Justia Civil Rights Opinion Summaries

Plaintiff, an employee of NGA with a top secret security clearance, informed the NGA of his marriage after the investigation for his security clearance had been completed but before he had begun work. The NGA conducted a reinvestigation into his security clearance and then revoked the security clearance. Plaintiff commenced this action under the Administrative Procedure Act (APA), 5 U.S.C. 500 et seq., against the NGA and its Director to reverse the NGA's decision, to reinstate his security clearance, and to award him back pay, benefits, and attorneys' fees. The district court dismissed the complaint, concluding that it did not have subject-matter jurisdiction to review a security clearance determination. The court concluded that plaintiff's speculative and conclusory allegations of constitutional violations were essentially recharacterizations of his challenge to the merits of the NGA's security clearance determination and that the court did not have jurisdiction to review such a determination. Accordingly, the court affirmed the judgment. View "Hegab v. Long" on Justia Law

Plaintiff, a professor at LSU, appealed the district court's dismissal of his complaint for lack of subject matter jurisdiction and for failure to state a claim on which relief can be granted. Plaintiff alleged discrimination based on his race, religion, national origin, age, and gender. Although plaintiff asserted claims for injunctive and declaratory relief, he could not overcome sovereign immunity under Ex parte Young because he named only LSU, LSU Health, and the LSU Board as defendants. Therefore, the court found that sovereign immunity barred plaintiff's claims under the Age Discrimination in Employment Act, 29 U.S.C. 621 et seq., and 42 U.S.C. 1983 and 1985. Plaintiff's state law claims were also barred by sovereign immunity. With regard to plaintiff's remaining claims, the court recognized that plaintiff was not required to establish a prima facie case of discrimination at the pleading stage, but the court nonetheless concluded that plaintiff had failed to state a claim for which relief could be granted. Accordingly, the court affirmed the judgment. View "Raj v. LSU, et al" on Justia Law

Dodd, an African-American mail carrier for the U.S. Postal Service, was the subject of an investigation for failing to deliver mail. He was arrested and held for seven days before charges were dismissed. He filed suit, alleging claims of false imprisonment, false arrest, abuse of process, and malicious prosecution under the Federal Tort Claims Act, and of race discrimination under Title VII of the Civil Rights Act of 1964. The district court dismissed Dodd’s FTCA claim because it determined that the claim was preempted by the Civil Service Reform Act, 5 U.S.C. 2301, and granted summary judgment in favor of defendants on Dodd’s Title VII claim because Dodd failed to make a prima facie showing of discrimination. The Sixth Circuit reversed with respect to the FTCA claim, noting that the Civil Service Reform Act does not apply to postal employee, but affirmed with respect to the Title VII claim. View "Dodd v. Potter" on Justia Law

Relator, a trucking company, sought a writ of mandamus compelling Respondents, the Bureau of Motor Vehicles (BMV) Registrar and the Department of Public Safety Director, to provide an unredacted, noncertified copy of the driving records of the trucking company's employee at cost. This case was consolidated with a direct appeal from the Tenth District Court of Appeals involving the same parties and the same issues but a different driving record. The BMV refused to provide the copies at cost but instead, following the BMV rule, required Relator to specify the basis for its entitlement to an unredacted copy and to pay a $5 fee for a certified copy. Relator claimed it should be able to receive an unredacted copy at cost under the Public Records Act. The Supreme Court affirmed the Tenth District in one case and denied the writ in the other case, holding (1) the BMV properly promulgated the rule at issue under its rule-making procedure; and (2) therefore, disclosure of the records was prohibited under the Driver's Privacy Protection Act and its counterpart in Ohio unless Relator could demonstrate a permissible use. View "State ex rel. Motor Carrier Serv., Inc. v. Rankin" on Justia Law

Appellants, state police officers, brought this suit individually and on behalf of a class consisting of members of the Arkansas State Police Retirement System (ASPRS), contending that various state defendants had violated the law by failing to properly fund the ASPRS between 1992 and 2003 and that the improper funding violated the Arkansas Constitution. The circuit court dismissed some of Appellants' claims and remanded. On remand, the circuit court granted summary judgment for Defendants. On appeal, Appellants asserted that the circuit court erred in finding that a uniform and travel-expense allowance provided for in Ark. Code Ann. 12-8-209 was not reportable to the ASPRS as a portion of payroll pursuant to Ark. Code Ann. 24-6-209(a). The Supreme Court affirmed, holding that section 24-6-209(a) does not include a uniform and travel-expense allowance such that it is reportable to ASPRS for purposes of calculating retirement benefits. View "McLemore v. Weiss" on Justia Law

Plaintiff was hired by Employer in 2000 and began working as part of a five-person sales team. In 2009, Employer reduced the sales team to two employees and terminated Defendant. Plaintiff was fifty-five years old at the time. Plaintiff subsequently file a complaint with the Massachusetts Commission Against Discrimination (MCAD), alleging age discrimination. MCAD dismissed Plaintiff's complaint for a lack of probable cause. Plaintiff then brought suit in state court, claiming age discrimination under Massachusetts law. Employer removed the case to the U.S. district court based on diversity jurisdiction. Thereafter, the district court granted Employer's motion for summary judgment. The Supreme Court affirmed, holding that the district court did not err (1) in partially denying Plaintiff's third motion to compel; (2) in quashing deposition notices for three of Employer's employees; and (3) in granting summary judgment to Employer. View "Woodward v. Emulex Corp." on Justia Law

Plaintiff, an instructor in graphics who did not have a Ph.D., was denied a tenure-track position at the University of Puerto Rico. Three others, all of whom had Ph.D.s as the description required, did receive tenure-track positions. Plaintiff filed administrative discrimination charges, followed by a Title VII lawsuit against the University. The district court granted summary judgment for the University. The First Circuit Court of Appeals affirmed, holding that the Ph.D. requirement for tenure-track positions was a legitimate, nondiscriminatory reason for the University's actions and that Plaintiff did not meet her burden of showing that the articulated reason was pretextual. View "Johnson v. Univ. of P.R." on Justia Law

Plaintiff filed suit against the State alleging statutory claims under the Rhode Island Fair Employment Practices Act, the Rhode Island Civil Rights Act, and the Rhode Island Whistelblowers' Protection Act. The State filed a motion to dismiss and a motion for summary judgment, arguing that the claims should be barred by the doctrine of res judicata because Plaintiff had previously filed a nearly identical suit in federal court, which dismissed the action. The superior court denied the State's motions. The Supreme Court quashed the decision of the superior court and remanded, holding that the federal court judgment was entitled to preclusive effect, and Plaintiff's claims were barred by res judicata. View "Huntley v. State" on Justia Law

Cromwell was fired from his position as a Momence police lieutenant, after an incident of alleged misconduct involving alcohol that was followed by lying and insubordination during the investigation. Cromwell sued, arguing that his termination was procedurally inadequate and that that he had a constitutionally protected property interest in his continued public employment derived from the city’s Police Department Rules and Regulations, which provide that probationary employees may be terminated at any time for any reason but omit similar language with regard to nonprobationary employees. The district court rejected this argument and dismissed. The Seventh Circuit affirmed. The regulations on which Cromwell based his claim do not contain the clear language needed to overcome Illinois’s presumption of at-will employment. Something more than inference from silence is required. View "Cromwell v. City of Momence" on Justia Law

Plaintiff appealed the district court's dismissal of her claims of employment discrimination and retaliation under federal, state, and New York City law. Plaintiff claimed that defendants unfairly reprimanded her, observed her classroom with unusual frequency, evaluated her classroom performance negatively, and gave her less desirable classroom assignments and duties. She argued that these actions were unwarranted and motivated by discriminatory and retaliatory animus. Defendants acknowledged that they increased their supervision of and attention toward plaintiff, but they contended that they did so to address her performance and behavioral issues. The court concluded that the district court properly granted summary judgment in favor of defendants for substantially the reasons articulated by the district court. With respect to plaintiff's retaliation claims, even if the court assumed that defendants' actions resulted in adverse employment action, no reasonable jury could find that such actions were motivated by a retaliatory animus. Accordingly, the court affirmed the judgment in its entirety. View "Sotomayor v. City of New York" on Justia Law