Justia Civil Rights Opinion Summaries

Mike Burcham filed an action against the University of Arkansas and others, claiming that he was wrongfully terminated. The University filed an amended motion to dismiss, arguing that Burcham’s complaint was barred by sovereign immunity. The circuit court denied the motion, concluding that an allegation in Burcham’s complaint that the University failed to follow a grievance procedure outlined in the employee handbook was sufficient to waive the University’s sovereign immunity. The Supreme Court reversed, holding that none of the exceptions to sovereign immunity were applicable to the instant case, and therefore, the circuit court erred in denying the University’s amended motion to dismiss. View "Bd. of Trs. v. Burcham" on Justia Law

Until 1998, Vanaria was employed by the Cook County Probation Department. He was terminated following investigation of allegations that he had sought sexual favors in exchange for looser conditions of probation. In 2002 the county rehired Vanaria, who was a political operative. He began working at a county hospital in a position excluded from decrees prohibiting hiring decisions based on politics. The hospital did not conduct background investigations of patronage hires. A pharmaceutical representative alleged that Vanaria had attempted to condition her participation in a hospital program on her giving him a massage. An investigation resulted in oral counseling for Vanaria, but no discipline. In 2007, Vanaria offered Krystal, an unemployed massage therapist, a position as a physical therapist. When she stated that she was not qualified as a physical therapist, he explained that he could make things happen because people owed him favors. He provided her with legitimate application forms and insurance paperwork. When Krystal returned to his office with her Social Security card, Vanaria asked Krystal to close the door and told her that if she truly wanted the job, she had to kiss and massage him. Krystal agreed to have Vanaria visit her at her home massage studio, where they had sexual contact. Krystal eventually called the hospital’s HR department and learned that no position had ever existed, Vanaria eventually pled guilty to official misconduct and bribery. The district court rejected Krystal’s Title VII (42 U.S.C. 2000e), equal protection, and due process claims and state law claims. The Seventh Circuit affirmed. View "Wilson v. Cook County" on Justia Law

The certified questions in this case centered on whether, the exemption of nonprofit religious organizations from the definition of "employer" under Washington's Law Against Discrimination (WLAD), violates article I, section 11 or article I, section 12 of the Washington Constitution. Larry Ockletree sued his former employer, Franciscan Health System (PHS), challenging the termination of his employment after he had a stroke. Ockletree, who is African-American, claimed that his termination was the result of illegal discrimination on the basis of race and disability. FHS removed the suit to federal court and moved to dismiss Ockletree's claims. FHS argued that it was exempt from WLAD as a nonprofit religious organization. Ockletree challenged the validity of the religious employer exemption under the state and federal constitutions. The district court certified questions to this court asking whether the religious employer exemption violated Washington's article I, section 11 establishment clause or its article I, section 12 privileges and immunities clause. The Washington Supreme Court answered both questions in the negative. View "Ockletree v. Franciscan Health Sys." on Justia Law

A large group of African-American police officers and firefighters sued the City of Indianapolis, alleging that the examination process it uses to rank candidates for promotion in the police and fire departments has a disparate impact on black candidates and is intentionally discriminatory. They filed lawsuits targeting promotion decisions made in successive promotion cycles starting inv2002, but most of the challenged decisions were based on scores generated by testing administered by the police department in 2008 and the fire department in 2007. The district court dismissed many of the claims as either time-barred or substantively flawed. The Seventh Circuit affirmed. Although the district court mistakenly assumed that allegations of intentional discrimination necessarily defeat a disparate-impact claim, here the disparate-impact claims fail because they are stated as legal conclusions, without any factual content to support an inference that the examination procedures caused a disparate impact on black applicants for promotion. The disparate-treatment claims lacked evidentiary support and were properly resolved on summary judgment. Although the second complaint concerns a different set of promotion decisions, it attacked the same eligibility list that was at issue in the first case and was, therefore, barred. View "Adams v. City of Indianapolis" on Justia Law

Plaintiff filed suit alleging, inter alia, that she was subjected to a hostile work environment based on her race. The court concluded that the evidence did not support a hostile work environment claim and Denton County was entitled to judgment as a matter of law; because plaintiff failed to plead facts sufficient to survive a motion to dismiss on her failure to promote claim, the district court did not err by denying discovery and dismissing the suit against the Individual Defendants; and, therefore, the court reversed in part and affirmed in part. View "Williams-Boldware v. Denton County Texas" on Justia Law

Plaintiffs, African American officers who worked in a state penitentiary, filed suit under 41 U.S.C. 1981 and 1983 against supervisors for race based harassment and retaliation. On appeal, the officers challenged the district court's dismissal of their claims against Lieutenants Stoner, Haney, and Runge and against Sergeants Miles and Furby. The court concluded that the evidence revealed acts, comments, and inaction by Sergeant Miles sufficient to make out prima facie harassment claims against him, which must be reinstated and remanded; there was insufficient evidence of harassment by the other supervisors and therefore the claims against Lieutenant Stoner, Runge, and Haney, and Sergeant Furby were affirmed; the retaliation claims by supervisors were affirmed; and Sergeant Miles has not shown that he was entitled to qualified immunity on the officers' harassment claims, nor have Lieutenants Stoner and Haney shown they were entitled to qualified immunity on the retaliation claims of Officer Ellis. Accordingly, the court reversed in part, affirmed in part, and remanded for further proceedings. View "Ellis, et al. v. Houston, et al." on Justia Law

Plaintiff filed an action against her former employer (Employer) for violations of Title VII, 42 U.S.C. 2000e et seq., and Mass. Gen. Laws ch. 151B, alleging that she was subject to sexual harassment while working for Employer and that she was terminated in retaliation for reporting the harassment. The district court granted summary judgment in favor of Employer. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in concluding that no reasonable juror could conclude that Plaintiff was subjected to sexual harassment while an employee for Employer; and (2) even if Plaintiff had made a prima facie case of retaliation, which she did not, Plaintiff did not meet her burden of showing that Employer’s legitimate, non-retaliatory reason for the termination was mere pretext. View "Ponte v. Steelcase Inc." on Justia Law

Zayas worked at the Hospital as an ultrasound technician from 1999 until her discharge, at age 55, in 2011. Griesman, Zayas’ supervisor, was responsible for hiring and terminating Zayas and, before firng her, had warned Zayas about sending disrespectful emails. Zayas is Puerto Rican. She brought a national origin discrimination claim and a hostile work environment claim under Title VII, 42 U.S.C. 2000e, and an age discrimination claim under the Age Discrimination in Employment Act, 29 U.S.C. 621. Her case was based on the fact that she was the oldest technician in the department, and was replaced by a younger employee and on evidence of several incidents during which Zayas believed that Griesman or her co-workers were disrespectful. The district court granted the Hospital summary judgment on all three claims. The Seventh Circuit affirmed. Although Zayas cited a number of hostile incidents, none were related to her national origin, nor were they objectively severe enough to survive summary judgment. Although Zayas’ coworkers did not like her, it was likely the result of “workplace pettiness,” not her Puerto Rican origin. View "Zayas v. Rockford Mem'l Hosp." on Justia Law

Plaintiff, an employee of MTA for four decades, filed suit against MTA alleging various forms of discrimination after her position was terminated due to budget cuts. The court concluded that, because summary judgment was granted before plaintiff had a chance to discover facts essential to her claim, and she alleged discrimination occurring before any legislative activity, the district court's Rule 56(d) denial was an abuse of discretion. The court concluded, however, that the district court's dismissal of plaintiff's age discrimination and disability discrimination claims were barred by sovereign immunity. Accordingly, the court affirmed in part, reversed in part, and remanded. View "McCray v. Maryland Dep't of Transp." on Justia Law

Plaintiff, the former captain of a village fire department, filed this action against the department, its fire chief, and the board of fire commissioners (collectively, Defendants) after the board chose to terminate Plaintiff’s employment. Plaintiff alleged political discrimination in violation of the First Amendment and 42 U.S.C. 1983, retaliation in violation of the Massachusetts Whistleblower Act, and tortious interference with contractual relations. The district court granted summary judgment for Defendants on all counts. The First Circuit Court of Appeals affirmed, holding that Defendants presented legitimate, business-related grounds for their employment decisions, and Plaintiff failed to demonstrate that the proffered explanations were pretextual. View "Pierce v. Cotuit Fire Dist." on Justia Law