Justia Civil Rights Opinion Summaries

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

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims against Defendants for wrongful termination, workplace harassment, and age discrimination, holding that the district court properly granted summary judgment on all claims.Plaintiff, an at-will employee, was promptly fired after he texted his plant manager "FUCK You!" and "Believe who and what you want" following the manager's criticism of his job performance. In response to Plaintiff's complaint, Defendants moved for summary judgment on the grounds that Plaintiff was lawfully fired for insubordination. The district court granted summary judgment in favor of Defendants. The Supreme Court modified the McDonnell-Douglas burden-shifting framework for summary judgment on discrimination claims under the Iowa Civil Rights Act to align with the causation standard at trial and adopted and applied the good-faith "honest believe rule" to affirm Defendant's decision to terminate Plaintiff's employment for insubordination. View "Feeback v. Swift Pork Co." on Justia Law

After the EEOC closed its investigation into Plaintiff’s charge of discrimination, the agency issued Plaintiff a right-to-sue notice. This notice, however, only reached Plaintiff’s attorney and not Plaintiff himself. The EEOC then sent a subsequent notice acknowledging that the first had not reached Plaintiff and advising him that his 90-day window in which to file suit began to run upon its—the second notice’s—receipt. Plaintiff filed his complaint 141 days after his attorney is presumed to have received the first notice and 89 days after Plaintiff and his attorney received the second. The district court dismissed Plaintiff’s suit as untimely and held that equitable tolling was unavailable.   The Fifth Circuit vacated the district court’s order dismissing Plaintiff’s complaint. The court explained that Plaintiff’s case did not present the kind of exceptional circumstances that may warrant equitable tolling; the district court failed to consider controlling precedent from this court that tolling may be available when the EEOC affirmatively misleads a claimant about the time in which he must file his federal complaint. The court wrote that this was an abuse of discretion. Further, the court found that the district court did not proceed beyond this first prong of the tolling analysis the record at this motion to dismiss stage does not disclose whether Plaintiff diligently pursued his rights. View "Bernstein v. Maximus Federal Services" on Justia Law

The First Circuit affirmed the order of the district court granting Defendant's motion for summary judgment and dismissing Plaintiff's action alleging gender discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. and other claims under Puerto Rico law, holding that Defendant was not entitled to relief on her assignments of error.Plaintiff sued Defendant after she was not selected for promotion and her employment was terminated. The district court dismissed Plaintiff's claims on summary judgment, finding that Plaintiff failed to show that Defendant's decisions relating to Plaintiff's employment were motivated by discriminatory animus. The First Circuit affirmed, holding that summary judgment was proper as to all of Plaintiff's claims. View "Lopez-Hernandez v. Terumo Puerto Rico LLC" on Justia Law

Plaintiff, a federal inmate, sued Federal Bureau of Prisons (BOP) staff alleging, inter alia, discrimination and retaliation under the Rehabilitation Act. The district court dismissed the action for failure to exhaust available administrative remedies. According to the court, the Prison Litigation Reform Act (PLRA) required Plaintiff to exhaust both the BOP’s Administrative Remedy Program and an additional remedy, particular to prison discrimination claims, administered by the Department of Justice’s Director of Equal Employment Opportunity. Plaintiff appealed, arguing that he was only required to exhaust the BOP’s Administrative Remedy Program under the Prison Litigation Reform Act. Plaintiff asserted in the alternative that the Department of Justice remedies were not “available” to him.   The Fourth Circuit affirmed. The court explained that the PLRA’s exhaustion provision is plain. It requires prisoners to utilize all “available” administrative remedies. For Rehabilitation Act claimants, these remedies include both the BOP’s ARP and a separate EEO process administered by the DOJ. Here, Plaintiff failed to exhaust these remedies despite them being “available” to him under the PLRA. Accordingly, the court affirmed the district court’s dismissal of Plaintiff’s complaint without prejudice to his ability to exhaust the EEO remedies “available” to him within the meaning of the PLRA. View "Webster Williams, III v. Michael Carvajal" on Justia Law

Plaintiff began working for McDonnell Douglas in 1985. He stayed there until it merged with The Boeing Company (Boeing) in 1997. In 2017 and 2018, Plaintiff unsuccessfully applied for promotions within Boeing. Both times, the promotion was given to younger candidates who scored better in the interview. In 2017, the promotion went to an employee aged 33; in 2018, to one aged 34. Plaintiff alleged that Boeing discriminated against him on the basis of age, in violation of the Missouri Human Rights Act (MHRA). Plaintiff brought two separate lawsuits, now consolidated, alleging age discrimination in relation to the 2018 opening and a claim for constructive discharge.  The district court granted summary judgment in favor of Boeing on both claims, holding that Plaintiff (1) failed to demonstrate a material dispute as to whether Boeing’s stated rationale for the hiring decision was a mere pretext for age discrimination and (2) failed to timely file a complaint with the Missouri Commission on Human Rights within six months of when his constructive-discharge claim accrued.   The Eighth Circuit affirmed. The court concluded that Plaintiff failed to rebut the non-age-based, legitimate reasons offered by Boeing for its choice to hire the other applicant instead of him. Further, Plaintiff alleged that his termination paperwork started the clock, not his email. The court explained that Plaintiff gave his employer a little more than five weeks’ notice. But his claim still accrued then—on the day he gave notice, not the day he filed the paperwork. Because May 28, 2020, falls 185 days after November 25, 2019, Plaintiff’s complaint was untimely and thus barred. View "Jeff Bonomo v. The Boeing Company" on Justia Law