Justia Civil Rights Opinion Summaries

Plaintiff, a female physician of Iranian origin, brought claims under Title VII, 42 U.S.C. 2000e et seq., and the Iowa Civil Rights Act, Iowa Code ch. 216, alleging discrimination based on her sex, pregnancy, and national origin. The court affirmed the district court's grant of summary judgment to defendant, concluding that plaintiff could not assert a claim under either statute because she was an independent contractor. View "Glascock v. Linn County Emergency Medicine" on Justia Law

Norman Budge and twenty-eight additional parties (collectively, Employees) filed a complaint for review of government action for the Town of Millinocket's (Town) amendments to its personnel policy originally adopted as a town ordinance. In the most recent amendment, the Town reduced its obligation for paying for the health insurance plan for its employees and established a new policy for the health insurance offered to retirees that resulted in the Town reducing its payment of the retirees' premiums. Employees alleged that, regardless of the policy language, this reduction was inconsistent with promises made to them either when they were hired or during their tenure with the Town. The superior court granted summary judgment in favor of the Town. The Supreme Court affirmed, holding (1) the personnel policy did not create an enforceable contract between the Town and its employees; (2) the Town was not bound to pay Employees' retirement group hospitalization and life insurance premiums by virtue of promissory estoppel; and (3) the Town's reduction in benefits did not result in an unconstitutional taking. View "Budge v. Town of Millinocket" on Justia Law

Defendant, the Superintendent of the Connecticut Technical High School System, renewed a motion for summary judgment, arguing that she was entitled to qualified immunity in this 42 U.S.C. 1983 action in which defendant was alleged to have deprived plaintiff of her right to procedural due process. The district court denied the motion after concluding that there existed a dispute of material fact as to whether plaintiff received sufficient notice before the elimination of her position as a guidance counselor at a Connecticut high school. The court held that defendant's conduct in this case, even when viewed in the light most favorable to plaintiff, did not violate plaintiff's clearly established rights. Therefore, defendant was entitled to qualified immunity. The court reversed and remanded. View "Coollick v. Hughes" on Justia Law

The EEOC appealed from a post-judgment order by the district court denying its request for injunctive relief against defendant following a jury verdict finding defendant liable for sexual harassment and fostering a sexually hostile work environment, in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and New York State law. The court held that the district court abused its discretion in denying any injunctive relief to the EEOC. At minimum, the district court was obliged to craft injunctive relief sufficient to prevent further violations of Title VII by the individual who directly perpetrated the egregious sexual harassment at issue in this case. Accordingly, the court vacated and remanded for further proceedings. View "Equal Employment Opportunity v. KarenKim, Inc." on Justia Law

In this appeal from the denial of a preliminary inunction, plaintiff labor unions claimed that sections 6.007-.010 of Law 222, Puerto Rico's campaign finance law, placed an unconstitutional burden on the union's First Amendment right to engage in political speech. Both the district court and the government declined to address the merits of Plaintiffs' claims. The First Circuit Court of Appeals issued an appellate injunction enjoining enforcement of the challenged provisions of Law 222 pending the final disposition of this appeal. In this opinion the First Circuit outlined the reasons it ordered entry of the appellate injunction, holding, among other things, that it was incumbent upon the district court to engage with the merits of Plaintiffs' claims. The Court also ordered the district court to enter a preliminary injunction enjoining the enforcement of certain sections of the law. View "Puertorriqueno v. Fortuno" on Justia Law

In this appeal, the Court of Appeals considered whether a written letter from the assistant commissioner of the fire department of the city of New York to Petitioner firefighter advising him that he violated the department's code of conduct and equal employment (EEO) policy may be made part of Petitioner's permanent EEO file without affording him an opportunity for a hearing. The supreme court annulled the department's determination that Petitioner made racially offensive remarks and expunged the letter from Petitioner's EEO file. The appellate division affirmed, concluding that the department did not comport with the requirements of due process. The Court of Appeals affirmed, holding that the department denied Petitioner his right to due process by placing the letter in his file without conducting a hearing, and thus the letter was properly expunged from Petitioner's permanent EEO file. View "D'Angelo v. Scoppetta" on Justia Law

Plaintiff sued defendant under 42 U.S.C. 1983, alleging that her termination was unconstitutional under the First Amendment because it was based on her candidacy. The court held that the First Amendment, as interpreted by the Supreme Court and the Eleventh Circuit, did not require defendant to retain her political opponent after becoming superior court clerk for the county. Accordingly, the court affirmed the district court's grant of summary judgment in favor of defendant. View "Underwood v. Harkins, et al" on Justia Law

Plaintiff filed suit against her employer, alleging discrimination and retaliation claims under 42 U.S.C. 1983; the Arkansas Equal Pay Act, Ark. Code. Ann. 11-4-601; and the Arkansas Civil Rights Act (ACRA), Ark. Code. Ann. 16-123-101 et seq. On appeal, plaintiff challenged the district court's grant of summary judgment dismissing all claims. The court affirmed the judgment, concluding that no reasonable factfinder could find that any defendant was guilty of intentional, gender-based wage discrimination when plaintiff's initial salary as a new zoning official was established in November 2006; plaintiff's failure-to-hire claim failed based on undisputed evidence supporting defendants' nondiscriminatory reason for hiring another candidate based on more experience and better qualifications and because plaintiff failed to demonstrate pretext; and plaintiff's remaining claims also failed. View "Hill v. City of Pine Bluff, et al" on Justia Law

This case required the Supreme Court to determine whether a state employee, after receiving notice of her employer's intent to dismiss her, waived her right to a pre-termination hearing by repeatedly engaging in conduct that delayed the hearing. The Kentucky Personnel Board concluded that the employee did not waive her right to a pre-termination hearing, and that her dismissal therefore violated her right to due process. The circuit court and court of appeals affirmed. The Supreme Court reversed, holding that the employee was not deprived of her constitutional rights to notice and an opportunity to be heard prior to her dismissal, as the employee constitutionally waived her right to a hearing by applying for FMLA leave in a deliberate attempt to delay the pre-termination hearing, after previously postponing the hearing twice, which constituted a knowing, intelligent, and voluntary waiver of that hearing. View "Dep't of Revenue v. Wade" on Justia Law

Following her resignation as a dental assistant in the dental office of Appellee, Appellant sued Appellee for sexual harassment and outrage. On remand, the circuit court granted Appellee's motion for partial summary judgment, concluding that Appellant's state-law claim for sexual harassment failed because the material facts established that Appellee did not have enough employees for a cause of action to exist against him pursuant to the Arkansas Civil Rights Act (ACRA). On interlocutory appeal, Appellant claimed the numerosity requirement of the ACRA violated the state and federal Constitutions. The Supreme Court dismissed without prejudice Appellant's appeal, holding that the circuit court's order was not final and appealable because it did not satisfy the requirements of Ark. R. Civ. P. 54(b). View "Pepper v. Garrett" on Justia Law