity protected by Title VII. Analysis of the Title VII race discrimination claim was insufficient for dismissing the Title VII retaliation claim; the “materially adverse action” element of a Title VII retaliation claim is substantially different from the “adverse employment action” element of a Title VII race discrimination claim. That Laster cannot show that he was constructively discharged is not dispositive of the retaliation claim, given evidence of other adverse actions. View "Laster v. City of Kalamazoo" on Justia Law

After Scott Schuette, who was working as a police officer at the time, responded to an accident at the local high school he began experiencing mental health problems. Schuette was later diagnosed with post-traumatic stress disorder (PTSD). Schuette filed a claim petition seeking workers’ compensation benefits for PTSD. A compensation judge denied Schuette’s claim, finding that Schuette’s PTSD lacked a physical component and was thus not a compensable injury under Minnesota law. The Workers’ Compensation Court of Appeals (WCCA) affirmed, determining (1) to be compensable under Lockwood v. Independent School District No. 877, an injury must include a physical component; and (2) the compensation judge’s findings that Schuette’s PTSD did not result in a physical brain injury had substantial evidentiary support. The Supreme Court affirmed, holding (1) the compensation judge’s findings were not manifestly contrary to the evidence; and (2) applying the doctrine of stare decisis, Schuette’s request to overrule Lockwood was declined. View "Schuette v. City of Hutchinson" on Justia Law

Plaintiff appealed from the dismissal of her state-law tort claims as time-barred, arguing that the statute of limitations applicable to her tort claims was tolled by her filing of a charge of discrimination with the EEOC. The court joined the Seventh and Ninth Circuits in holding as a matter of federal law that filing an EEOC charge did not toll the limitations period of state-law tort claims, even if those claims arose out of the same factual circumstances as the discrimination alleged in the EEOC charge. Accordingly, the court affirmed the dismissal of plaintiff's tort claims. View "Castagna v. Luceno" on Justia Law

Defendant hired Plaintiff twice when Plaintiff was sixty-seven years old for brief periods of employment. When Plaintiff was sixty-eight, Defendant rehired her as a titles and registrations clerk. When Plaintiff was seventy-two years old, Defendant terminated her employment. Plaintiff filed an action against Defendant for unlawful age and disability discrimination in violation of the Fair Employment Practices Act. The superior court granted summary judgment for Defendant on both employment discrimination claims. The Supreme Court affirmed, holding that the trial justice did not err (1) in finding that Defendant met its burden of producing a legitimate nondiscriminatory reason for Plaintiff’s dismissal, and (2) in holding that Plaintiff failed to demonstrate that those reasons were merely pretextual. View "Bucci v. Hurd Buick Pontiac GMC Truck, LLC " on Justia Law

United Public Workers, AFSCME, Local 646, AFL-CIO (“UPW”) filed an action on behalf of the employees it represented, alleging (1) then-Governor Lingle and members of her administration retaliated against UPW members for filing a lawsuit opposing her statewide furlough plan; and (2) the State was unlawfully privatizing positions customarily performed by civil servants under the merit system. The circuit court dismissed the complaint based on a lack of jurisdiction. The intermediate court of appeals (ICA) vacated the circuit court’s judgment and remanded with instructions to stay the action pursuant to the primary jurisdiction doctrine so the parties could pursue appropriate administrative remedies before the Hawaii Labor Relations Board (HLRB). The Supreme Court primarily affirmed, holding (1) the ICA did not err in concluding that the primary jurisdiction doctrine was applicable to UPW’s retaliation claims because the claims required the resolution of issues that have been placed within the special competence of the HLRB, and that a stay, rather than a dismissal, was appropriate under the circumstances; and (2) the primary jurisdiction doctrine did not apply to UPW’s privatization claims, and therefore, the circuit court erred in dismissing these claims, and the ICA erred in referring the claims to the HLRB. Remanded. View "United Pub. Workers, AFSCME, Local 636, AFL-CIO v. Abercrombie" on Justia Law

Plaintiff, a member of a union, filed a complaint against Defendant, her former employer, alleging that during her employment she was subjected to a hostile work environment on account of her race and color and that she was wrongfully terminated. Defendant filed a motion to stay proceedings, arguing that the proper forum for resolution of Plaintiff’s claims was binding arbitration as required by the collective bargaining agreement (CBA) between the union and Defendant. A hearing justice granted Defendant’s motion to stay and ordered that the matter be resolved through arbitration. Plaintiff appealed, arguing that the hearing justice’s decision was in error because the CBA’s arbitration provision did not preclude her from asserting her statutorily created rights under the Rhode Island Civil Rights Act (RICRA) and Rhode Island Fair Employment Practices Act (FEPA) in a judicial forum. The Supreme Court vacated the order of the superior court, holding that the CBA’s general arbitration provision, which contained no specific reference to the state anti-discrimination statutes at issue, did not constitute a clear and unmistakable waiver of Plaintiff’s right to a judicial forum in which to litigate her claims arising under the RICRA and the FEPA. Remanded. View "Weeks v. 735 Putnam Pike Operations, LLC" on Justia Law

As a condition of her employment, Employee signed an agreement to arbitrate claims with Employer. Employee later filed a complaint with the Iowa Civil Rights Commission (ICRC), alleging that Employer had discriminated against her because of her pregnancy. The ICRC subsequently filed a statement of charges with the Iowa Department of Inspections and Appeals (DIA). Employer filed a motion to dismiss the ICRC’s charges or, in the alternative, compel arbitration. The DIA denied Employer’s motion on the ground that ICRC was not a party to the arbitration agreement and, consequently, not bound by it. On judicial review, the district court remanded instructions for the ICRC to dismiss the matter pending arbitration by the parties, concluding that the Federal Arbitration Act (FAA) preempted state law. The Supreme Court reversed, holding the FAA did not require arbitration of this proceeding because it was brought by an entity that was not bound to arbitrate under generally applicable principles of contract law, where the ICRC was not a party to the agreement and its interest was not derivative of Employee’s. View "Rent-A-Center, Inc. v. Iowa Civil Rights Comm'n" on Justia Law

Plaintiff filed suit against Timothy Geithner, in his capacity as the Secretary of the Treasury, for retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The court concluded that no senior-international-agent position was available to which plaintiff could be promoted based on his work in the "M" case and plaintiff failed to demonstrate that the IRS's failure to promote him to a senior international agent for his work on the "M" case constituted a materially adverse employment action; failed to demonstrate unlawful retaliation because no reasonable juror could determine that the IRS undertook material adverse employment actions; and failed to demonstrate constructive discharge. Accordingly, the court affirmed the judgment of the district court. View "AuBuchon v. Geitner" on Justia Law