Justia Civil Rights Opinion Summaries

Plaintiff brought suit under 42 U.S.C. 1983 against the County of Dakota, Nebraska, and former county official Rodney Herron. Plaintiff alleged defendants committed gender discrimination in violation of her Fourteenth Amendment rights. Herron appealed the district court's denial of summary judgment, asserting that he was entitled to qualified immunity. The Eighth Circuit Court of Appeals affirmed, holding (1) Plaintiff met her burden to show that Herron violated her Fourteenth Amendment right to be free from gender discrimination; (2) the right Herron violated was clearly established; and (3) because Plaintiff satisfied both prongs of the qualified-immunity analysis, the district court correctly found that Herron was not entitled to qualified immunity.

Toni Duncan sued her former employer, Dakota County, Nebraska, under 42 U.S.C. 1983 for hostile-work-environment sexual harassment and constructive discharge in violation of the Equal Protection Clause of the Fourteenth Amendment. Duncan also sued Sheriff James Wagner and her supervisor, Chief Deputy Rodney Herron, in their individual capacities. The district court (1) granted summary judgment to Wagner; and (2) denied the motions for summary judgment by the County and Herron on the basis of qualified immunity. The Eighth Circuit Court of Appeals reversed in part, holding that Herron was entitled to qualified immunity on Duncan's claim, as Herron did not violate Duncan's right to equal protection. Remanded.

Plaintiff sued her former employer, Dakota County, Nebraska under 42 U.S.C. 1983 and 1985. She also sued a sheriff, chief deputy, and sergeant, claiming the chief deputy and sheriff created or fostered a sexually hostile work environment, and the chief deputy and sergeant conspired to deprive her of her civil rights. The defendants moved for summary judgment based on qualified immunity, which the district court denied. The Eighth Circuit Court of Appeals (1) affirmed the denial of summary judgment to the chief deputy, holding that Plaintiff sufficiently showed the five elements of a hostile-work-environment sexual harassment claim and that the right the chief deputy violated was clearly established; (2) reversed the denial of summary judgment as to the sheriff and sergeant on Plaintiff's claim that they conspired to violate her constitutional rights, as Plaintiff failed to demonstrate the existence of a conspiracy; and (3) reversed the denial of summary judgment as to the sheriff on Plaintiff's sexually hostile work environment claim, as the sheriff's conduct was not sufficiently severe to create a sexually hostile work environment.

In 1996, Cordero began working as an agent in the Internal Revenue Division of the Puerto Rico Treasury Department. Her supervisor, Rodríguez, was brother of the mayor of Mayagüez, who was head of the Popular Democratic Party's city office. Politically, Cordero affiliates with the New Progressive Party. Cordero says that on many occasions Rodríguez made disparaging comments about the NPP within her earshot. She also claims that Rodríguez took many subtle steps to inconvenience her, such as repeatedly changing her schedule and falsely claiming that she left early so he could deduct ten minutes of pay from her check. She also claims that Rodríguez "physically and verbally assaulted" her and that there were several other incidents, including incidents after she received a transfer. The district court rejected her suit under 42 U.S.C. 1983. The First Circuit affirmed, finding the allegations “troubling” but untimely. Although the continuing violation doctrine can render otherwise time-barred conduct actionable, the doctrine still requires some anchoring violation within the limitations period, and none of Rodríguez's post-transfer conduct meets that test. Cordero's transfer occurred more than a year before she filed suit, and none of Rodríguez's conduct within that one-year limitations period was actionable.

Mischelle Richter appealed (1) the district court's order dismissing her retaliation claims under Title VII and the Missouri Human Rights Act for failure to exhaust administrative remedies, and (2) the dismissal of her wrongful discharge claim under Missouri law for failure to state a claim upon which relief may be granted. The Eighth Circuit Court of Appeals (1) affirmed the district court's dismissal of the retaliation claims, holding that Richter did not properly exhaust her retaliation claims; but (2) reversed and remanded on the state-law wrongful discharge claim, holding that Richter alleged sufficient facts to state a wrongful discharge claim under Missouri law.

Kathleen Marez sued her former employer, Saint-Gobain Containers, Inc. for unlawful termination. Marez claimed that Saint-Gobain retaliated against her in violation of the family Medical Leave Act (FMLA) and that Saint-Gobain committed gender discrimination in violation of the Missouri Human Rights Act (MHRA). A jury returned a verdict in Marez's favor on the FMLA claim and in Saint-Gobain's favor on the gender discrimination claim. The district court awarded Marez liquidated damages and part of her requested attorneys' fees. The Eighth Circuit Court of Appeals affirmed, holding (1) there was sufficient evidence to support the jury's verdict in Marez's favor; (2) the district court did not abuse its discretion in awarding liquidated damages, as Saint-Gobain was liable for employment discrimination under the cat's-paw theory of liability, and liquidated damages may be awarded in eligible FMLA cases premised on cat's-paw liability; and (3) the district court did not abuse its discretion in its award of attorneys' fees.

Plaintiff, a former employee of the Equal Employment Opportunity Commission (EEOC) who suffered from multiple sclerosis and systemic lupus, filed an administrative complaint based on alleged violations of the Rehabilitation Act of 1973. The complaint was adjudicated by an ALJ, who denied relief in part. Plaintiff then filed an optional administrative appeal with the EEOC. Plaintiff withdrew her appeal without waiting 180 days as specified in 29 C.F.R. 1614.407(d) and filed suit in district court based on the same claims she asserted in her administrative complaint. The district court dismissed Plaintiff's complaint for failure to exhaust administrative remedies, holding that under Rivera v. USPS, it lacked jurisdiction because Plaintiff had not waited 180 days after filing her administrative appeal. The Ninth Circuit Court of Appeals reversed, holding that based on Bankston v. White and on post-Rivera regulation, Bullock had exhausted her administrative remedies. Remanded.

Appellant appealed the district court's grant of summary judgment in favor of her employer, G4S Youth Services, LLC, and her supervisor, Todd Speight (Appellees), on Appellant's claims that they terminated her employment based on her race, age, and use of family medical leave. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant did not create a genuine issue of material fact as to whether G4S's legitimate, non-discriminatory reason for terminating her employment was merely a pretext for intentional race of age discrimination, the district court did not err in granting summary judgment in favor of Appellees on Appellant's race and age discrimination claims; and (2) because Appellant failed to raise a genuine issue of fact as to whether G4S retaliated against her for exercising her FMLA rights, the district court did not err in granting summary judgment on Appellant's Family and Medical Leave Act claims.

African-American firefighters brought a Title VII discrimination (42 U.S.C. 2000e) claim, based on 1998 and 2002 promotional examinations for the position of fire lieutenant. The district court ruled in favor of the city, finding that Buffalo had demonstrated that the test was job related and consistent with business necessity, despite the disparate impact of the 1998 examination on African Americans, and that plaintiffs were barred from challenging the job relatedness and business necessity of similarly derived examinations. The Second Circuit affirmed: an employer can show that examinations having a disparate impact on a protected class are job related and supported by business necessity when the analysis that produced the test relied on data not specific to that employer. While employer-specific data may make it easier for an employer to carry its burden in Title VII analysis, such evidence is not required as a matter of law. In this case, an independent state agency determined, based on empirical, expert, and anecdotal evidence drawn from fire departments across New York and the nation, that the job of fire lieutenant, wherever performed, involves common tasks requiring essentially the same skills, knowledge, abilities, and personal characteristics; and developed a general test based on those findings.

The State of Alaska dismissed an employee for allegedly submitting a falsified timesheet and claiming full pay for a week when she was not working. The employee argued her dismissal violated the implied covenant of good faith and fair dealing because a biased supervisor was involved with the termination decision, because the State's investigation was conducted unfairly, and because she was treated differently from similarly situated employees. Upon review, the Supreme Court affirmed the superior court's decision that there was insufficient evidence to show a breach of the implied covenant on any of these grounds. The Court also affirmed the superior court's ruling that the employee's unfair labor practice claim was untimely and therefore waived.