Justia Civil Rights Opinion Summaries

Plaintiff appealed the adverse grant of summary judgment on her claim under the Equal Pay Act. The district court granted summary judgment in favor of Daugherty Systems, Inc. (“Daugherty”) on the basis that Plaintiff had failed to establish a prima facie case because almost all her alleged comparators were either paid less than she was or did not perform equal work.   The Eighth Circuit affirmed, holding that the pay disparity was justified by a legitimate factor other than sex. The court explained that Daugherty’s explanation for the pay differential—the differences in skillsets and experience and the desire to incentivize Plaintiff to grow in the position—is sufficient to satisfy its burden of proving the pay differential was based on a factor other than sex. The court wrote that because “no reasonable jury” could find other than in Daugherty’s favor on the affirmative defense, Plaintiff failed to raise a genuine dispute for trial, and Daugherty has shown it is entitled to judgment as a matter of law. View "Tamara O'Reilly v. Daugherty Systems, Inc." on Justia Law

Plaintiff sued Advance Auto Parts, claiming unlawful discrimination under 42 U.S.C. Section 1981, assault, and intentional infliction of emotional distress. The district court granted Advance Auto’s motion for summary judgment.   The Eighth Circuit affirmed. The court reasoned that here, unlike Green v. Dillard’s Inc., there is no genuine dispute whether Advance Auto acted negligently or recklessly under Section 213. As for Section 213(a), Plaintiff does not allege that Advance Auto made improper orders or regulations. It had a written policy prohibiting discrimination based on any protected status; all employees had to read and familiarize themselves with this policy and complete annual training. The court further explained that Advance Auto is not liable under Section 1981 for discrimination based on its employee’s conduct. Plaintiff’s claims for assault and intentional infliction of emotional distress fail under respondeat superior and ratification. View "Nicolas Tashman v. Advance Auto Parts, Inc." on Justia Law

Plaintiff opposed a new collective-bargaining agreement that passed by a 119-vote margin. Plaintiff sued the union for breach of its duty of fair representation and a violation of the Labor-Management Reporting and Disclosure Act. At their core, these claims are about whether the union hoodwinked members into ratifying the new collective-bargaining agreement by concealing what would happen to the 30-and-out benefit. The district court dismissed the Labor-Management Reporting and Disclosure Act claim, denied Plaintiff’s motion for class certification, and granted summary judgment to the union on the fair-representation claim. On appeal, Plaintiff alleged that the union concealed key information, but only nine members said it would have made a difference.   The Eighth Circuit affirmed, holding that Plaintiff failed to provide other evidence that the outcome of the vote would have changed. The court reasoned that the ratification vote was overwhelmingly in favor: 228 to 109, a 119-vote margin. Plaintiff offers only nine members who would have voted “no” if they had known about the elimination of the 30-and-out benefit. Even assuming each would have voted the way he thinks, the agreement still would have passed by a wide margin. The court wrote that no reasonable jury could conclude that the union’s alleged bad-faith conduct was the but-for cause of the union’s ratification of the collective-bargaining agreement. View "Matthew Nagel v. United Food and Com. Workers" on Justia Law

Plaintiff was fired by John Deere & Co.; he sued Deere for failing to accommodate his disability and discriminating against him in violation of the Iowa Civil Rights Act (ICRA). The district court granted summary judgment to Deere. Plaintiff appealed the district court’s judgment on his disability and failure to accommodate claims.   The Eighth Circuit affirmed. The court explained that Plaintiff cannot make a prima facie case for failure to accommodate because he never requested an accommodation at the relevant time. In fact, Deere encouraged Plaintiff to request accommodations and accommodated him before when he asked. And when Plaintiff returned to work in September 2019, he had been cleared of all restrictions. Because Plaintiff has not shown that Deere knew he needed an accommodation on his return to work, his claim fails. Further, the court wrote that Plaintiff has not provided any direct evidence of discrimination that “shows a specific link between the alleged discriminatory animus and the challenged decision, sufficient to support a finding by a reasonable fact finder that an illegitimate criterion actually motivated the adverse employment action.” Finally, the court held that Plaintiff’s suggestion that his actions weren’t serious enough to merit his termination “merely questions the soundness of [Deere’s] judgment, and does not demonstrate pretext for discrimination.” View "Michael Winters v. Deere & Company" on Justia Law

Plaintiff sued her former employers, Rowley Memorial Masonic Home and Rowley Masonic Assisted Living Community, LLC (collectively, Rowley), as well as the Administrator, and Director of Nursing, for age discrimination under the Iowa Civil Rights Act (ICRA) and the Age Discrimination in Employment Act (ADEA). Plaintiff argued that the district court erred by denying her motion to compel and granting summary judgment to Defendants. She also moved to certify a question of law to the Iowa Supreme Court and to supplement the record under seal.   The Eighth Circuit affirmed the district court’s judgment, denied the motion to certify, and granted the motion to supplement. The court held that Plaintiff provided no basis for her speculation that Lemke’s additional answers would yield evidence of age discrimination. In light of the likely minimal relevance of the investigator’s additional answers and the fact that at least some of the information Plaintiff seeks was discoverable from other sources, the court wrote it perceives no abuse of the district court’s discretion and cannot say that its denial of the motion resulted in fundamental unfairness to her. Further, the court held that because Plaintiff cannot create an inference that Defendants’ decisions were motivated by her age, she has failed to make a prima facie case of age discrimination View "Inge Smothers v. Rowley Mem. Masonic Home" on Justia Law

Plaintiff brought claims of age discrimination and retaliation against her former employer, the United States Postal Service (“USPS”). The district court granted summary judgment to USPS on all of Plaintiff’s claims. Plaintiff appealed.   The Fifth Circuit affirmed in part and reversed in part. The court reversed summary judgment on Plaintiff’s age discrimination and retaliation claims arising out of her February 26, 2019 termination from USPS Central Station, as well as her retaliation claim arising out of the May 2019 recission of her job offer at the Metairie USPS station. The court affirmed dismissal of all other claims.   The court concluded, in assessing Plaintiff’s age-discrimination claim, that Plaintiff’s evidence creates a fact issue as to whether USPS’s proffered reason for her termination is pretextual. Specifically, Plaintiff has submitted evidence that her supervisors set her up for failure by obstructing her efforts to succeed at her job, including by hiding her mail, making her clock into street time when she was, in fact, in the office, and denying her the tools necessary for her deliveries. Moreover, Plaintiff has submitted evidence that USPS did not document the performance deficiencies it relies on as the basis for Plaintiff’s termination. And again, the circumstances of the station manager’s “hiring” of Plaintiff render inappropriate the “same actor” inference. A reasonable jury could find, based on this evidence, that USPS’s reason for terminating Plaintiff was pretext for retaliation based on her EEO activity directed against the USPS. View "Allen v. USPS" on Justia Law

On November 22, 2021—the day federal employees were required to be vaccinated—Appellant filed suit in District Court, challenging the mandate’s constitutionality. Characterizing Appellant’s suit as a “workplace dispute involving a covered federal employee,” the District Court found Appellant’s claims were precluded under the CSRA and dismissed the suit for lack of subject matter jurisdiction. On appeal, Appellant insisted that he challenges the vaccine mandate’s constitutionality, as opposed to contesting a workplace dispute under the CSRA. According to his complaint, however, he alleged that the vaccine mandate is unconstitutional—at least in part—because it requires that he obtain the vaccine to avoid adverse employment action.   The DC Circuit affirmed. The court explained that all attempts to characterize his argument as anything but a challenge to adverse employment action fail for jurisdictional purposes because Appellant himself admitted that his standing to challenge the vaccine mandate is rooted in the looming disciplinary action he now faces as a result of his continued noncompliance. In other words, Appellant challenges the vaccine mandate to maintain his employment while continuing to defy the mandate that he views as unlawful. And while his constitutional arguments are relevant to the merits, they do not change the fact that one of Appellant’s interests in this suit is to avoid the impending adverse employment action. Appellant’s claims are not wholly collateral because challenges to adverse employment actions are the type of claims that the MSPB regularly adjudicates. Thus, the court found that should Appellant choose to continue challenging the vaccine mandate, he must do so through the CSRA’s scheme. View "Jason Payne v. Joseph Biden, Jr." on Justia Law

The Equal Employment Opportunity Commission (EEOC) sued Methodist Hospitals of Dallas (Methodist) for allegedly violating the Americans with Disabilities Act (ADA). The EEOC asserts that Methodist’s categorical policy of hiring the most qualified candidate violates the ADA when a qualified disabled employee requests reassignment to a vacant role, even if he or she is not the most qualified applicant. The EEOC also alleged that Methodist failed to reasonably accommodate a disabled employee, who was not reassigned to a vacant position for which she applied. The district court granted Methodist’s motion for summary judgment on both claims. The EEOC appealed, arguing that the Supreme Court’s ruling in US Airways, Inc. v. Barnett requires Methodist to make exceptions to its most-qualified-applicant policy and that the employee was entitled to a reasonable accommodation under the ADA.   The Fifth Circuit vacated the judgment of the district court as to Methodist’s most-qualified-applicant policy and remand for further proceedings consistent with this opinion. The court affirmed the judgment as to the EEOC’s reasonable accommodations claim involving the employee. The court explained that at summary judgment, an employee’s “unilateral withdrawal from the interactive process is fatal to her claim,” so long as the employer “engaged in a good-faith, interactive process with the employee regarding her request for a reasonable accommodation.” Based on the evidence, no reasonable jury could find that Methodist was unwilling to participate in the interactive process. When the employee did not respond to either the August 7th letter or the follow-up letter after her appeal of her termination, she caused the breakdown of the interactive process. Thus, Methodist did not act unlawfully. View "EEOC v. Methodist Hospitals" on Justia Law

Crain, a Black woman, became the Chief of the Environmental Management Service at the VA Center in July 2014, subject to a year-long supervisory probationary period, with a GS-12 pay grade. Before Crain applied, she was told that if she successfully completed her probationary period, the Center would try to get the position’s pay grade increased to the GS-13 level. After Crain assumed the position, her supervisor added responsibilities to the role in an effort to justify a higher pay grade and asked Scaife, an HR classification specialist, to upgrade the role. Scaife concluded that she was unable to “justify anything higher than a GS-12.” Crain alleges that six White service chiefs’ pay grades were elevated to GS-13 or GS-14. During Crain’s tenure as Chief of EMS, several performance and behavior-related concerns arose.In June 2015, Crain was notified that she had failed to satisfactorily complete her supervisory probationary period and was being reassigned to a different role with the same salary. The memo identified multiple “performance-based deficiencies” as the basis for the decision. Months before her reassignment, Crain had initiated an EEOC complaint. After her reassignment, Crain sued under Title VII. The Seventh Circuit affirmed summary judgment in favor of the VA, rejecting Crain’s claims of disparate pay based on her race and that she was removed as Chief of EMS in retaliation for filing an EEOC complaint. View "Crain v. McDonough" on Justia Law

In 2014, Lopez became the manager at La Casa’s domestic violence shelter. In 2016, Lopez gave birth and experienced complications. She provided La Casa with certifications relating to her condition. Lopez alleged La Casa sent harassing communications, failed to engage in an interactive process to determine if Lopez’s disability could be accommodated, and refused to provide “modest” accommodations suggested by Lopez’s doctor. Lopez alleged that her efforts to return to work were “rebuffed,” so she was forced out of her job, and that she was denied a job elsewhere because La Casa misrepresented the reasons for her termination.The court of appeal affirmed a judgment in favor of La Casa. A claim under the Fair Employment and Housing Act, Government Code 12945(a)(3)(A), requires proof that the plaintiff had a condition related to pregnancy, childbirth, or a related medical condition; the plaintiff requested accommodation of this condition, with the advice of her health care provider; the plaintiff’s employer refused to provide a reasonable accommodation; and with the reasonable accommodation, the plaintiff could have performed the essential functions of the job. The trial court correctly applied those elements, properly placing the burden on Lopez to prove that she had a condition related to pregnancy and that she was able to perform the essential functions of her job with reasonable accommodation. View "Lopez v. La Casa de Las Madres" on Justia Law