Justia Civil Rights Opinion Summaries

The South Dakota Department of Labor and Regulation, Unemployment Insurance Division disqualified Plaintiff from unemployment insurance benefits based on Plaintiff's alleged failure, without good cause, to accept work she was capable of performing. After Plaintiff missed a telephonic hearing on her appeal, an ALJ entered an order of dismissal and denied Plaintiff's request to reopen for failure to show good cause. The circuit court affirmed, concluding that the Department did not err in refusing to reopen Plaintiff's claim. The Supreme Court affirmed dismissal, holding that Plaintiff did not provide evidence of untimely receipt of her notice of the hearing to carry her burden to show good cause, and therefore, Plaintiff received sufficient due process. View "Eiler v. Dep't of Labor & Regulation" on Justia Law

Plaintiffs filed suit against the Sheriff of the City of Hampton, Virginia, in his individual capacity and in his official capacity, alleging that the Sheriff retaliated against plaintiffs in violation of their First Amendment rights by choosing not to reappoint them because of their support of his electoral opponent. The court concluded that, as to the claims of Plaintiffs Sandhofer, Woodward, and Bland, the district court properly analyzed the merits of the claims; as to the claims of Plaintiffs Carter, McCoy, and Dixon, the district court erred by concluding that plaintiffs failed to create a genuine dispute of material fact regarding whether the Sheriff violated their First Amendment rights; nevertheless, the district court properly ruled that the Sheriff was entitled to qualified immunity on Carter's McCoy's, and Dixon's claims seeking money damages against the Sheriff in his individual capacity, and that the Sheriff was entitled to Eleventh Amendment immunity against those claims to the extent they sought monetary relief against him in his official capacity; and the Sheriff was not entitled to Eleventh Amendment immunity on Carter's, McCoy's and Dixon's claims to the extent the remedy sought was reinstatement. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Bland v. Roberts" on Justia Law

Plaintiff, a surgical technologist, filed suit against the hospital alleging racial discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1981. The court concluded that the district court did not clearly err in concluding that plaintiff failed to prove the hospital terminated her in retaliation for complaining of racial discrimination; in finding that plaintiff failed to prove that race was the motivating factor behind her termination, rather the district court believed that plaintiff was terminated for being insubordinate; and in finding that plaintiff was not subject to disparate terms and conditions of her employment based on race. Accordingly, the court affirmed the judgment of the district court. View "Wright v. St. Vincent Health System" on Justia Law

Plaintiff, a former assistant attorney general for the Louisiana DOJ, claimed that LDOJ discriminated against her by declining to provide a free on-site parking space to accommodate her disability in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and violated the ADA and Title VII of the Civil Rights Act, 42 U.S.C. 2000e-1 et seq., by terminating her employment in retaliation for charges she filed with the EEOC. The court concluded that, because the district court erred in requiring a nexus between the requested accommodation and the essential functions of plaintiff's position, the court vacated the judgment and remanded for further proceedings. The court affirmed the summary judgment dismissal of the retaliation claim because the LDOJ has offered a non-retaliatory explanation for plaintiff's dismissal and because plaintiff has presented no evidence of pretext. View "Feist v. State of Louisiana" on Justia Law

Appellant Lillian Hatheway appealed a district court's grant of summary judgment in favor of the Board of Regents of the University of Idaho and the University of Idaho. Appellant worked for the University as an administrative assistant for nine years before she resigned. She sued for age discrimination, hostile work environment, retaliation, constructive discharge and negligent infliction of emotional distress. Upon review, the Supreme Court concluded the district court correctly dismissed all of Appellant's claims. View "Hatheway v. Bd of Regents - UI" on Justia Law

Plaintiff, former President of the United Steel Workers Local 12-369, filed suit against defendants alleging claims of discrimination on the basis of race and gender, and retaliation for having engaged in protected speech under the Labor-Management Reporting and Disclosure Act (LMRDA), 29 U.S.C. 401 et seq. The court concluded that, because the alleged retaliatory actions directed toward plaintiff impinged only upon her status as a union officer, she could not seek redress for these actions under section 609. The court held that the district court did not clearly err in finding defendants did not discriminate or retaliate against plaintiff given the district court's analysis of plaintiff's allegations, both as discrete incidents and as part of a broader course of conduct. Accordingly, the court affirmed the judgment of the district court. View "USW Local 12-369 v. USW Int'l" on Justia Law

Plaintiff filed suit against Trinity alleging wrongful termination in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; Title VII of the Civil Rights Act, 42 U.S.C. 2000e-1 et seq.; the North Dakota whistleblower statute, N.D. Cent. Code 34-01-20(1); and N.D. Cent. Code 34-01-04 (the intimidation statute). On appeal, plaintiff challenged the district court's grant of summary judgment in favor of Trinity and the denial of her motion for a default judgment. The court found no abuse of discretion in the district court's denial of plaintiff's motion for summary judgment or default judgment, which asked the court to grant a dispositive discovery sanction against Trinity for its willful pattern of action in failing to comply with the scheduling order. Plaintiff failed to advance any evidence indicating that Trinity did in fact replace plaintiff with someone substantially younger, that she was treated differently than any other similarly situated male employee, that plaintiff engaged in a protected activity under the whistleblower statute, and that there was a private right of action under the intimidation statute. Accordingly, the court affirmed the judgment of the district court. View "Holmes v. Trinity Health" on Justia Law

This case arose when three former employees of ASU alleged that they were subjected to a hostile work environment and retaliation during their employment. ASU appealed the district court's judgment. The court concluded that the district court did not err in denying ASU's motion to sever where the district court had broad discretion to deny the severance in the interest of judicial economy; the court did not have jurisdiction to hear ASU's appeal of the district court's denial of its Rule 50(b) and 59(b) motion where ASU had not filed a notice of appeal with the district court clerk; and the district court did not abuse its discretion in awarding front pay. Accordingly, the court affirmed in part and dismissed in part. View "Weatherly, et al. v. Alabama State University" on Justia Law

Plaintiff, who was formerly employed by Hospital, brought an eight-count petition against Hospital and Doctor (collectively, Defendants) alleging violations of the Missouri Human Rights Act (the MHRA) and other common law claims related to the termination of her employment. The circuit court granted summary judgment in favor of Defendants on all claims. The Supreme Court (1) reversed the circuit court's judgment with respect to Plaintiff's MHRA claims and wrongful discharge claim, holding (i) the circuit court erred in dismissing Plaintiff's MHRA claims on the grounds that Plaintiff failed to satisfy the statutory prerequisites for filing a lawsuit under the MHRA, and (ii) because Plaintiff's amended petition sufficiently invoked the public policy exception to the at-will employment doctrine, the circuit court erred in sustaining summary judgment in Hospital's favor on Plaintiff's wrongful discharge claim; and (2) affirmed the circuit court's judgment as to all remaining counts. Remanded. View "Farrow v. St. Francis Med. Ctr. " on Justia Law

Plaintiff filed suit alleging sex and race discrimination, retaliation, and sex and race harassment in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and retaliation in violation of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The court concluded that the district court properly granted summary judgment for the state on plaintiff's race and sex discrimination and retaliation claims where plaintiff did not establish a prima facie case because she could not show, as a matter of law, that she suffered an adverse employment action. The court also concluded that summary judgment was appropriately granted on the harassment claim where the conduct described did not affect a term, condition, or privilege of employment because this conduct was not severe or pervasive enough to constitute actionable discrimination. Accordingly, the court affirmed the district court's judgment. View "Jackman v. Fifth Judicial District, et al." on Justia Law