Justia Civil Rights Opinion Summaries

Plaintiff and others brought claims of hostile work environment based on gender under the Civil Rights Act of 1964, 42 U.S.C. 2000e; 42 U.S.C. 1983; and the New York State Human Rights Law, N.Y. Exec. Law 290 et seq. (NYSHRL), as well as claims of retaliation under Title VII and the NYSHRL. Plaintiff subsequently appealed from the district court's grant of summary judgment in favor of the City. The court concluded that plaintiff's claim of a hostile work environment involving allegations of repeated solicitation of sexual relations in a vulgar and humiliating manner sufficed to warrant a trial; plaintiff's claim of gender discrimination because of hostile work environment also sufficed under the Equal Protection Clause of the Fourteenth Amendment; but the district court properly determined that plaintiff's claims of retaliation failed. Accordingly, the court reversed in part, affirmed in part, and remanded. In a summary order, the court affirmed the dismissal of the claims of the other plaintiffs. View "Desardouin v. City of Rochester" on Justia Law

Appellees sued the District, their employer, for retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The District argued on appeal, inter alia, that it was entitled to a new trial because of improper closing arguments. Appellees' counsel made four inappropriate arguments: three after the district court had sustained objections. The first three arguments were "golden rule" arguments and the fourth argument was a "send a message" argument. As the district court's efforts to cure the resulting prejudice were insufficient, the court reversed and remanded for further proceedings. View "Caudle, et al v. District of Columbia" on Justia Law

Plaintiff sued her former employer, SatCom, alleging violations of the Minnesota Whistleblower Act (MWA), Minn. Stat. 181.932; Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-.43; common law of wrongful termination, and Fair Labor Standards Act, 29 U.S.C. 201 et seq. Although plaintiff succeeded in establishing a prima facie case of retaliation where three of her reports constituted a protected activity, the court affirmed the district court's grant of summary judgment in favor of SatCom because SatCom had a legitimate, non-retaliatory reason for terminating plaintiff. Because the district court's McDonnell-Douglas analysis was sufficiently thorough to encompass plaintiff's claims under the Reporting Clause and Opposition Clause of the MWA, plaintiff was not entitled to reversal on this basis. Accordingly, the court affirmed the district court's grant of summary judgment in favor of SatCom. View "Wood v. SatCom Marketing, LLC, et al" on Justia Law

Young served as a Public Housing Revitalization Specialist in the Office of Public Housing in the Cleveland office of the Department of Housing and Urban Development for 10 years. Young was representing himself at an arbitration hearing, appealing his five-day suspension for disruptive behavior, misrepresentation of authority, and use of insulting language to and about other employees. One of the witnesses testifying against him was Darr, Executive Director of the Coschocton Metropolitan Housing Authority and a HUD client. Following Darr’s testimony, there was a recess; Darr claims that while he was walking down the hallway, about 25-30 feet away from Young, Young shouted from immediately outside the door of the hearing room, “[y]ou are a racist. You are a member of the KKK, and you should be shot.” Young was later placed on administrative leave; notice of proposed removal issued. Interviews were conducted after Young submitted his oral and written statements, so that Young was unaware of the content and substance of the interviews and was unable to respond to anything unearthed during those interviews. An arbitrator rejected a challenge to Young’s termination. The Federal Circuit reversed, finding that the agency violated Young’s due process rights and its own procedures.View "Young v. Dep't of Housing & Urban Dev." on Justia Law

Petitioner Laura Conroy filed this Title VII lawsuit against her employer, the United States Forest Service, after it (among other things) filled an open position with a male employee, instead of her. The district court excluded the testimony of Petitioner's two experts and granted summary judgment to the Forest Service. Petitioner did not have a college degree. She applied for the INFRA Program Manager position in the administrative series. She was found to be qualified, and her name, along with that of one other qualified applicant, was passed on to Larry Larson, the head of the group where the new position would be located. Mr. Larson, however, decided to readvertise the position. He would later explain that his reason for doing so was to broaden the pool of applicants. A revised announcement was issued modifying the job requirement noted above, replacing the words "[c]omprehensive knowledge and skills in" with simply "[k]nowledge of." The new advertisement drew interest from a greater number of applicants, and four were certified as sufficiently qualified for the position. Petitioner was certified under the administrative announcement, and three others were certified under the professional announcement. Among the latter three candidates was Daniel Hager, who had not applied when the position was originally advertised. Petitioner filed a grievance when she did not receive the position. Mr. Hager left the INFRA Program Manager position, and the position was readvertised. The position was advertised solely in the professional series. Although Petitioner applied again, she was deemed not qualified, and management ultimately selected Andrea Gehrke. Petitioner filed a second formal grievance, alleging that the decision to advertise the position solely in the professional series was made in order to retaliate against her for filing the first grievance. After exhausting administrative remedies, Petitioner filed suit in federal district court pursuant to Title VII of the Civil Rights Act. She asserted various individual and class claims arising out of the agency's hiring decisions. The district court ultimately ruled in the agency's favor. Upon review, finding no abuse of the district court's discretion, the Tenth Circuit affirmed dismissal of Petitioner's claims. View "Conroy v. Vilsack" on Justia Law

Plaintiff Cheryl Debano-Griffin sued Lake County and the Lake County Board of Commissioners alleging, in part, that she had been terminated from her position as the director of Lake County’s 911 department in violation of the Whistleblowers’ Protection Act (WPA) after she raised concerns about a potentially improper transfer of county funds from the county’s ambulance account and regarding the ambulance service provided to the county. Defendants moved to dismiss. The court denied the motion, and the jury returned a verdict in plaintiff’s favor. Defendants appealed. The Court of Appeals reversed and remanded for entry of an order granting summary judgment to defendants. In lieu of granting leave to appeal, the Supreme Court reversed the judgment of the Court of Appeals and remanded the case for consideration of an additional argument that had been raised by defendants. On remand, the Court of Appeals, held that plaintiff had failed to establish a genuine issue of material fact regarding the causation element of her claim and again reversed the trial court’s order denying defendants’ motion for summary judgment. Upon review of the matter, the Supreme Court concluded that plaintiff presented sufficient evidence that reasonable minds could differ regarding the board’s true motivation for eliminating her position and raised a genuine issue of material fact regarding causation. Defendants were not entitled to summary judgment. View "Debano-Griffin v. Lake County" on Justia Law

Plaintiff asserted wrongful termination claims against the WCRA, alleging disability discrimination and retaliation in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213; the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-.43; and the Minnesota Whistleblower Act, Minn. Stat. 181.932. On appeal, plaintiff challenged the district court's grant of summary judgment dismissing these claims. The court held that there was no evidence giving rise to an inference that the WCRA terminated her because of her medical condition; plaintiff had no claim of ADA retaliation because she did not engage in protected activity by complaining about disability discrimination; the court doubted that the supervisor's alleged harassment of plaintiff and intimidating management style created a hostile work environment; plaintiff's claim that the WCRA failed to provide reasonable accommodations for her disability failed because she never requested or otherwise adequately informed the WCRA of the need for additional accommodations; plaintiff's Whistleblower Act claim was without merit because there was no evidence plaintiff was terminated because she engaged in statutorily protected conduct; and plaintiff's contention that the district court abused its discretion by excluding certain affidavits was without merit because any error was harmless. Accordingly, the court affirmed the judgment. View "Lenzen v. Workers Compensation Reinsurance Assoc." on Justia Law

Plaintiffs were several dismissed or demoted employees of the State Insurance Fund Corporation, a public corporation that administered Puerto Rico's workers' compensation program. Before the adverse employment actions took effect, Plaintiffs requested informal administrative hearings before the Corporation. Plaintiffs then filed administrative appeals before the Corporation's board of appeals. The board had not acted on the appeals when Plaintiffs sued the Corporation and several of its officers in the U.S. district court, alleging political discrimination and due process violations stemming from adverse employment actions. The district court abstained under Younger v. Harris and dismissed Plaintiffs' claims, finding that Plaintiffs voluntarily engaged the wheels of an administrative procedure before filing an action in federal court. The First Circuit Court of Appeals reversed, holding (1) the district court erred in abstaining based on Younger, and dismissal was not the remedy in any event; and (2) a stay of the federal proceedings was appropriate in this case pending the Puerto Rico Supreme Court's decision in Gonzales Segarra v. State Ins. Fund Corp. View "Casiano-Montanez v. State Ins. Fund Corp." on Justia Law

Plaintiff, a former TDCJ employee, appealed the district court's grant of summary judgment for TDCJ on her Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), and Family Medical Leave Act (FMLA), 29 U.S.C. 2612(a)(1)(D), claims. Plaintiff's allergic reaction to the use of scented candles and wall plug-ins around her work area was the basis of her ADA claim. The court held that plaintiff did not suffer from a disability within the meaning and coverage of the ADA. Further, there was no dispute that TDCJ did not receive plaintiff's FMLA certification before the deadline. Accordingly, the court affirmed the judgment. View "Milton v. Texas Dept. of Criminal Justice" on Justia Law

The City fired Plaintiff, a bus driver, for allegedly poor job performance. Plaintiff brought this action against the City, alleging she was fired because of her pregnancy in violation of the Fair Employment and Housing Act (FEHA). During trial, the City requested the court to instruct the jury that if it found a mix of discriminatory and legitimate motives, the City could avoid liability by proving that a legitimate motive alone would have led it to make the same decision to fire Plaintiff. The trial court refused the instruction, and the jury returned a verdict for Plaintiff. The court of appeal reversed, concluding that the refusal to give the requested instruction was prejudicial error. The Supreme Court affirmed the court of appeal's judgment overturning the damages verdict in this case and remanded, holding (1) under the FEHA, when a jury finds that unlawful discrimination was a substantial factor motivating a termination of employment, and when the employer proves it would have made the same decision absent such discrimination, a court may not award damages, backpay, or an order of reinstatement; but (2) Plaintiff in this circumstance could still be awarded, where appropriate, declaratory relief or injunctive relief to stop discriminatory practices. View "Harris v. City of Santa Monica" on Justia Law