Justia Civil Rights Opinion Summaries

Plaintiff, a woman with severe autism, and her mother, filed an employment discrimination lawsuit against Menards. Plaintiff's mother, who was also a plaintiff in the suit, arranged to have a job coach help Plaintiff obtain employment. However, despite the coach being willing to help Plaintiff through her orientation, Menards did not allow the coach to be present. After orientation, Plaintiff signed an arbitration agreement without the opportunity to show it to her job coach. Ultimately, Plaintiff was terminated and filed this case.Menards moved to compel arbitration. The district court denied Menards' request, resulting in this appeal.On appeal, the Eighth Circuit held that the fact Plaintiff's mother was appointed as Plaintiff's conservator did not necessarily mean that Plaintiff lacked the ability to enter into the contract. However, the court held that the record was not sufficiently developed to determine whether the facially valid contract was revocable under the void contract defense. Thus, the Eighth Circuit vacated the district court's order denying the motion to compel arbitration, and remanded to the district court for further proceedings. View "Mary Triplet v. Menard, Inc." on Justia Law

The Seventh Circuit reversed the judgment of the district court granting summary judgment in favor of the Federal Aviation Administration (FAA) and dismissing Plaintiff's claims that the FAA violated Title VII by retaliating against her for filing a formal complaint of religious discrimination, holding that a reasonable juror could conclude that retaliatory animus influenced Defendant's decision-making and proximately caused Plaintiff's termination.Plaintiff violated the FAA's alcohol and drug policy when she was arrested for an alcohol-related offense. By self-reporting her infraction, Plaintiff avoided disciplinary action if she completed a rehabilitation plan supervised by the FAA. Plaintiff objected on religious reasons to the plan's requirement that she attend Alcoholics Anonymous meetings and complained of religious discrimination, even after the FAA approved her participation in an alternate recovery program. The district court concluded that Plaintiff failed to establish a causal link between the formal complaint and her termination and granted summary judgment to the FAA. The Seventh Circuit reversed, holding that, under the causation standard for federal-sector retaliation claims, a reasonable juror could conclude that retaliatory animus influenced the FAA's decision-making and proximately caused Plaintiff's termination. View "Huff v. Buttigieg" on Justia Law

The Sixth Circuit reversed the order of the district court granting summary judgment dismissing Plaintiff's complaint that the Tennessee Valley Authority (TVA) discriminated against him based on his age and disability in violation of the Age Discrimination in Employment Act (ADEA) and the Rehabilitation Act, holding that summary judgment was improperly granted.A committee overseeing a training center at which Plaintiff taught voted to demote Plaintiff from his instructor position, citing ethical concerns that arose when Plaintiff's son was accepted to the training program. Plaintiff brought this complaint, alleging violations of the ADEA and Rehabilitation Act. The district court granted summary judgment for TVA. The Sixth Circuit reversed, holding (1) where a jury could infer that Plaintiff's supervisor used the ethical concern as a pretext to convince the other members of the committee to demote him, summary judgment on Plaintiff's ADEA and Rehabilitation Act claims was unwarranted; and (2) the district court incorrectly dismissed Plaintiff's retaliation claim. View "Bledsoe v. Tennessee Valley Authority Board of Directors" on Justia Law

Current and former Minnesota state employees brought an action seeking damages for money deducted from their paychecks by unions that represented their local bargaining units. Although the Supreme Court held the deduction practice unlawful in Janus v. American Federation of State, County, & Municipal Employees, 138 S. Ct. 2448 (2018), the district court determined that the unions acted in good faith reliance on state statutes and existing judicial precedent. Accordingly, the court ruled that the unions were entitled to a defense to liability under 42 U.S.C. Section 1983, and dismissed the employees’ claims.   The employees appealed arguing that there is no good-faith defense to liability for damages under Section 1983. The Eighth Circuit affirmed the district court’s judgments. The court explained because the unions collected fair-share fees under Minn. Stat. Section 179A.06 at a time when the procedure employed had been deemed constitutional by the Supreme Court, their reliance on the statute was objectively reasonable, and they are entitled to a good-faith defense. Even if subjective intent were deemed relevant, the employees have pleaded no facts to support a plausible inference that the unions collected these fees in subjective bad faith. The good-faith defense thus bars the employees’ claims for damages. View "Eric Brown v. AFSCME" on Justia Law

Appellants are four Minnesota state employees who sued unions that represented their local bargaining units. The employees sought monetary relief based on the amount of so-called “fair-share” fees that were deducted from employee paychecks for the benefit of the unions. The district court granted summary judgment in favor of the unions.  On appeal, the employees argue that the district court erred by granting summary judgment in favor of the unions on each of the claims for retrospective relief.   The Eighth Circuit affirmed, holding that the unions’ reliance on Section 179A.06 was objectively reasonable. It is an open question whether subjective intent is relevant to the defense, but the employees did not present a submissible case that the unions collected fair-share fees in subjective bad faith in any event. Therefore, the district court correctly granted summary judgment for the unions on these claims.   The unions prevailed on motions for summary judgment. The rules of civil procedure provide those costs “should be allowed to the prevailing party,” unless the court or a federal statute or rule directs otherwise. Further, the employees point to no authority that requires a district court to reduce an award of costs because a defendant opted to forgo a motion to dismiss and to file a dispositive motion only after developing a factual record. A defendant may choose how best to defend a lawsuit, and if the case is resolved in favor of the defense on a motion for summary judgment, then the defendant is presumptively entitled to costs. View "Linda Hoekman v. Education Minnesota" on Justia Law

First Data Technologies, Inc. (“First Data”), a credit and debit card processing company, employed Plaintiff as a call center representative. Plaintiff submitted a request pursuant to the Family and Medical Leave Act (“FMLA”) as a result of back pain she was experiencing from an automobile accident that occurred 15 days earlier. After a series of contested events, Plaintiff filed a charge of discrimination against First Data with the EEOC, alleging disability discrimination under the Americans with Disabilities Act (“ADA”). Finding no evidence of an ADA violation, the EEOC issued a dismissal and notice of rights.   Plaintiff later filed a complaint in the district court and First Data moved to dismiss Cowgill’s FMLA retaliation claim as time-barred, as well as Plaintiff’s ADA retaliation claim because Plaintiff’s failed to exhaust her administrative remedies. Plaintiff appealed the district court’s dismissal of the ADA retaliation claim, as well as the grant of summary judgment as to the disability discrimination and failure-to-accommodate claims.   The Fourth Circuit vacated the district court’s judgment because the court erred in holding that there are no genuine issues of material fact precluding summary judgment on the disability discrimination claim. The court explained that Plaintiff is entitled to the benefit of all inferences as the nonmovant, thus the court concluded that there is a genuine dispute as to whether Plaintiff met First Data’s legitimate expectations. Further, the court found that Plaintiff satisfied the final requirement of her disability discrimination claim because a reasonable factfinder could conclude that First Data’s proffered explanation served as pretext for an impermissible consideration. View "Terri Cowgill v. First Data Technologies, Inc." on Justia Law

Myers, a Centerville Police Department detective sergeant, Myers reported to then-Lieutenant Brown and then-Police Chief Robertson, that Lieutenant Lavigne possessed and “possibl[y] disseminat[ed]” sexually explicit photos of minors that he obtained while investigating a “sexting" complaint at Centerville High School. Myers continued to pursue that allegation to no avail. Three years later, Myers sought whistleblower protection and met with City Manager Davis to report new allegations against Robertson, and to repeat the allegation against Lavigne, then met with an outside attorney appointed by Davis. After learning of the investigation, Robertson retired. Myers was interviewed but not hired for the vacant chief post, which went to Brown; the hiring panel included Lavigne. Myers was also passed over for two lieutenant positions. He was admitted to the FBI National Academy but Quantico rescinded that offer after its background investigator spoke to Lavigne. Myers was disciplined for writing a “character letter” for another city employee; the letter was critical of the city. He was later terminated for recording a meeting.Myers sued. alleging First Amendment retaliation under 42 U.S.C. 1983. The Sixth Circuit affirmed the denial of a motion claiming qualified immunity. The district court erred by failing to meaningfully analyze the assertions of immunity by Brown and Davis at the pleadings stage, but Myers plausibly alleged First Amendment retaliation, and the defendants are not yet entitled to qualified or statutory immunity. View "Myers v. City of Centerville, Ohio" on Justia Law

Plaintiff worked as a driver for California Transit. After California Transit terminated his employment, Evenskaas filed this wage and hour class action against California Transit; its owner, and the company that administered California Transit’s payroll, Personnel Staffing Group, LLC (collectively, the California Transit defendants).   Because Plaintiff signed an arbitration agreement, in which he agreed to arbitrate all claims arising from his employment and waived his right to seek class-wide relief, the California Transit defendants filed a motion to compel arbitration. The trial court denied the motion. The California Transit defendants appealed, contending the FAA applies to the arbitration agreement.   The Second Appellate District reversed the order denying Defendants’ motion to compel arbitration is reversed. The court directed the trial court to enter a new order granting the motion and dismissing Plaintiff’s class claims. The court explained that because the paratransit services California Transit hired Plaintiff to provide involve interstate commerce for purposes of the FAA, the FAA applies to the arbitration agreement and preempts the Gentry rule that certain class action waivers in employment arbitration agreements are unenforceable. View "Evenskaas v. California Transit, Inc." on Justia Law

Plaintiff, an employee of the Department of Veterans Affairs, sued Denis McDonough, Secretary of the Department of Veterans Affairs, for disability discrimination. Plaintiff alleged three violations of the Rehabilitation Act: failure to accommodate; disability discrimination; and retaliation for requesting an accommodation. The district court granted summary judgment to Secretary McDonough.   The Eighth Circuit affirmed. The court wrote that Plaintiff’s requested accommodation was not required under the Rehabilitation Act because it would impose an undue hardship on the VAPD. The court explained that Plaintiff’s accommodations would have violated the VAPD’s collective bargaining agreement, which requires that “[s]cheduled off-tours shall be rotated fairly and equitably among affected employees, i.e., day/evening, day/night.” Plaintiff’s requested accommodations are therefore presumptively unreasonable.   Plaintiff further argued that his reassignment was not reasonable for two reasons. First, he claimed that day shifts were not the only form of requested relief; they were just one of many possible accommodations the VAPD could have made. But the record undermines his argument. Further, he also suggested that his reassignment constituted an adverse employment action, not a reasonable accommodation. The VAPD provided the only available reasonable accommodation—reassignment. The district court was therefore correct to grant summary judgment to Secretary McDonough on Plaintiff’s failure to accommodate claim.   Moreover, Plaintiff claimed the unusual nature of his hiring process proves that the real reason for his non-selection was disability discrimination. However, showing that an interview process is “unusual” is not sufficient to prove that an employer’s proffered reason is pretextual. View "Jesse LeBlanc v. Denis McDonough" on Justia Law

The First Circuit reversed the order of the district court denying Defendant's motion for summary judgment as to Plaintiff's whistleblower retaliation claim brought under section 1514A of the Sarbanes-Oxley Act, holding that Plaintiff could not satisfy his burden of bringing a claim for whistleblower retaliation under section 18 U.S.C. 1514A.Plaintiff, a former employee of Defendant, sued Defendant for whistleblower retaliation under section 1514A, but his particular whistleblower claim was based on an alleged violation of 15 U.S.C. 78m(b)(2), (5). Defendant moved for summary judgment following the completion of discovery, arguing that Plaintiff's action did not fall within any of the definitions of protected activity under section 1514A. The district court denied the motion as to the whistleblower retaliation claim. The First Circuit reversed and remanded with instructions to enter summary judgment in favor of Defendant, holding that Plaintiff's conduct was not "protected activity" under section 1514A. View "Baker v. Smith & Wesson, Inc." on Justia Law