Justia Civil Rights Opinion Summaries

Plaintiff Allstate Sweeping, LLC (Allstate) is owned and operated by two white women: Martha Krueger and Barbara Hollis. In January 2006 it began performing pressure-washing services at Denver International Airport (DIA) under a contract with the City and County of Denver (Denver). Although the contract term was through July 2008, it was terminated by Denver July, 2007. Defendant Calvin Black, a contract-compliance technician at DIA, was assigned to monitor Allstate’s contract. Black is an African-American male. Allstate claimed that it was subjected to gender- and race-based discrimination and to retaliation for its complaints of discrimination. It filed suit in the federal district court in Colorado against Denver and four DIA employees, including Black, claiming violations of 42 U.S.C. 1981, 42 U.S.C. 2000d (Title VI), and the Equal Protection Clause of the Fourteenth Amendment. The district court granted summary judgment to all defendants except Black, holding that there were genuine issues of fact regarding whether Black was motivated by racial and gender bias and whether Black created a hostile work environment in such a way as to make plaintiff’s contract "unprofitable and its owners miserable." It did not address Allstate’s retaliation claim. Black appealed the denial of his motion for summary judgment, contending that he was entitled to qualified immunity and that the Tenth Circuit had jurisdiction to review the denial under the collateral-order doctrine. Upon review, the Tenth Circuit held that it lacked jurisdiction to review the district court’s determinations because such sufficiency determinations are not reviewable under the collateral order doctrine. The Court did, however, have jurisdiction to review the legal sufficiency of the claim that Black made Allstate’s owners "miserable" and to review the sufficiency of the evidence of the retaliation claim (which the district court did not consider). The Court reversed the denial of summary judgment on those claims. View "Allstate Sweeping, LLC v. Black" on Justia Law

Plaintiff, a nurse working for Employer, was injured during a horseback riding accident. Plaintiff's employment was later terminated. Plaintiff filed a complaint against Employer, alleging Employer retaliated against her for requesting an accommodation in violation of the Americans with Disabilities Act (ADA) and the Maine Human Rights Act (MHRA). The district court granted summary judgment in favor of Employer, concluding that Plaintiff had failed to adduce evidence that Employer's stated basis for terminating Plaintiff was pretextual and that Plaintiff's evidence of retaliatory animus was too conclusory and speculative to take to trial. The First Circuit Court of Appeals vacated the entry of summary judgment on Plaintiff's retaliation claims under the ADA and MHRA, holding that Plaintiff presented sufficient evidence to bring to a jury. Remanded. View "Kelley v. Corr. Med. Servs., Inc." on Justia Law

A jury found in favor of plaintiff in his employment-discrimination suit under the Missouri Human Rights Act (MHRA), section 213.010 of the Missouri Revised Statutes, against Kaman. Both parties appealed. The court held that plaintiff made a submissible case for punitive damages by providing clear and convincing proof from which a reasonable factfinder could conclude that Kaman acted with evil motive or reckless indifference when it retaliated against him; the $500,000 in punitive damages that the jury awarded plaintiff did not violate due process; the district court did not did not err in refusing to grant a new trial on plaintiff's discrimination and retaliation claims; and the district court did not abuse its discretion in restricting plaintiff's recovery of attorneys' fees. Accordingly, the court affirmed the judgment. View "Trickey v. Kaman Industrial Technologies Corp." on Justia Law

Plaintiff filed a complaint pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., the District of Columbia Human Rights Act of 1977, D.C. Code 2-1404.01 et seq., and the Civil Rights Act of 1991, 42 U.S.C. 1981a, against the City, alleging that she had suffered sexual harassment during the course of her employment with the DCFEMS. The district court granted the City's motion to dismiss, dismissed plaintiff's Title VII claim with prejudice because she had not filed a timely Charge with the EEOC, and declined to exercise supplemental jurisdiction over her D.C. Human Rights Act claim. On appeal, plaintiff challenged the district court's denial of her motion for reconsideration. The court held that the district court did not err in finding that plaintiff failed to meet the requirements for equitable tolling of the statute of limitations. Plaintiff neither pursued her rights diligently nor proved that some extraordinary circumstance prevented her from satisfying the statute of limitations. Therefore, the court affirmed the judgment. View "Dyson v. District of Columbia" on Justia Law

A group of firefighters brought a class action lawsuit against the City of Atlanta alleging that the city breached its employment contracts with the firefighters as well as its statutory obligation to provide a fair and impartial promotional process by failing to prevent cheating on a fire lieutenant promotional exam. The trial court issued an interlocutory injunction prohibiting the city from making any permanent promotions based on the results of the challenged exam and providing that all appointments would be temporary pending a final decision on the merits of the case. After the jury returned a verdict in favor of the plaintiffs, the trial court crafted a permanent injunction that contained mandatory instructions regarding how the city must re-test. Appellants, all of whom are firefighters who scored 90 or higher on the first exam, appealed the permanent injunction to challenge provisions of the injunction that treated them as "probable cheaters." Appellees (named plaintiffs in the class action), moved to dismiss the appeal, arguing that appellants lacked standing to challenge the trial court’s judgment because they were not parties to the original action and because the judgment was not entered against them. Upon review of the matter, the Supreme Court found appellants had standing to appeal the judgment in this case. Further, the Court held that the trial court abused its discretion in fashioning injunctive relief specific to appellants and erred in entering judgment against them. Accordingly, the Court vacated those portions of the permanent injunction that required the city to treat appellants differently from class members. View "Barham v. City of Atlanta" on Justia Law

McArdle was hired as principal of Lindbergh School in 2008 with a two-year contract that allowed termination after one year with payment of severance. Lindbergh’s prior principal, Davis, was McArdle’s superior. McArdle claims that she discovered irregularities, including Davis’ use of school funds for personal purposes; improper payment to a student teacher; and circumvention of rules regarding admission of nonresidents. McArdle alleges that she received evasive responses from Davis. Davis put McArdle on a performance improvement plan in 2009, asserting parental complaints, but refusing to identify complainants. McArdle was told that the board would consider termination of her contract. McArdle consulted an attorney and filed a police report, accusing Davis of theft of school funds. She sent letters to the board, listing improprieties. Davis was excused from the meeting; the board discussed McArdle’s allegations, then voted to terminate McArdle’s contract at the end of the school year. Davis was prosecuted for theft of school funds. The district court granted defendants summary judgment on claims under the First Amendment and of breach and interference with contract. The Seventh Circuit affirmed. McArdle’s reporting of misconduct was speech as a public employee, not shielded from her employer’s response; defendants’ motives are immaterial. View "McArdle v. Peoria Sch. Dist. 150" on Justia Law

Plaintiff sued the former Mayor of the City of Russelville and the members of the Russellville City Council in federal district court, alleging age and race discrimination. Defendants subsequently filed an interlocutory appeal, seeking a reversal of the district court's denial of legislative immunity. The court concluded that defendants were entitled to legislative immunity where defendants not only eliminated plaintiff's position, but also instantaneously created a seemingly identical position. In the present case, control over the position at issue moved from the Mayor to the City Council, a quintessential legislative decision. View "Leaphart v. Williamson, et al" on Justia Law

Plaintiff sued her employer, alleging violations of Title II of the Americans with Disabilities Act (ADA), 42 U.S.C. 12131 et seq. Plaintiff alleged that her job as a librarian at the Library was terminated because of behavior symptomatic of her chronic mental illness. Because the court concluded that Title II did, in some circumstances, require reasonable departures from standards established by state laws, the court vacated the district court's judgment of dismissal in that respect. Because the court concluded, based principally on the structure of the ADA, that Title II did not apply to employment discrimination, the court affirmed the district court's judgment of dismissal of that claim. View "Mary Jo C. v. New York State and Local Retirement Sys." on Justia Law

Plaintiff, a former sergeant with the Hartford Police Department, appealed the district court's grant of summary judgment to defendants where plaintiff alleged, inter alia, that defendants wrongfully failed to promote him and defendants instigated several internal affairs investigations into his conduct on the basis of his race or national origin. With respect to plaintiff's discrimination claims, the court held that he failed to introduce factual evidence that defendants' nondiscriminatory reasons for the investigation and failure to promote him were pretextual or that plaintiff's race or national origin was a motivating favor. With respect to Chief Croughwell, although the court agreed with plaintiff that his statement to the press implicated a matter of public concern, the court affirmed the judgment on the district court's alternative ground that Chief Croughwell was protected from liability by qualified immunity. View "Garcia v. Hartford Police Dept." on Justia Law

Plaintiff claimed that his former employer discriminated against him on account of his age when it terminated his employment, in violation of the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. 621 et seq. The employer argued that the reason for plaintiff's discharge was due to a reduction in force (RIF), not his age, 71-years-old. After thorough review of the record with benefit of oral argument, the court affirmed the district court's grant of summary judgment in favor of the employer, concluding that no reasonable fact finder could find that the employer's decision was "but-for" his age and plaintiff had not established that the project manager acted as a mere cat's paw for the assistant project manager's discriminatory animus. View "Sims, Jr. v. MVM, Inc." on Justia Law