Justia Civil Rights Opinion Summaries

In this adverse employment action, Plaintiff appealed the district court's award of summary judgment to his former employer ("the Company") on his claims of age discrimination in violation of the Age Discrimination in Employment Act. On appeal, the First Circuit Court of Appeals noted inconsistencies between the Company's stated reasons for dismissal and Plaintiff's performance record at the Company, the lack of credibility that could be ascribed by a jury to certain of the Company's justifications for dismissal, and the fact that in response to arguably similar conduct by Plaintiff's younger replacement, the Company took no disciplinary action. The First Circuit reversed the district court's grant of summary judgment, holding that there was sufficient evidence presented on summary judgment from which a jury could draw the permissible inference that the Company's claimed reasons for terminating Plaintiff were pretextual and that the decision was the result of discriminatory animus. View "Acevedo-Parrilla v. Novartis Ex-Lax, Inc." on Justia Law

Plaintiff filed a complaint against her former employer, Adroscoggin County, alleging gender discrimination, constructive discharge, and retaliation. The superior court granted partial summary judgment in favor of the County dismissing the counts of constructive discharge and gender discrimination. The retaliation claim proceeded to trial, and the jury returned a verdict for the County. Plaintiff subsequently appealed from the partial summary judgment dismissing the constructive discharge claim. The Supreme Court affirmed, holding (1) notwithstanding its application in the labor and discrimination contexts, constructive discharge does not exist as an independent cause of action under Maine statutory or common law; and (2) because Plaintiff did not challenge the summary judgment denying her claim for gender discrimination or the judgment entered on the jury's verdict denying her claim for retaliatory discrimination, nor did Plaintiff allege that the actions giving rise to her alleged constructive discharge from employment were themselves a form of unlawful discrimination under the Maine Human Rights Act, Plaintiff's claim for constructive discharge failed. View "Levesque v. Androscoggin County" on Justia Law

An employee of a church who claimed she was harmed by actions of a church's minister brought numerous claims against the church and the minister. At this point in the proceedings, the case involved her negligent retention, negligent supervision, and Title VII sex discrimination claims against the church. The Court of Appeals, reversing the trial court's grant of partial summary judgment, ruled that these claims were not barred by the First Amendment to the United States Constitution as the trial court had determined. Upon review of the matter, the Supreme Court reversed the Court of Appeals and reinstated the trial court's grant of summary judgment on the negligent retention and supervision claims. "Under the First Amendment, allowing these claims to go forward would violate the First Amendment right of the church to select and supervise its ministers as well as the First Amendment right of a hierarchical religious organization to be free of government involvement in the decisions made by its ecclesiastical tribunals. We remand the Title VII claims for further proceedings." View "Erdman v. Chapel Hill Presbyterian Church" on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and state law, alleging that defendant had retaliated against him after he raised complaints protected by those statutes. The district court granted summary judgment to defendant on the federal law claims and dismissed the state law claims without prejudice. The court concluded that plaintiff failed to make a prima facie case of retaliation under ERISA. Likewise, plaintiff failed to make a prima facie case of retaliation under the FLSA. At any rate, plaintiff failed to show a causal connection between his complaint about holiday meal time and his termination six months later. Accordingly, the court affirmed the judgment. View "Shrable v. Eaton Corp." on Justia Law

After Mark Jones repeatedly failed to pass an examination to receive a license required by his employer of all persons in that position, by a date of which he had many months' notice, he requested for the first time that the date be extended due to his medical condition. When his employer declined, and Jones declined to pursue an open alternate position at lesser pay, his employment ended. He then sued under both federal and state disability laws. The district court entered summary judgment for the employer. The First Circuit Court of Appeals affirmed, bypassing the question of whether Jones met the definition of "disability" and holding that the reasonable accommodation provisions of both statutes did not save his case. View "Jones v. Nationwide Life Ins. Co." on Justia Law

Clay was appointed as public records coordinator for the City of Memphis. The volume of public-record requests increased substantially during an FBI investigation into awards of city contracts. Clay claims that her efforts to comply with requests were thwarted by delays in response from city employees and even delays in requests for office supplies and a place for the public to review documents. Clay was also concerned with the conduct of various other employees, such as not reporting absences, and “issues regarding nepotism and favoritism based upon personal relationships.” Clay repeatedly raised her concerns to various officials. When a new mayor was sworn in, she began to suspect the new city attorney of abuse of policies and sought records concerning employees in that office. Clay’s employment was terminated and she sued, asserting violations of the Tennessee Public Protection Act, common law retaliatory discharge and wrongful termination, tortious interference with at-will employment, breach of the duty of good faith and fair dealing, deprivation of constitutional rights in violation of 42 U.S.C. 1983, and violation of the Tennessee Governmental Tort Liability Act. The district court dismissed. The Sixth Circuit reversed with respect to a First Amendment retaliation claim, but otherwise affirmed. View "Handy-Clay v. City of Memphis, TN" on Justia Law

The issue in this case concerned a procedural requirement that must be satisfied in order to file suit under Title I of the Americans with Disabilities Act of 1990 (ADA). Pursuant to this requirement, a claimant must exhaust administrative remedies and file her Title I suit within ninety days after receiving a right-to-sue notice from the EEOC. The district court, citing this requirement, concluded that Plaintiff's Title I suit, which was filed 144 days after the EEOC sent the notice, was brought too late. To explain the delay, Plaintiff suggested that she did not receive the right-to-sue notice until nineteen days before she filed suit. The district court concluded that there is a presumption of timely receipt of a mailed notice and that Plaintiff did not furnish sufficient record evidence to rebut this presumption. The Supreme Court affirmed but on other grounds, holding that the action was time-barred, as Plaintiff had constructive notice of the ninety-day filing requirement, and yet her suit was commenced well after the expiration of that filing period. View "Loubriel v. Fondo del Seguro del Estado" on Justia Law

This was an appeal from a judgment denying the request of Appellant for a writ of mandamus to compel Appellee, Columbus State Community College, to provide access to its complaint files, litigation files, and certain e-mails, and to award statutory damages and reasonable attorney fees. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant did not establish by the requisite clear and convincing evidence that Columbus State violated Ohio Rev. Code. 149.43 by denying her record requests and that the court of appeals did not err by (1) denying Appellant's request for access to the requested complaint and litigation files, as Appellant's request was overbroad; (2) denying Appellant's request for e-mails based on her claim that Columbus State had violated section 149.43(B)(2) by not initially organizing its records so that work-related e-mails could be retrieved based on sender and recipient status, as section 149.43(B)(2) does not expressly require public offices to maintain e-mail record so they can be retrieved based on sender and recipient status; and (3) determining that Columbus State had complied with section 149.43(B)(2). View "State ex rel. Zidonis v. Columbus State Cmty. Coll." on Justia Law

Plaintiff-Appellant Clarice Sanchez, a long-time secretarial employee of the United States Forest Service, suffered irreversible brain damage after falling at work. As a result of her injury, Sanchez lost the left half of her field of vision. She requested a hardship transfer to Albuquerque where she could better access ongoing medical treatment. After the Forest Service declined to accommodate her request, she brought suit under the Rehabilitation Act. The district court granted summary judgment in favor of the Forest Service, concluding that Plaintiff was not disabled within the meaning of the Act. Upon review, the Tenth Circuit disagreed and held that Plaintiff raised a genuine issue of material fact regarding her disability. On appeal, the Forest Service urged the Court to affirm summary judgment on an alternative ground. However, the Court declined, concluding that transfer accommodations for the purpose of medical treatment or therapy were not unreasonable per se. View "Sanchez v. Vilsack" on Justia Law

At issue in this case was (1) whether a superior court judge erred in ordering the dismissal of an age discrimination complaint filed with the Massachusetts Commission Against Discrimination for lack of subject matter jurisdiction before a final decision had been reached by the commission, and (2) whether the ministerial exception required by the First Amendment prohibits a court or administrative agency from applying Massachusetts' antidiscrimination laws to the decision of a Jewish temple not to rehire a teacher in its Sunday and after-school religious school. The Supreme Court affirmed the dismissal of the complaint, holding (1) the judge erred in deciding whether the ministerial exception barred the discrimination claim before the commission had entered a final decision on the claim; but (2) the dismissal of the complaint was proper because the ministerial exception barred the teacher's claim of discrimination. View "Temple Emanuel of Newton v. Mass. Comm'n Against Discrimination" on Justia Law