Justia Civil Rights Opinion Summaries

Plaintiff appealed the district court's denial of relief on her claims of discrimination, retaliation, and hostile work environment, brought under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e, as well as wrongful discharge, assault, and battery, brought under Virginia law, against Huntington Ingalls, the successor to her former employer. According to plaintiff, Huntington Ingalls subjected her to an ongoing sexually hostile work environment and her claims centered on the actions of her supervisor. The court held that the district court properly declined to consider those allegations not included in plaintiff's EEOC charge; because the district court correctly determined that amending her complaint would be futile, it did not abuse its discretion in denying her leave to do so; because the department manager did not know of the protected activity, and because the supervisor, who allegedly influenced him, was not principally responsible for the decision to terminate plaintiff's employment, the court affirmed the district court's grant of summary judgment to Huntington Ingalls on the retaliatory discharge claim; and the court affirmed the district court's grant of summary judgment as to the assault and battery claims. View "Balas v. Huntington Ingalls Industries" on Justia Law

Plaintiff, an international affairs specialist at the Puerto Rico State Department, filed a complaint against the Department, ten of its employees, the Commonwealth (collectively, the State Department defendants), and the Puerto Rico Ports Authority. Plaintiff alleged that the State Department defendants had discriminated against her due to her political views and that they had denied her the rights and benefits to which she was entitled under federal and local law. As against the Ports Authority, Plaintiff alleged it slandered her by publishing false information regarding an arrest for marijuana, which prevented her from fulfilling her work duties. The district court found that Plaintiff's complaint failed to state a claim upon which relief could be granted and dismissed the complaint. Plaintiff appealed, requesting a reversal of the district court's refusal to grant leave to amend the complaint based upon its finding that amendment would be futile. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in denying the requested amendment. View "Flores-Silva v. McClintock-Hernandez" on Justia Law

Chrylser appealed an adverse jury verdict in favor of plaintiff on a retaliation claim under the Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213. Plaintiff cross-appealed, claiming that the district court improperly granted a motion for directed verdict on a punitive-damages claim and improperly reduced the attorney's fee award. The court held that the jury instruction on plaintiff's retaliation claim was proper; evidence was sufficient to support the verdict under the MHRA "contributing factor" standard; and the evidence was sufficient to support the jury's economic-damages award. The court affirmed the district court's refusal to submit the punitive damages claim to the jury. Because plaintiff also requested attorney's fees for time spent on post-trial motions and appellate work, however, the court remanded to the district court for consideration of this request, leaving the issue to the district court's discretion. View "Al-Birekdar v. Chrysler Group, LLC" on Justia Law

In October 2008, Deputy Kuhn, a black man, stopped Joseph, a white woman for a traffic violation. Joseph falsely reported that Kuhn had raped her during the stop. An internal investigation into the allegation was not closed until January 2009. Several months after the investigation closed, Kuhn requested medical leave based on stress. Kuhn eventually took approximately seven months of paid and unpaid leave that did not end until he was terminated in January 2010. He filed suit against the county, and his superior. Against the county only, Kuhn asserted claims for termination without due process of law, violation of Michigan’s Whistleblowers’ Protection Act, Mich. Comp. Laws 15.361, and retaliation in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e. Kuhn asserted a claim against his superior only for tortious interference with business expectancy. Against both, Kuhn asserted racial discrimination in violation of 42 U.S.C. 1981, racial discrimination and harassment in violation of Title VII, and racial discrimination and harassment in violation of Michigan’s Elliott-Larsen Civil Rights Act, Mich. Comp. Laws 37.2101. The district court granted summary judgment in favor of both defendants on all claims. The Seventh Circuit affirmed. View "Kuhn v. County of Washtenaw" on Justia Law

Kristofek, a part-time police officer in Orland Hills, arrested a driver for traffic violations, but the driver turned out to be the son of a former mayor of a nearby town. Kristofek was ordered to let him go. Kristofek disagreed with what he believed was political corruption and expressed his concerns to fellow officers, supervisors, and eventually the FBI. When Police Chief Scully found out about this conduct, he fired him. Kristofek sued, bringing First Amendment retaliation claims against Scully and the village under 42 U.S.C. 1983. The district court dismissed, finding that Kristofek’s speech did not involve a matter of public concern, principally because his sole motive was to protect himself from civil and criminal liability. The Seventh Circuit reversed. The complaint did not allege that Kristofek’s only motive was self-interest, and the mere existence of a self-interest motive does not preclude the plausibility of mixed motives, which is consistent with protected speech. Kristofek plausibly pled, “albeit barely,” that Scully had at least de facto authority to set policy for hiring and firing, sufficient to sustain a “Monell” claim against the village. View "Kristofek v. Village of Orland Hills" on Justia Law

Plaintiff sued the BBG pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., after she did not receive a promotion. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of the BBG. The court agreed with the district court's finding that no reasonable employee could believe that the objected-to conduct was unlawful under Title VII and therefore, summary judgment was appropriately granted on plaintiff's retaliation claims. Although the court had not held that bad faith was required for a party to be entitled to a spoliation inference where, as here, there was a duty of preservation, the error was harmless. Plaintiff's objections to the selection process, even applying a spoliation inference, failed to demonstrate that summary judgment was inappropriately granted on her discrimination claims. Accordingly, the court affirmed the judgment. View "Grosdidier v. Broadcasting Board of Governors" on Justia Law

Montone was an officer with the Jersey City Police Department from 1981 until 2010, when she retired as a sergeant. Plaintiffs are present or former sergeants in the JCPD. The plaintiffs claim that retaliation for exercise of First Amendment rights and discrimination, in violation of 42 U.S.C. 1983 and New Jersey state law, was the basis of their failure to be promoted from the rank of sergeant to lieutenant during Healy’s tenure as mayor and Troy’s tenure as police chief. Healy’s mayoral campaign was heated and personal. Plaintiffs claim that all promotions from sergeant to lieutenant were halted by Healy and Troy to penalize Montone for her support of Healy’s opponent. Each plaintiff had passed the civil service examination required to be promoted to the rank of lieutenant. The district court entered summary judgment in favor of the defendants. The Third Circuit vacated, finding that genuine issues of material fact remained concerning defendants’ motivations for their decisions. View "Montone v. City of Jersey City" on Justia Law

Respondents were former employees of Verizon West Virginia, Inc. who filed wrongful termination claims against Verizon based upon alleged violations of the West Virginia Human Rights Act. Petitioners were Verizon and various of its managerial and similar-positioned employees (collectively, Verizon) who were named as defendants in the underlying wrongful termination proceedings. At issue before the Supreme Court was Verizon's contention that Respondents' counsel's (Law Firm) prior representation of other former employees of Verizon in substantially related matters that were settled and dismissed required Law Firm to be disqualified. The circuit court permitted Law Firm to continue its representation of Respondents. Verizon subsequently requested the issuance of a writ of prohibition disqualifying Law Firm. The Supreme Court denied the writ, finding that Verizon was not entitled to prohibitory relief because (1) Law Firm's successive representation of its former and current clients did not constitute a conflict under the West Virginia Rules of Professional Conduct; and (2) moreover, the relief requested by Verizon would impermissibly restrict Law Firm's right to practice law in contravention of the Rules of Professional Conduct. View "State ex rel. Verizon West Virginia, Inc. v. Circuit Court" on Justia Law

Vaughn started working for the U.S. Forest Service in 1974. Vaughn filed internal complaints in 1997, 2004, 2005 and 2006, asserting discrimination based on race and age, and retaliation for exercising his right to bring such complaints. Vaughn filed suit, but in 2007 signed a settlement agreement. Two days later, he received a “letter of direction” describing a change in his work schedule. He would no longer work regular weekday hours. After receiving the letter, Vaughn was passed over for a temporary assignment and was denied overtime. During roughly the same period, Vaughn’s relationship with a co-worker ended, she accused him of harassment, and he was placed on administrative leave. She continued to complain after he returned and filed an EEOC complaint and a state court order of protection. Vaughn sued under Title VII, 42 U.S.C. 2000e to 2000e-17, claiming retaliation for engaging in protected activity. The district court granted the employer summary judgment. The Seventh Circuit affirmed. Vaughn failed to establish a prima facie case of retaliation because he has failed to demonstrate that he was meeting his employer’s legitimate expectations. The employer put forward, and he failed to rebut, a legitimate reason for the action that was taken. View "Vaughn v. Vilsack" on Justia Law

Plaintiff sued United Systems for sex and disability discrimination after she was terminated. After plaintiff prevailed on both claims, United Systems appealed the district court's denial of its post trial motions for judgment as a matter of law and for remittitur of the mental anguish damages. The court concluded that a legally sufficient basis existed for a reasonable jury to determine that plaintiff had made a showing that she had been discriminated against by her employer. Since the court concluded that the district court did not err in denying United Systems' motion for judgment as a matter of law on plaintiff's sex discrimination claims, the court need not address the denial of the motion on her disability discrimination claims. Considering precedent and the record made in this case, the court could not conclude that the award of $100,000 to plaintiff was monstrous, shocking, or grossly excessive. Accordingly, the district court did not manifestly abuse its discretion in denying the motion for remittitur. View "Hudson v. United Systems of Arkansas, Inc." on Justia Law