Justia Civil Rights Opinion Summaries

Plaintiff brought a Title VII action against her former employer, West Coast, claiming sexual harassment and retaliatory discharge. The district court granted summary judgment to West Coast and plaintiff appealed. Because the court concluded that the evidence, viewed favorably to plaintiff, did not show sexual harassment that was sufficiently severe or pervasive to alter the terms of plaintiff's employment and subject her to an abusive environment, the court affirmed the judgment for West Coast on her sexual harassment claim. The court concluded that the evidence was sufficient to raise a material question of fact as to whether plaintiff's July 14 complaints - which the court already said could be protected activity - were a but-for cause of her termination. Therefore, the court believed that the district court erred in granting summary judgment on the retaliation claim. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Westendorf v. West Coast Contractors of NV" on Justia Law

Although Hall has been a plumber for the City of Chicago since 1995, she was on disability leave from 1999 to 2003 due to a work-related injury. Hall returned to the City’s employ with the limitation that she could not lift over 25 pounds. Hall and the City agree this restriction precluded her from resuming work as a plumber, so Hall began working in the House Drain Inspectors Division of the Department, which was composed of 13 male house drain inspectors and the supervisor’s female secretary. Hall claims that the supervisor created a hostile work environment by assigning her menial work and prohibiting coworkers from interacting with her. The district court granted the defendants summary judgment in her Title VII suit, finding that the conduct was not hostile in comparison to other employees’ responsibilities and that Hall failed to produce evidence that the supervisor’s conduct was because of her sex. The Seventh Circuit reversed, stating that a jury could infer that deliberate isolation of Hall was sufficiently pervasive to constitute a hostile work environment and that the supervisor’s comments to Hall could indicate that Hall’s gender played a part in his actions. View "Hall v. City of Chicago" on Justia Law

Plaintiffs, three applicants for attorney positions under the Honors Program in 2006, alleged that they were not selected for interviews because of their political affiliations. Plaintiffs claimed that senior officials at the DOJ created records describing how an individual exercised First Amendment rights, in violation of the Privacy Act, 5 U.S.C. 552a, in the form of annotations to plaintiffs' applications and internet printouts concerning their political affiliations. The court held that summary judgment was inappropriately granted on plaintiffs' Privacy Act claims under 5 U.S.C. 552a(e)(5) and (e)(7). In light of the destruction of plaintiffs' records, a permissive spoliation inference was warranted because the senior DOJ officials had a duty to preserve the annotated applications and internet printouts given that DOJ investigation and future litigation were reasonably foreseeable. On remand, the district court shall construe the evidence in light of this negative spoliation inference, which would permit a reasonable trier of fact to find that two of the plaintiffs were harmed by creation and use of the destroyed records. View "Gerlich, et al v. DOJ, et al" on Justia Law

Plaintiff sued the City and her supervisors, claiming that the City's reasons for terminating her were pretextual. The district court granted defendants' motion for summary judgment on all of plaintiff's seven claims. The court affirmed the judgment because there was no evidence or reasonable inference that the City's reasons for terminating plaintiff's employment for failure in performance of her duties were pretextual. View "Brown v. City of Jacksonville, et al" on Justia Law

Plaintiff appealed the district court's dismissal of his complaint, filed in forma pauperis (IFP), for untimely service of process and failure to state a claim. Plaintiff claimed that First Student fired him from his position as a bus driver based on his race, age, disability, seniority rights, and eligiblity for a pay raise. The court vacated the district court's order, remanding for further proceedings, because the court concluded that the complaint stated a claim and because the court could not determine from the record whether the delay in service of process was plaintiff's fault or was attributable to delays by district court staff and the USMS. View "Wright v. First Student, Inc." on Justia Law

Plaintiff brought suit against the Chief of Police and the City under 42 U.S.C. 1983, alleging a First Amendment retaliation claim. Plaintiff, a police officer for the City, led a no-confidence vote of the police officers' union against the Chief. The Chief subsequently delayed signing an application for a certification that would have entitled plaintiff to a five percent salary increase. The district court granted summary judgment in favor of defendants, concluding that plaintiff failed to meet his burden under Garcetti v. Ceballos, to show that he undertook his act as a private citizen and not pursuant to his official duties. The court disagreed and held that plaintiff had established a prima facie case of First Amendment retaliation. Therefore, the court reversed the grant of summary judgment in favor of the Chief and remanded for further proceedings. The court affirmed the district court's grant of summary judgment to the City because plaintiff did not adduce sufficient evidence to defeat summary judgment on his Monnell claim. View "Ellins v. City of Sierra Madre, et al" on Justia Law

Plaintiffs were former employees of the Puerto Rico Administration of Juvenile Institutions. After an election that produced a regime change, Plaintiffs were ousted from their positions, notwithstanding solid qualifications and positive evaluations. Plaintiffs sued several government defendants, invoking 42 U.S.C. 1983 and alleged discrimination based on political affiliation in violation of the First Amendment. Plaintiffs also lodged pendent claims under Puerto Rico law. The district court ruled that the complaint failed to state a claim for relief because it did not assert facts sufficient to establish a prima facie case of political discrimination. The First Circuit Court of Appeals reversed in part, holding (1) the prima facie case is not the appropriate benchmark for determining whether a complaint has met the plausibility standard under Bell Atlantic v. Twombly; (2) the factual allegations in Plaintiffs' complaint, taken as true, state plausible section 1983 claims for political discrimination with respect to two of the defendants; and (3) the pendent claims against those two defendants, which were dismissed without prejudice when the district court declined to exercise supplemental jurisdiction, must be reinstated. Remanded. View "Rodriguez-Reyes v. Molina-Rodriguez" on Justia Law

Plaintiff, an Egyptian-American, filed a workplace discrimination suit against the Mohegan Council, Boy Scouts of America alleging that he was denied career advancement opportunities on account of his religion of Islam and his national origin. After a jury trial, the district court ruled in favor of Plaintiff. The First Circuit Court of Appeals affirmed, holding that the district court did not err in denying Mohegan Council's motion for judgment as a matter of law, where (1) the district court correctly found that Mohegan Council was an "employer" with the requisite fifteen or more employees under the Title VII of the Civil Rights Act of 1964; (2) Plaintiff's complaint with the Massachusetts Commission Against Discrimination was timely filed; and (3) sufficient evidence supported a finding of discrimination. View "Aly v. Mohegan Council, Boys Scouts of Am." on Justia Law

Goldman Sachs appealed from an order of the district court denying their motion to compel arbitration of plaintiff's claims of gender discrimination. Plaintiff and others alleged that Goldman Sachs engaged in a continuing pattern and practice of discrimination based on sex against female employees in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000 et seq., and the New York City Human Rights Law, Administrative Code of the City of New York 8-107 et seq. On appeal, plaintiff contended that the arbitration clause in her agreement must be invalidated because arbitration would preclude her from vindicating a statutory right. The court disagreed and held that the district court erred in denying the motion to compel arbitration where plaintiff had no substantive statutory right to pursue a pattern-or-practice claim. Accordingly, the court reversed the judgment of the district court. View "Parisi v. Goldman, Sachs & Co." on Justia Law

In 1999, Geraldine Fuhr successfully sued to be instated as varsity boys basketball coach at Hazel Park High School, where she had been employed as varsity girls basketball coach. For five years she coached both teams. In 2006, she was removed from her position coaching varsity girls basketball. She claims that her dismissal as the varsity girls basketball coach and other acts of harassment were a result of her 1999 suit. The district court granted the district summary judgment, rejecting claims of retaliation (42 U.S.C. 2000e-3(a)), gender discrimination, and hostile work environment. The Sixth Circuit affirmed, noting a substantial time gap between the suit and the complained-of actions and the district’s complained-of actions were not discriminatory. View "Fuhr v. Hazel Park Sch. Dist." on Justia Law