Justia Civil Rights Opinion Summaries

Plaintiff appealed from the district court's dismissal of her claim of sexual harassment under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The district court ruled that plaintiff, a volunteer firefighter, was not an "employee" within the meaning of Title VII. The court concluded that plaintiff was not an "employee" for purposes of Title VII because she failed to make a threshold showing of remuneration. Plaintiff's benefits were purely incidental to her volunteer services with District 5. Accordingly, the court affirmed the district court's judgment. View "Juino v. Livingston Parish Fire District No. 5" on Justia Law

The EEOC sued Houston Funding, alleging that Houston Funding unlawfully discharged one of its employees because she was lactating and wanted to express milk at work. The district court granted summary judgment in favor of Houston Funding, finding that, as a matter of law, discharging a female employee because she was lactating or expressing milk did not constitute sex discrimination. However, given the court's precedent, the court held that the EEOC's argument that Houston Funding discharged the employee because she was lactating or expressing milk stated a cognizable sex discrimination claim under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. An adverse employment action motivated by these factors clearly imposed upon women a burden that male employees need not - indeed, could not - suffer. Moreover, the court held that lactation was a related medical condition of pregnancy for purposes of the Pregnancy Discrimination Act, 42 U.S.C. 2000e-(k). Accordingly, the court vacated and remanded for further proceedings. View "EEOC v. Houston Funding II, et al." on Justia Law

Plaintiffs, labor organizations and state employees, brought this action contending that defendants, state officials, violated their First Amendment right to freedom of association. The court concluded that, on the stipulated facts, defendants violated plaintiffs' rights by targeting union employees for firing based on their union membership. Therefore, the court reversed the district court's grant of summary judgment to defendants; remanded to the district court with instruction to grant summary judgment to plaintiffs on their First Amendment claim and to craft appropriate equitable relief; reversed the district court's dismissal on the pleadings of plaintiffs' claims against defendants in their individual capacities; and remanded those claims for further proceedings. View "State Employees Bargaining Agent Coalition v. Rowland" on Justia Law

Appellant filed an employment action against her former employer. Appellant initially authorized her attorney to settle with Respondent, but Appellant refused to sign the settlement agreement. Respondent filed a motion to enforce the settlement agreement. The district court granted the motion and entered an order setting forth the terms of the parties' settlement. The Supreme Court dismissed Appellant's appeal for lack of jurisdiction, concluding the order was not a final judgment because it did not dismiss or formally resolve Appellant's complaint. Respondent subsequently issued a check to Appellant for the settlement amount, which Appellant refused to accept. The district court then granted Respondent's motion to deposit the settlement proceeds with the district court. The order, however, failed to enter judgment in favor of either party or otherwise resolve the case. The district court then entered an order statistically closing the case on the basis that there had been a stipulated judgment. The Supreme Court dismissed Appellant's appeal for lack of jurisdiction, holding that the district court's order was not substantively appealable because no statute or court rule authorizes an appeal from an order statistically closing a case, and the order did not constitute a final, appealable judgment, as none was entered. View "Brown v. MHC Stagecoach, LLC" on Justia Law

The Service Employees International Union, Local 721 (SEIU) was the exclusive bargaining representative of all Los Angeles County employees. SEIU proposed amending the memorandum of understanding it had with the County's bargaining units to enable SEIU to obtain the home addresses and phone numbers of all represented employees, including those who had not joined the union. The County rejected the amendment. The Los Angeles County Employee Relations Commission concluded that the County's refusal to provide the contact information was an unfair labor practice. The superior court denied the County's petition for relief. The appellate court affirmed but held that nonmember employees were entitled to notice and an opportunity to opt out before their contact information could be disclosed to SEIU. The Supreme Court affirmed but reversed the court of appeal's imposition of procedural requirements limiting disclosure, holding (1) although the County's employees have a cognizable privacy interest in their home addresses and telephone numbers, the balance of interests strongly favors disclosure of this information to the union that represents them; and (2) procedures may be developed for employees who object to this disclosure, but the court of appeal exceeded its authority by attempting to impose specific procedures on the parties. View "County of Los Angeles v. Los Angeles County Employee Relations Comm'n" on Justia Law

Plaintiff appealed the district court's grant of summary judgment to her former employer, Mission, on her hostile work environment claim brought under Title VII of the Civil Rights Act of 1963, 42 U.S.C. 2000e. The court concluded that the district court did not err in finding that plaintiff failed to establish that she had suffered a tangible employment action. The court also concluded that the undisputed facts demonstrated that Mission satisfied both elements of its affirmative defense. Mission could not be held vicariously liable for a supervisor's alleged harassment of plaintiff. Accordingly, the court concluded that the district court did not err in granting summary judgment to Mission. View "Crockett v. Mission Hospital, Inc." on Justia Law

Appellants were five upper-level employees of the Ohio Department of Natural Resource's Division of Wildlife (DOW). The Ohio inspector general (OIG) asked a deputy inspector to investigate alleged misconduct of a DOW wildlife officer. The inspector interviewed Appellants. The OIG's subsequent investigative report concluded that Appellants failed to report the wildlife officer's criminal conduct to the appropriate authorities. A grand jury later indicted each appellant on obstructing justice and complicity in obstructing justice. Appellants filed motions to suppress or, alternatively, dismiss, on the ground that their statements to the investigator were coerced by threat of job loss and were therefore inadmissible under Garrity v. New Jersey. The trial court suppressed Appellants' statements as compelled and therefore inadmissible under Garrity. The court of appeals reversed. The Supreme Court reversed, holding Appellants' statements during the OIG investigation required suppression because Appellants answered questions after receiving a warning that they could be fired for failing to do so, and statements extracted under these circumstances cannot be considered voluntary within the meaning of Garrity. View "State v. Graham" on Justia Law

This case involved Executive Order 11-58 (EO), which mandated two types of suspicionless drug testing: random testing of all employees at state agencies within the Governor of Florida's control, and pre-employment testing of all applicants to those agencies. In this case, the district court declared the EO unconstitutional as to all current state employees. This relief swept too broadly, enjoined both constitutional and unconstitutional applications of the EO, and did so without examining the specific job categories to be tested. What the Supreme Court's case law required, in contrast, was that the trial court balance the governmental interests in a suspicionless search against each particular job category's expectation of privacy. Accordingly, the court vacated the district court's order granting summary judgment to the Union and denying summary judgment to the State. On remand, the State must meet its burden of demonstrating important special needs on a job-category-by-category basis. View "American Federation of State, County, and Municipal Emp'ees Council 79 v. Scott" on Justia Law

In 2008, Plaintiff was hired as the chief of police for the City of McRae. The Mayor terminated Plaintiff's employment in 2009 for allegedly falsifying fire-department records and for insubordination. The city council voted not to overturn the Mayor's decision to terminate Plaintiff. Plaintiff filed a complaint in 2009 against the City, the Mayor, and City alderman, asserting (1) Defendants failed to comply with the provisions of the Arkansas Freedom of Information Act because they did not give sufficient notice of the city council meeting; (2) Plaintiff's due process rights were violated; (3) the Mayor's termination of Plaintiff's employment violated her rights under the Arkansas Whistle-Blower Act; and (4) Plaintiff's termination without just cause violated her rights under the Arkansas Civil Rights Act. Defendants filed a motion for summary judgment on each of Plaintiff's claims, asserting that they were entitled to qualified immunity. The circuit court denied the summary judgment motion. The Mayor appealed. The Supreme Court reversed, holding that the circuit court erred in not granting the Mayor qualified immunity on the claims brought by Plaintiff. Remanded. View "Sullivan v. Coney" on Justia Law

McFatridge prosecuted Steidl and Whitlock for 1986 murders and obtained convictions, which were subsequently overturned in federal court. The defendants filed separate federal suits seeking financial recovery against McFatridge, Edgar County, and others. McFatridge sought mandamus to compel Attorney General Madigan to approve payment for litigation expenses he incurred in his defense of the civil lawsuits, under the State Employee Indemnification Act. The Attorney General refused requests for payment, contending that payment was barred under the Act by the allegations of intentional, willful, or wanton misconduct, but that there could be indemnification later if a court or jury should find that there was no such misconduct. The circuit court dismissed the mandamus complaint, but the appellate court reversed. The Illinois Supreme Court reinstated the dismissal. The statute has a provision that an elected official (such as a State’s Attorney) may choose his or her own defense counsel and have the resulting expenses paid as they are incurred; the provision has no impact on an earlier provision of the Act that allows the Attorney General to decline representation if she determines that the claim is for intentional, willful, or wanton misconduct.Burke View "McFatridge v. Madigan" on Justia Law