Justia Civil Rights Opinion Summaries

The Washington State Criminal Justice Training Commission (“CJTC”), the City of Spokane, and others (collectively, the “CJTC Defendants”) moved for summary judgment in the district court on Plaintiff’s state law claims, asserting that they are entitled to statutory immunity under Wash. Rev. Code (“RCW”) 43.101.390(1). The district court denied summary judgment, and the CJTC Defendants appealed.   The Ninth Circuit certified to the Washington Supreme Court the following question: What is the scope of immunity provided by RCW 43.101.390? Specifically, does the provision grant immunity for intentional torts committed in the course of administering the Basic Law Enforcement Academy? View "JOHN CRUZ V. CITY OF SPOKANE, ET AL" on Justia Law

Moore is a male Examination Manager at the SEC's Washington, D.C. headquarters. Two women Examination Managers in that office perform the same work as Moore under similar working conditions. In 2014, the SEC initiated a Pay Transition Program to recalibrate its employees’ pay so that they could receive credit for years of relevant work experience regardless of their SEC hire date. The Program was open to all SEC employees from September 14-October 14, 2014. The women applied for the Program during this open period. Moore did not, due to family-related issues occupying his attention. The SEC permitted 10 other employees with extenuating circumstances to apply for the Program in November-December 2014. Program pay adjustments began taking effect around June 2015; the women’s salaries were increased. In August-September 2016, Moore unsuccessfully tried to apply for the Program.Moore's Equal Pay Act, 29 U.S.C. 206(d), lawsuit argues that the SEC lacks justification for any Program-related pay differential between him and the women because the application process was unnecessary, given that the SEC always had the necessary information in its records and the SEC had no valid basis for creating, or not extending, an application deadline. The Federal Circuit vacated the dismissal of Moore’s complaint, first overruling its own 2009 decision, Yant, which added an element to the prima facie case–a showing that the pay differential “is either historically or presently based on sex.” The court remanded for consideration on non-Yant grounds. View "Moore v. United States" on Justia Law

Plaintiff alleged that he was denied a bathroom break by his supervisor at a Dallas, Texas, warehouse until he was forced to defecate on himself at his workstation. Plaintiff sued his employer, UPS, for negligent supervision, invasion of privacy, and intentional infliction of emotional distress (IIED). The district court dismissed the first two claims under Fed. R. Civ. P. 12(b)(6) and granted UPS’s motion for summary judgment on the third. Plaintiff appealed.   The Fifth Circuit affirmed in part and reversed in part. The court explained that the district court correctly held that Plaintiff has not met the standard for IIED claims. However, it erred in concluding that Plaintiff’s negligent supervision claim was preempted by federal law. Further, the court wrote that based on its Erie guess, the court also disagreed with the district court’s conclusion that the alleged facts do not constitute an invasion of privacy. The court concluded that the invasion of privacy tort covers the alleged facts. In recent years, there have been troubling reports of industry practices that deny employees adequate bathroom breaks. It is important to clarify that such actions, or similar examples of public humiliation by an exhibition of intimate personal details or actions, are not immune from liability. View "Amin v. United Parcel Service" on Justia Law

After the Acting General Counsel of the National Labor Relations Board withdrew an unfair labor practice complaint that his predecessor had issued against a union, the aggrieved employer requested permission to appeal the complaint’s withdrawal to the Board. The Board denied the request, concluding that the Acting General Counsel’s decision was an unreviewable act of prosecutorial discretion. The employer then petitioned the Fifth Circuit for review of the Board’s order.   The Fifth Circuit denied the petition. The court concluded that it has jurisdiction over the petition for review, that Acting General Counsel’s designation was valid and that the Board permissibly determined that Acting General Counsel had discretion to withdraw the complaint against the Unions. The court explained that the Board’s own conclusion that the General Counsel has the discretion to withdraw unfair labor practice complaints in cases where a motion for summary judgment has been filed but no hearing has occurred, and the Board has neither issued a Notice to Show Cause nor transferred the case to itself fits squarely within the holding of UFCW. As such, it is a permissible interpretation of the National Labor Relations Act (“NLRA”) View "United Natural Foods v. NLRB" on Justia Law

People working part-time may qualify for weekly unemployment benefits, but must accurately report their income so the Indiana Department of Workforce Development can reduce their benefits accordingly. A claimant who knowingly fails to disclose earnings on a weekly application must repay all benefits received for that week and is subject to a civil penalty of 25% of that forfeited amount. Grashoff omitted her part-time income on 24 weekly applications. The Department determined that she knowingly violated the law and assessed a forfeiture and penalty totaling $11,190. An ALJ affirmed the sanction. Grashoff did not seek state judicial review but filed suit under 42 U.S.C. 1983 alleging that the sanction violates the Eighth Amendment’s Excessive Fines Clause. The district court rejected the claim, classifying the entire forfeiture as remedial rather than punitive. The penalty is a punitive sanction subject to Eighth Amendment scrutiny but is not grossly disproportionate to the seriousness of the offense.The Seventh Circuit affirmed. Grashoff conceded that the difference between the benefits she received and the smaller amount she would have received had she reported her income is purely remedial. The remaining forfeiture amount, even when considered together with the 25% penalty, is not a grossly disproportionate sanction for Grashoff’s knowing violations of the law. View "Grashoff v. Payne" on Justia Law

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