Justia Civil Rights Opinion Summaries

Between 2002 and 2005, May, a Chrysler pipefitter, was the target of graffiti in and around the plant’s paint department. Messages stated: “Otto Cuban Jew fag die,” “Otto Cuban good Jew is a dead Jew,” “death to the Cuban Jew,” “fuck Otto Cuban Jew fag,” “get the Cuban Jew,” and “fuck Otto Cuban Jew nigger lover.” May found death-threat notes in his toolbox, had his tires punctured, had sugar poured in the gas tanks of his cars, and found a dead bird wrapped in toilet paper to look like a Ku Klux Klansman in his work station. May contacted the police, the FBI, the Anti-Defamation League, and complained to Chrysler. Chrysler responded: The head of human resources informed employees that harassment was unacceptable, a procedure was implemented to document harassment, efforts were made to discover who was present when the incidents occurred, and a handwriting analyst was retained. The offenders were never caught. May sued Chrysler, alleging violations under Title VII and 42 U.S.C. 1981. His hostile work environment claim survived summary judgment. A jury awarded $709,000 in compensatory damages and $3.5 million in punitive damages. May accepted remittitur to $300,000; the court vacated the award of punitive damages. On rehearing, the Seventh Circuit affirmed. View "May v. Chrysler Group LLC" on Justia Law

Plaintiff sued Coca-Cola, his employer, alleging that the psychiatric/psychological fitness-for-duty evaluation he was required to undergo violated 42 U.S.C. 12112(d)(4)(A), a provision of the Americans with Disabilities Act (ADA). The court affirmed the district court's grant of summary judgment for Coca-Cola, concluding that the evaluation was both job-related and consistent with business necessity and, therefore, permissible under the ADA. View "Owusu-Ansah v. The Coca-Cola Co." on Justia Law

Plaintiff, employed by the CRMC, filed charges of discrimination against her employer after CRMC's placement of her on administrative leave following work-related epileptic seizures and the hiring of a younger technician. Because plaintiff was not a qualified individual to perform the job duties with or without accommodation, the court did not err in granting summary judgment to CRMC based on the Americans with Disabilities Act, 42 U.S.C. 12101 et seq., and Missouri Human Rights Act, Mo. Rev. Stat. 213.010, claims. Plaintiff's age discrimination claims failed for the same reason her disability discrimination claims failed. Accordingly, the court affirmed the judgment. View "Olsen v. Capital Region Medical Center, et al" on Justia Law

Plaintiff appealed the district court's grant of summary judgment against her claims of age and sex discrimination in the workplace. The district court credited the defense of plaintiff's employer that she was let go during a restructuring of the firm only because her expertise was not a good fit with the firm's new business focus. Viewing the facts in the light most favorable to plaintiff - including a productivity spreadsheet that included the age of each employee - the court concluded that a reasonable jury could find the employer's defense to be a pretext for discrimination. Therefore, the court reversed the judgment of the district court and remanded for further proceedings. View "Barnett v. PA Consulting Group, Inc." on Justia Law

Appellant was a probationary public employee of the Town of Smithfield, Rhode Island. The Town hired Appellant on the condition that he obtain his building official certification. After Appellant failed to obtain the certification, the Town terminated Appellant. Appellant filed a complaint against the Town and its officials, alleging that he received insufficient procedural due process in violation of the Fourteenth Amendment when his employment was terminated and that the Town violated the Rhode Island Constitution and Rhode Island Whistleblowers' Protection Act when it fired him. Defendants removed the case to federal court. The district court granted Defendants' motion for summary judgment on all counts. The First Circuit Court of Appeals affirmed, holding (1) Appellant received constitutionally adequate procedural due process; and (2) the district court acted within its discretion in reaching and resolving the state law claims after ruling against Appellant on the sole federal claim. View "Senra v. Town of Smithfield" on Justia Law

A jury found that Raytheon willfully violated the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq., and the Texas Commission on Human Rights Act (TCHRA), Tex. Lab. Code 21.001 et seq., by terminating plaintiff because of his age. Both parties appealed. The court affirmed the finding of liability; affirmed in part the award of liquidated damages, and vacated the liquidated damages award for enhanced pension because it was a future, not past loss; vacated the damages for mental anguish, rejected plaintiff's issues on cross-appeal; and remanded for reconsideration of the front pay award. View "Miller v. Raytheon Co." on Justia Law

Plaintiff, a contract FBI employee, sued the government under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-1 et seq., alleging sex discrimination and retaliation. The district court dismissed for failure to state a claim under Rule 12(b)(6) and for summary judgment. The court concluded that subsection (g) created a security exemption to Title VII where access was denied to a premise where secure information was kept. Therefore, plaintiff could not be granted relief under Title VII where the government advanced numerous reasons for revocation of her access to the building where secured information was kept, all of which were related to security breaches she allegedly committed. View "Toy v. Holder, Jr." on Justia Law

Plaintiff sued her former employer asserting claims of gender discrimination and retaliation under the New York City Human Rights Law (NYCHRL), N.Y.C. Admin. Code 8-107(1)(a), (7). The district court granted summary judgment to the employer and dismissed the complaint. The court concluded, however, that the district court erred in granting summary judgment because the record presented genuine disputes of material fact regarding both plaintiff's claims under the NYCHRL. Accordingly, the court vacated the judgment and remanded for trial. View "Mihalik v. Credit Agricole Cheuvreux N. Am., Inc." on Justia Law

Plaintiff filed suit under Title VII and the New York State Human Rights Law (NYSHRL), N.Y. Exec. Law 290 et seq., alleging that an affair that one of her brothers had with another worker in their family business created a hostile work environment and that both of her brothers retaliated against her for complaining about the affair. On appeal, plaintiff challenged the dismissal of her retaliation claim. The court examined all of plaintiff's arguments on appeal and found them to be without merit. Because there was no indication that plaintiff believed that her sex had anything to with her treatment or that defendants could have understood her statements as such, she failed to establish a prima facie case for retaliation under Title VII and the NYSHRL. Accordingly, the court affirmed the district court's judgment. View "Kelly v. Howard I. Shapiro & Assocs. Consulting Eng'rs., P.C." on Justia Law

The City terminated plaintiff's employment after she refused a state trooper's request to take a drug test. Plaintiff sued the City and others, claiming that she was terminated in retaliation for her decision to exercise her Fourth Amendment rights. Even assuming the termination violated plaintiff's Fourth Amendment rights, it was not clearly established at the time of the incident that such an action was unconstitutional, and therefore defendants were entitled to qualified immunity. The court also agreed with the district court that plaintiff's remaining federal claims failed to allege a constitutional violation. The court further held that the district court properly dismissed the official capacity claims and the claims against the City where plaintiff failed to allege facts indicating that the City delegated final policymaking authority to the officials. Finally, because plaintiff did not explain why her Arkansas Civil Rights Act, Ark. Code Ann. 16-123-105(a), claims warranted separate analysis, the district court did not err in dismissing the ACRA claims alongside the 42 U.S.C. 1983 claims. Accordingly, the court affirmed the judgment. View "Hess v. Abels, et al" on Justia Law