Justia Civil Rights Opinion Summaries

Plaintiff signed a one-year contract to teach criminal justice courses at Spartanburg Methodist College (SMC). Less than a year later, SMC decided not to renew Plaintiff’s contract and terminated her shortly thereafter. Plaintiff brought a mix of state and federal law claims against SMC, essentially arguing that her contract nonrenewal and termination were unlawful. The district court granted summary judgment in favor of SMC on all federal claims and declined to exercise supplemental jurisdiction over the state law claims. Plaintiff appealed. Under the Americans with Disabilities Act (ADA), Plaintiff accused SMC of discrimination, retaliation, and engaging in an unlawful health inquiry. Under Title IX of the Education Amendments Act of 1972 (Title IX), she accused SMC of retaliation.   The Fourth Circuit affirmed. The court explained that in analyzing the case, it becomes clear that Plaintiff’s retaliation claims cannot succeed. SMC offers nonretaliatory reasons for not renewing Plaintiff’s contract and terminating her employment, and she is unable to demonstrate that SMC’s reasons are pretextual. Further, the court explained that Plaintiff’s claim of pretext is undermined by the fact that the primary decision-makers at SMC were not aware of Plaintiff’s ADA or Title IX-protected activity. Second, any notion of pretext is further dispelled by the fact that SMC’s explanations have been consistent throughout. Moreover, the court explained that Plaintiff cannot show that SMC refused to make an accommodation because she cannot show that she ever properly requested one. Her failure-to-accommodate claim fails for this reason. View "Summer Lashley v. Spartanburg Methodist College" on Justia Law

Plaintiff brought a wrongful-termination action against her former employer—the North Carolina Department of Justice—and two former supervisors in their official and individual capacities. The district court dismissed some claims as barred by sovereign immunity and dismissed the entirety of the complaint as time-barred.   The Fourth Circuit affirmed the uncontested dismissal of the North Carolina Department of Justice and the uncontested dismissal of the official-capacity claims against the individual Defendants for money damages. But because the statute of limitations for the remaining claims is four years and not three years as the district court found, the court explained it must otherwise vacate the district court’s grant of Defendants’ motion to dismiss the individual Defendants from the action.   The court explained that here, Plaintiff brought a Section 1983 action for wrongful termination in violation of Section 1981. A wrongful termination claim is based on post-contract-formation conduct. The court reasoned that as Defendants correctly recognized at oral argument, it would not have been possible for Plaintiff to bring this action prior to December 1, 1990, because, before that date, Section 1981 was limited to discrimination in contract formation and enforcement. In 1991, Congress expanded Section 1981 to include discrimination post-contract formation. Therefore, the 1991 amendment to Section 1981 “made possible” this Section 1983 action, and the four-year catchall statute of limitations provided by Section 1658 applies. View "Margaret Chambers v. North Carolina Department of Justice" on Justia Law

Plaintiff was dismissed from the Univeristy of Virginia's doctoral program after receiving poor grades. Plaintiff sued, alleging national origin discrimination and retaliation based on interactions with his immediate supervisor. The district court granted the school's motion to dismiss and Plaintiff appealed.The Fourth Circuit affirmed, finding that although his supervisor made derogatory comments about Plaintiff's national origin, they were not made in close proximity to the school's decision to dismiss Plaintiff. The supervisor made a "handful" of comments over the course of four years, none of which were close in time to the Plaintiff receiving poor grades or being dismissed from the program. View "Andreas Alberti v. Rector and Visitors of the University of Virginia" on Justia Law

Plaintiff appealed from the district court’s judgment dismissing all claims against Defendants-Newburgh Enlarged City School District, Superintendent, and Assistant Superintendent. Plaintiff, an African American woman of West Indian descent who served as principal of South Middle School, asserts claims of discrimination under Title VII of the Civil Rights Act of 1964 and the Equal Protection Clause of the Fourteenth Amendment.   The Second Circuit affirmed the district court’s dismissal of the Title VII claim to the extent the claim is based on alleged adverse employment actions in May 2019 and vacated the district court’s judgment to the extent it dismissed the Section 1983 claim and the remainder of the Title VII claim. The court remanded the case to the district court for further proceedings, including a determination as to whether Plaintiff should be provided with an extension of time to effectuate proper service as to the Superintendent and Assistant Superintendent. The court explained that taking the allegations in the FAC as true and drawing all reasonable inferences in Plaintiff’s favor, the FAC meets that pleading standard with respect to the denial of the position for RISE administrator, the denial of her application to administer the summer-school program, and the termination of her position as SMS principal. Accordingly, the court explained that Plaintiff has stated plausible discrimination claims under Title VII and Section 1983, and the district court erred in dismissing them. Therefore, Plaintiff may proceed with her Section 1983 claim as to all three alleged adverse employment actions and with her Title VII claim against the School District. View "Buon v. Spindler, et al." on Justia Law

Dr. Bounds was hired for one year beginning in July 2019 as an at-will employee. In February 2020, Dr. Scott stated that Scott would recommend that Bounds's contract be renewed. Scott notified Bounds and others on March 24 that she would email approved contracts and that they had until March 31 to sign and return the contracts. Upon receiving the contract, Bounds noted that her vacation days had been reduced. Scott told Bounds to contact the Board. Later that day, Bounds became ill and was advised to quarantine for 14 days. Bounds testified that she made inquiries to the Board but never received a reply. On April 1, Scott telephoned Bounds, who had not returned the signed contract. Bounds replied that she wanted her attorney to review the agreement. Scott warned that the Board previously had released another administrator who did not sign her contract by the deadline. The following day, Scott advised Bounds that the Board had requested that her position be posted as vacant. On April 14, Bounds was notified that her position had been posted.Bounds filed suit, 42 U.S.C. 1983, contending that the Board had deprived her of procedural due process by rescinding her contract and posting her position without notice or the opportunity to be heard. The Seventh Circuit affirmed summary judgment in favor of the defendants. Bounds did not have a property interest subject to due process protections. Bounds had no enforceable expectation as to her continued employment. View "Bounds v. Country Club Hills School District 160" on Justia Law

In 2015, Levine, an African-American woman, applied for the position of supervisor of customer services at the main post office in Grand Rapids, Michigan. Levine had then worked for USPS for over 27 years, in a variety of positions. USPS did not select Levine for the position. Instead, it hired a white employee, Peare, whom Levine alleges was significantly less qualified than Levine. USPS disputes Levine’s allegations that the failure to hire her was racially discriminatory under Title VII, 42 U.S.C. 2000e.The district court granted USPS summary judgment. The Sixth Circuit reversed, noting various factual disputes. Levine met her burden of producing enough evidence to convince a reasonable jury that USPS’s proffered reasons for not promoting her may have been a mere pretext for racial discrimination, so USPS was not entitled to summary judgment. The parties dispute the position’s requirements. Levine possesses three post-secondary degrees and has had seven different awards from USPS. Peare’s formal academic training ended with high school and she had worked for USPS for nearly eight years. Levine provided abundant evidence that she is arguably more qualified for the position than Peare. USPS’s reliance on Peare’s purportedly superior interview warrants similar scrutiny as does USPS’s contention that Peare had more relevant experience than Levine. View "Levine v. DeJoy" on Justia Law

Brownsburg Community School Corporation requires its high school teachers to call all students by the names registered in the school’s official student database. Kluge, a teacher, objected on religious grounds to using the first names of transgender students to the extent that he deemed those names not consistent with their sex recorded at birth. After Brownsburg initially accommodated Kluge’s request to call all students by their last names only, the school withdrew the accommodation when it became apparent that the practice was harming students and negatively impacting the learning environment for transgender students, other students in Kluge’s classes and in the school generally, and the faculty.Kluge brought a Title VII religious discrimination and retaliation suit after he was terminated from his employment. The district court granted the school summary judgment, concluding that the school was unable to accommodate Kluge’s religious beliefs and practices without imposing an undue hardship on the school’s conduct of its business of educating all students and rejected Kluge’s retaliation claim.The Seventh Circuit affirmed. The undisputed evidence demonstrates that Kluge’s accommodation harmed students and disrupted the learning environment. No reasonable jury could conclude that harm to students and disruption to the learning environment are de minimis harms to a school’s conduct of its business. View "Kluge v. Brownsburg Community School Corp." on Justia Law

Plaintiff a devout Jehovah’s Witness, objected to California’s loyalty oath because she believed it would violate her religious beliefs by requiring her to pledge primary allegiance to the federal and state governments and to affirm her willingness to take up arms to defend them. he Controller’s Office rejected this proposal and rescinded the job offer. Plaintiff sued the Controller’s Office and the California State Controller in her official capacity, alleging violations of Title VII under both failure-to-accommodate and disparate-impact theories. She also asserted a failure-to-accommodate claim against the Controller’s Office under the California Fair Employment and Housing Act (“FEHA”), and she alleged that the refusal by both defendants to accommodate her religious beliefs violated the Free Exercise Clauses of the federal and state constitutions.   THe Ninth Circuit reversed the district court’s dismissal. The panel held that, as currently pleaded, Plaintiff’s alleged injury was redressable only through a claim for damages. The panel held that she lacked the actual and imminent threat of future injury required to have standing to seek prospective relief on any of her claims, but she could attempt to cure this defect by amendment. The panel held that Plaintiff could seek damages from the Controller’s Office on her claims under Title VII. As currently pleaded, she could not obtain damages for her free exercise claim under 42 U.S.C. Section 1983. The panel held, however, that the district court abused its discretion in denying Plaintiff leave to amend to seek damages from the State Controller in her individual capacity. View "BRIANNA BOLDEN-HARDGE V. CALIFORNIA STATE CONTROLLER, ET AL" on Justia Law

The Boilermaker-Blacksmith National Pension Trust Board of Trustees (“Board”) denied Plaintiff’s application for disability pension benefits under a plan governed by the Employee Retirement Income Security Act (“ERISA”). Plaintiff argued the Board’s stated reason for denying his application was unreasonable and the Board violated its fiduciary duties. The district court granted the Board’s motion for summary judgment. Plaintiff appealed.   The Eighth Circuit affirmed. The court concluded that the Board did not breach its fiduciary duty when it did not notify Plaintiff the Notice of Decision he submitted on appeal was insufficient. The initial letter the Board sent to Plaintiff noting the absence of the document clearly stated Plaintiff needed to submit a “Notice of Award.” When the plain language of the Plan and the Board’s other communications are consistent, there is no obvious unfairness to Plaintiff if his claim is denied because he submitted the wrong document. Further, the court found that there is no evidence the Board knew silence would harm Plaintiff because, in the May 2018 phone call, Plaintiff himself asked about how waiting to receive the pension would affect the annuity amount and ultimately requested estimates for retirement at later ages. Moreover, Plaintiff has not identified anything that should have caused the Board to know he misunderstood his rights. Under these circumstances, Plaintiff failed to establish a violation of the duty of loyalty. View "Adam Ruessler v. Boilermaker-Blacksmith National Pension Trust" on Justia Law

The United Auto Workers union (“UAW”) and three pro-union Tesla employees filed multiple charges with the National Labor Relations Board (“NLRB”) alleging unfair labor practices against Tesla. An Administrative Law Judge (“ALJ”) found that Tesla had committed most of the alleged violations, and the NLRB issued an order largely affirming the ALJ. Both Tesla and the UAW filed petitions for review, and the NLRB filed a cross-application to enforce its order. Tesla and the UAW each challenged two of the NLRB’s findings through this appeal.   The Fifth Circuit denied the petitions for review. The court held that the NLRB’s findings were supported by substantial evidence, and it did not abuse its broad remedial discretion in declining to issue a notice-reading remedy. The court explained that the UAW cited no authority mandating a notice reading to remedy repeated violations in the absence of intervening cease-and-desist orders. And, as Tesla emphasizes, the company at most continued to commit violations after having a complaint filed against it, not after being ordered to cease its conduct. Moreover, given the deferential standard of review and the “special respect” given to the NLRB’s choice of remedy in light of its policy expertise and its broad, discretionary remedial powers, the court declined to disturb the NLRB’s order in this regard. View "Tesla v. NLRB" on Justia Law