Justia Civil Rights Opinion Summaries

Coleman was fired from the Cook County Juvenile Temporary Detention Center. Coleman was told that his position had been eliminated by budget cuts; he contends that his politics were the real cause for his discharge and a decision not to rehire him. Coleman’s job is not in the category for which politics is a legitimate consideration. Coleman sought damages under 42 U.S.C. 1983 and invoked the Shakman consent decrees, which allow parties aggrieved by certain Cook County patronage to bring civil contempt proceedings. The district judge dismissed the civil rights claim but declined to dismiss the Shakman claim. The Seventh Circuit affirmed. Dunlap is not protected by absolute immunity pursuant to the order under which he was appointed. In 2002 the Juvenile Detention Center and inmates settled a case; the court retained jurisdiction and in 2007 appointed Dunlap as administrator in an order, stating that Dunlap would have immunity: “[Dunlap] and his staff shall have the status of officers and agents of this Court and as such shall be vested with the same immunities as vest with this Court.” Dunlap’s decisions were administrative, not judicial. The order did not direct adoption of any particular personnel plan nor direct specific employment decisions.

Tim Clausnitzer appealed the grant of summary judgment that dismissed his lawsuit against Tesoro Refinery and Marketing Company alleging lawful-activity discrimination under the North Dakota Human Rights Act, N.D.C.C. ch. 14-02.4. Upon review of the matter, the Supreme Court affirmed, concluding Clausnitzer failed to make a prima facie showing that he was a member of a protected class under the Act when Tesoro terminated his employment.

While Daugherty worked as a manager in the city’s Department of Public Utilities from January 2006 to March 2007, he complained that he was underpaid and that he was paid less than white managers. His annual salary was $48,500, his white predecessor had earned $56,000, and his white subordinate earned $49,000. In 2006, Daugherty assisted two black DPU employees with discrimination complaints against the City of Toledo and individuals. Daugherty claims he was evaluated more harshly than white employees and that, despite his position as second-in-command in his division, was not placed in charge when the supervisor was absent. He also claimed derogatory remarks by one individual. Daugherty was terminated and filed suit under state law and Title VII, 42 U.S.C. 2000e. The district court entered summary judgment for defendants. The Sixth Circuit reversed. The district court required Daugherty to present more evidence than required under the McDonnell-Douglas framework and failed to adequately analyze evidence of discriminatory comments by the mayor. On remand, the court should also conduct a hostile-work environment analysis. The court erred in excluding testimony regarding other acts of alleged retaliation by the city, basing its decision solely on whether the same person made each termination decision.

Plaintiff appealed the district court's grant of summary judgment in a class action suit alleging that Broward County's employee wellness program violated the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq. Plaintiff alleged that the wellness program's biometric screening and online Health Risk Assessment questionnaire violated the ADA's prohibition on non-voluntary medical examinations and disability-related inquiries. The court held that the district court did not err in finding as a matter of law that the wellness program was a "term" of Broward County's group health insurance plan, such that the wellness program fell within the ADA's safe harbor provision.

Levin worked as an Illinois Assistant Attorney General from 2000, until his termination in 2006. Levin was over the age of 60 at the time of his termination and believes he was fired because of his age and gender. He was replaced by a woman in her 30s. He brought claims under the Age Discrimination in Employment Act, 29 U.S.C. 621, Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e, and the Equal Protection Clause of the Fourteenth Amendment via 42 U.S.C. 1983. The district court denied a motion to dismiss the individual-capacity defendants on grounds of qualified immunity with respect to Levin’s section 1983 age discrimination claim. The Seventh Circuit affirmed. At the time of the alleged wrongdoing, it was clearly established that age discrimination in employment violates the Equal Protection Clause. Although age is not a suspect classification, states may not discriminate on that basis if such discrimination is not “rationally related to a legitimate state interest.” Whether the ADEA is the exclusive remedy for plaintiffs suffering age discrimination in employment is irrelevant; a constitutional right was clearly established.

The Missouri Department of Corrections appealed the trial court's judgment in favor of Respondent on her claim of disability discrimination under the Missouri Human Rights Act (MHRA). On appeal, the Department claimed the trial court erred in overruling its objection to Respondent's verdict director because it did not include an essential element of her discrimination claim and erred in calculating punitive damages under Mo. Rev. Stat. 510.265. The Supreme Court reversed because the verdict-directing instruction did not require the jury to find that Respondent was disabled, an essential element of her MHRA claim. The Court also held that the trial court's calculation of punitive damages was the correct application of section 510.265.

After the State Department terminated the employment of Appellant on his sixty-fifth birthday, Appellant brought suit alleging that his forced retirement violated the federal employment provisions of the Age Discrimination in Employment Act (ADEA). The district court dismissed Appellant's complaint on the ground that the statute under which Appellant was hired, section 2(c) of the Basic Authorities Act, permitted the Department to exempt Appellant from the protections of the ADEA. The D.C. Circuit Court of Appeals reversed, finding nothing in the Basic Authorities Act that abrogates the ADEA's broad proscription against personnel actions that discriminate on the basis of age.

Four days after Plaintiff, a detective in the City of Burbank Police Department, disclosed the alleged use of abusive interrogation tactics by his colleagues to the Los Angeles Sheriff's Department, he was placed on administrative leave by the chief of police. Plaintiff filed a 42 U.S.C. 1983 suit against the chief of police and others in the Burbank Police Department, alleging that his placement on administrative leave was unconstitutional retaliation for the exercise of his First Amendment rights. The district court dismissed the suit, concluding that the Ninth Circuit Court of Appeals' decision in Huppert v. City of Pittsburg controlled Plaintiff's case. The Ninth Circuit affirmed, holding that the district court correctly found that, under Huppert, Plaintiff's disclosure to the Los Angeles Sheriff's Department was made in the course of his official duties, and thus fell outside the protection offered by the First Amendment.

Petitioner Lisa McBride was an accountant who worked as Respondent Peak Wellness Center’s business manager for about nine years. Peak terminated her in 2009, citing job performance and morale issues. Petitioner claimed she was terminated in retaliation for bringing various accounting improprieties to the attention of Peak’s Board of Directors. Petitioner brought several federal and state-law claims against Peak: (1) whistleblower retaliation under the federal False Claims Act (FCA); (2) violations of the federal Fair Labor Standards Act (FLSA); (3) breach of employment contract; (4) breach of implied covenant of good faith and fair dealing; (5) defamation; and (6) a federal sex discrimination claim under Title VII of the Civil Rights Act. After discovery, Peak moved for summary judgment on all claims, and the district court granted the motion. Petitioner appealed, arguing that significant issues of material fact remained unresolved and that her claims should have proceeded to trial. She also appealed district court’s denial of an evidentiary motion. Finding no error in the district court’s decision, the Tenth Circuit affirmed its grant of summary judgment in favor of Peak.

Plaintiff sued the County of Dakota, Nebraska, and former sheriff's deputy Rodney Herron, alleging Title VII violations, sexual harassment, and violation of the Equal Pay Act. The County advanced a limited offer to settle the Title VII and Equal Pay Act claims, which Plaintiff accepted. Plaintiff then sought an award of attorney's fees on the partial judgment, and the district court ultimately awarded $24,500 in attorney's fees to Williams in two separate orders. The district court certified its orders as final judgments under Fed. R. Civ. P. 54(b) so as to allow for an interlocutory appeal. Defendants appealed. The Eighth Circuit Court of Appeals dismissed the appeal for lack of jurisdiction, holding that the district court abused its discretion by entering final judgment under Rule 54(b).