Justia Civil Rights Opinion Summaries

In 2004, Akron held promotional exams for fire department positions of Captain and Lieutenant. The exams were prepared, administered and scored by an outside testing consultant. Each exam contained a 100-question multiple choice section on technical knowledge and two oral assessment exercises. The Lieutenant exam also required a written work-sample; the Captain exam had an additional oral group exercise. Candidates were placed on an eligibility list in an ordered ranking. Plaintiffs alleged disparate-impact age discrimination against 23 firefighters based on age, 29 U.S.C. 621; that the exam for Lieutenant had an adverse impact on three African-American firefighters and that the exam for Captain had an adverse impact on 12 Caucasian firefighters based on race, 42 U.S.C. 2000e; and state law violations. The district court concluded that the exam adversely impacted 12 Caucasian Captain candidates and three African-American Lieutenant candidates on the basis of race, and adversely impacted eleven Lieutenant candidates on the basis of their age and ordered promotion of 18 candidates. Each Lieutenant candidate was awarded $9,000 in compensatory damages and $72,000 in front pay. Captain candidate were awarded $10,000 in compensatory damages and $80,000 in front pay. The Sixth Circuit affirmed. View "Howe v. City of Akron" on Justia Law

Plaintiff sued her former employer alleging violations of her rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The employer believed that plaintiff suffered from a serious health condition and placed her on involuntary FMLA leave. After plaintiff submitted certifications of her fitness to return to work, the employer informed her that she had exhausted her FMLA leave and terminated her employment. The court affirmed the district court's grant of the employer's motion to dismiss where the statute entitled plaintiff to a certain amount of leave and her employer did not interfere with that entitlement. Further, the court concluded that plaintiff had no right to FMLA benefits where she admitted that she never suffered a serious health condition within the meaning of the Act. The court rejected defendant's claim of equitable estoppel where she did not establish a submissible case of detrimental reliance; and the employer's mistaken belief that plaintiff suffered a serious health condition could not entitle her to FMLA benefits. View "Walker v. Trinity Marine Products, et al." on Justia Law

Plaintiffs filed suit against their former employer alleging retaliatory termination after plaintiffs filed grievances against their supervisor. A jury found that the employer did retaliate against plaintiffs and awarded backpay and damages for emotional distress to each plaintiff. Both parties appealed. The court concluded that the evidence of discriminatory animus was sufficient to submit plaintiffs' retaliation claims to the jury; the employer's proffered non-discriminatory explanation for the terminations failed to address the discriminatory motivation; and the employer's argument that the discriminatory motivation was cured was unavailing. Accordingly, the district court properly denied the employer's motion for judgment as a matter of law on the retaliation claims. The court agreed with the district court's decision to instruct the jury that it could award damages for emotional distress; the district court did not clearly abuse its discretion in denying the employer's motion for new trial or remittitur; and the court affirmed the district court's decision to refuse an instruction on punitive damages. Accordingly, the court affirmed the judgment. View "Bennett, et al. v. Riceland Foods, Inc." on Justia Law

Plaintiff, an employee of the Hays County Sheriff's Office for over twenty years, filed suit alleging constitutional violations against Hays County; the Sheriff's Office; and Sheriff Gary Cutler, in his official and individual capacities. Plaintiff claimed that the comments he made during the Sheriff's Election motivated his demotion. The court found that defendants failed to show that they would have terminated plaintiff in the absence of his protected speech and, in the alternative, plaintiff was speaking as a citizen and his letter to the editor was protected speech under the First Amendment. The court concluded that plaintiff had presented sufficient evidence to raise a genuine dispute as to a material fact relating to his claim of First Amendment retaliation and that defendants were not entitled to summary judgment on the basis of qualified immunity. Accordingly, the court reversed the district court's grant of summary judgment and remanded for further proceedings. View "Haverda v. Hays County, et al." on Justia Law

Hobgood was the subject of repeated, intensive investigations that resulted in disciplinary proceedings and termination of his employment with the Illinois Gaming Board, though another state agency ultimately ordered that he be reinstated. Hobgood contends he was targeted because he helped a fellow Board employee with suits against the Gaming Board under Title VII and the Racketeer Influenced and Corrupt Organizations. Hobgood sued under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-3(a), and the First Amendment. The district court granted the defendants summary judgment, reasoning that Hobgood was fired, not because he had assisted his friend, but because the “nature” of that assistance involved providing confidential information. The Seventh Circuit reversed, noting genuine issues of fact concerning the defendants’ motives for investigating, disciplining, and terminating Hobgood, who presented a “convincing mosaic” to show that his employer acted for unlawful reasons. When the evidence is viewed as a whole, a jury could reasonably infer that the Board investigated and fired him because he assisted in lawsuits against the Board. View "Gnutek v. IL Gaming Bd." on Justia Law

After Plaintiff was suspended, he was discharged from his employment with the Massachusetts Bay Transportation Authority (MBTA). An arbitrator ruled that the MBTA had lacked just cause to terminate him, and the MBTA subsequently reinstated Plaintiff to his former position. Thereafter, Plaintiff filed a complaint against the MBTA, alleging, among other things, that his discharge constituted racial discrimination and that the MBTA unlawfully retaliated against him for writing a letter to Senator Edward Kennedy after MBTA officials recommended firing Plaintiff. The district court granted summary judgment to the MBTA on all claims. The First Circuit Court of Appeals affirmed, holding (1) MBTA's merely questionable behavior did not show minimally sufficient evidence of pretext sufficient to support a discrimination claim; and (2) the district court correctly held that there was no causal link between Plaintiff's letter and his termination. View "Pearson v. Mass. Bay Transp. Auth." on Justia Law

Dentist fired his long-time female dental assistant (Employee) at the request of his wife after she discovered Dentist and Employee had been texting. Wife claimed Employee "was a big threat" to the marriage. Employee subsequently brought this action against Dentist, alleging that he discriminated against her on the basis of sex. The district court granted summary judgment for Dentist, concluding that Employee was not fired because of her gender but because she was a threat to Dentist's marriage. The Supreme Court affirmed, holding that Dentist did not engage in unlawful gender discrimination in violation of the Iowa Civil Rights Act when he fired Employee at the request of his wife. View "Nelson v. Knight" on Justia Law

Plaintiffs, the superintendent of education and her assistant superintendent, filed suit claiming that the board and its members in both their official and individual capacities terminated the superintendent and demoted the assistant superintendent in retaliation for public comments plaintiffs made about local tax policy. The court concluded that it had jurisdiction over the appeal of the denial of qualified immunity, but lacked jurisdiction over the appeal of the board and its officials. Accordingly, the court dismissed the appeal of the board and its officials for lack of jurisdiction and reversed the denial of qualified immunity for the individual members of the board. View "Leslie, et al. v. Hancock County Board of Education, et al." on Justia Law

Plaintiff filed suit against the Postal Service for breach of prior settlement agreements, as well as various other claims related to her employment at the Postal Service. The district court dismissed plaintiff's breach of contract claim for lack of subject matter jurisdiction, holding that the Tucker Act, 28 U.S.C. 1491(a)(1), granted the Court of Federal Claims exclusive jurisdiction to hear breach of contract claims against the Postal Service that put more than $10,000 in controversy. The district court also dismissed seven of plaintiff's claims for lack of subject matter jurisdiction because plaintiff had not complied with the Federal Tort Claims Act (FTCA), 28 U.S.C. 2675(a), and held that plaintiff's three remaining claims were barred by res judicata. The court concluded that, even assuming that the Tucker Act conferred jurisdiction on the Court of Federal Claims to hear claims against the Postal Service, the Postal Reorganization Act (PRA), 39 U.S.C. 401 and 409, also vested the district court with independent jurisdiction over such claims. Therefore, the court reversed the district court's determination that it lacked subject matter jurisdiction to hear plaintiff's breach of contract claim. Although the district court had subject matter jurisdiction to consider plaintiff's breach of contract claim, it did not err in dismissing it because she failed to state a claim upon which relief could be granted. None of her remaining claims were viable and, therefore, the court affirmed the dismissal of her complaint. View "Tritz v. U.S. Postal Service" on Justia Law

Peele worked for the Portage Police Department as a detective. In 2007 he supported Charnetzky’s Democratic primary campaign to become mayor. Charnetzky lost. Peele spoke to a local reporter and criticized Sheriff Lain for endorsing the opponent, apparently stating that Sheriff Lain “won’t get any support here.” The day after the comments were published, Peele was reassigned to the more deskbound position of “Station Duty Officer.” Peele sued, claiming that he was demoted and constructively discharged without due process; retaliation for his support of Charnetzky; and defamation. The defendants counterclaimed malicious prosecution and abuse of process. The district court granted summary judgment to the defendants. The Seventh Circuit reversed with respect to retaliation, noting that the district court did not address conspiracy, immunity, or the city’s liability. View "Peele v. Burch" on Justia Law