Justia Civil Rights Opinion Summaries

In 2017 Nigro, a certified nurse anesthetist, began working at Riley Hospital. Division Director, Dr. Sadhasivam, recruited her and started implementing a new team-based care model. Within a year, an internal investigation revealed department-wide concern over the model’s efficacy and impact on team dynamics. Some employees believed that Sadhasivam’s leadership style resulted in a tense workplace. In 2017-2019, Nigro was the subject of multiple complaints, mostly concerning her attitude and ability to work on a team. Coworkers described her as “rude, snappy and belittling,” with management expressing concern that her behavior undermined the department’s already delicate atmosphere of collegiality. After investigating the complaints, hospital decision-makers issued a “coaching memorandum” to Nigro. A month later, it was determined that Nigro had engaged in timekeeping fraud by not working at times when she had been clocked in, Sadhasivam and three female administrators, agreed to terminate her for misconduct.Nigro filed suit under Title VII, 42 U.S.C. 2000e-2(a)(1), alleging sex-based discrimination and retaliation because of a supportive affidavit she had signed in another employee’s discrimination case. The Seventh Circuit affirmed summary judgment in favor of the defendants. There is neither direct nor indirect evidence to support Nigro’s Title VII claim. View "Nigro v. Indiana University Health Care" on Justia Law

Appellant, a black male who was 60 years old at the time his employment was terminated, brought race, sex, and age discrimination claims under Title VII, the Age Discrimination in Employment Act (“ADEA”), and the Minnesota Human Rights Act (“MHRA”) and a retaliation claim under the Minnesota Whistleblower Act ("MWA") after the Minnesota Guardian ad Litem Board (“GALB”) terminated his employment following internal and external investigations into allegations of his misconduct. The district court granted GALB’s motion for summary judgment, finding that Appellant failed to demonstrate a prima facie case of discrimination or retaliation and, even if he had done so, he failed to demonstrate GALB’s reasons for terminating his employment were pretextual.   Appellant appealed and the Eighth Circuit affirmed. The court explained that Appellant failed to point to any direct evidence of discrimination or retaliation; thus, the McDonnell Douglas burden-shifting framework applies. The court concluded that GALB has demonstrated a legitimate, nondiscriminatory and nonretaliatory reason for terminating Appellant in March 2018: the internal and external investigations into Appellant’s alleged misconduct uncovered evidence that Appellant had engaged in gross misconduct. As such, because Appellant failed to show that GALB’s reasons for terminating his employment were pretextual, the district court did not err in granting summary judgment to GALB on his race, sex, and age discrimination claims and his retaliation claim. View "Gregory King v. MN Guardian ad Litem Board" on Justia Law

The Seventh Circuit affirmed the judgment of the district court entering judgment upon the jury's verdict in favor of Paul Reina on his claim that Walmart violated the Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), (b) and acted maliciously or in reckless disregard of Reina's rights, holding that the district court did not abuse its discretion.Reina, who was deaf and legally blind, worked as a cart attendant for Walmart for almost twenty years. After providing Reina with a job coach, Walmart eventually ended Reina's employment. Reina filed an administrative charge with the Equal Employment Opportunity Commission (EEOC), which sued Walmart for violating the ADA. The jury concluded that Walmart violated the ADA by refusing Reina a reasonable accommodation in the form of a full-time job coach and acted maliciously or in reckless disregard of Reina's rights. The jury awarded Reina $200,000 in compensatory damages and $5 million in punitive damages. The Third Circuit affirmed, holding (1) the district court properly denied Walmart's motion for judgment as a matter of law; and (2) the district court did not abuse its discretion by declining to issue an injunction against Walmart as proposed by the EEOC. View "Equal Employment Opportunity Commission v. Wal-Mart Stores, Inc." on Justia Law

In response to the Covid-19 pandemic, Port Authority, a municipal bus and light-rail operator, required its uniformed employees to wear face masks. Initially, Port Authority was unable to procure masks for all its employees, so they were required to provide their own. Some employees wore masks bearing political or social-protest messages. Port Authority has long prohibited its uniformed employees from wearing buttons “of a political or social protest nature.” Concerned that such masks would disrupt its workplace, Port Authority prohibited them in July 2020. When several employees wore masks expressing support for Black Lives Matter, Port Authority disciplined them. In September 2020, Port Authority imposed additional restrictions, confining employees to a narrow range of masks. The employees sued, alleging that Port Authority had violated their First Amendment rights.The district court entered a preliminary injunction rescinding discipline imposed under the July policy and preventing Port Authority from enforcing its policy against “Black Lives Matter” masks. The Third Circuit affirmed. The government may limit the speech of its employees more than it may limit the speech of the public, but those limits must still comport with the protections of the First Amendment. Port Authority bears the burden of showing that its policy is constitutional. It has not made that showing. View "Amalgamated Transit Union Local 85 v. Port Authority of Allegheny County" on Justia Law

The First Circuit affirmed the district court's judgment dismissing Plaintiffs' lawsuit asserting race-based discrimination and retaliation in violation of Title VII of the Civil Rights Act, holding that the district court did not err in dismissing the suit for failure to state a claim.Plaintiffs represented a putative class of employees employed by Whole Foods and Amazon who were disciplined for wearing face masks with the message "Black Lives Matter." In their lawsuit, Plaintiffs alleged that the manner in which their employers enforced a previously unenforced dress code policy constituted race-based discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964. The district court dismissed all claims. The First Circuit affirmed, holding that Plaintiffs did not adequately plead claims for racial discrimination and retaliation under Title VII. View "Frith v. Whole Foods Market, Inc." on Justia Law

Plaintiff was transferred from a class where she instructed emotionally disturbed (“ED”) children to a class where Plaintiff worked with children with moderate intellectual disabilities. Plaintiff alleged that one of her students sexually harassed her between fall 2018 through mid-March 2019. This student, S.M., was an eight-year-old boy diagnosed with Down’s Syndrome and Attention Deficit Hyperactivity Disorder (“ADHD”). Although the teacher in the classroom recorded the incidents in her notes, or “point sheets,” where she detailed each student’s daily behavior, Plaintiff claims the teacher was generally dismissive of her concerns. After exhausting her remedies with the United States Equal Employment Opportunity Commission, Plaintiff filed suit against the Chesterfield County School Board (“the School Board”) alleging that she was subjected to a sexually hostile work environment in violation of Title VII.   The district court granted the School Board’s motion for summary judgment. At issue on appeal is whether the district court erred in dismissing Plaintiff’s hostile work environment claim on summary judgment. The Fourth Circuit affirmed, finding that the record does not support a prima facie case for hostile work environment sexual harassment. The court explained that Plaintiff cannot primarily rely upon her own statements to argue that S.M.’s conduct surpassed what could be expected of an eight-year-old child with his disabilities after two special education experts testified that it did not—instead, she is required by law to demonstrate it. Further, even if Plaintiff established that S.M. targeted her because of sex, she would still be unable to meet the third required element—that is, show that S.M.’s conduct rose to the level of severe or pervasive. View "Regina Webster v. Chesterfield County School Board" on Justia Law

St. Vincent Hospital adopted a COVID-19 vaccine requirement. Employees had until November 12, 2021 to get vaccinated unless they received a medical or religious exemption. In reviewing exemption requests, St. Vincent considered the employee’s position and amount of contact with others, the current health and safety risk posed by COVID, and the cost and effectiveness of other safety protocols. Dr. Halczenko treated gravely ill children, including those suffering from or at risk of organ failure.St. Vincent denied Halczenko’s request for religious accommodation on the ground that “providing an exemption to a Pediatric Intensivist working with acutely ill pediatric patients poses more than a de minim[i]s burden to the hospital because the vaccine provides an additional level of protection in mitigating the risk associated with COVID.” Halczenko and four other St. Vincent employees filed an EEOC complaint. The others—a nurse practitioner and three nurses, including two in the pediatric ICU—were granted religious accommodations. St. Vincent terminated Halczenko’s employment. Halczenko attributes his lack of success in finding new work to his non-compete agreement with St. Vincent, his preference not to move his family, and the limited demand for an unvaccinated physician in his specialty. In a purported class action, the Seventh Circuit affirmed the denial of preliminary relief, concluding that Halczenko had shown neither irreparable harm nor an inadequate remedy at law. View "Halczenko v. Ascension Health, Inc." on Justia Law

Several public-sector employees filed a class action lawsuit under 42 U.S.C. Sec. 1983 seeking to recover any agency fees taken from their paychecks by the Santa Clara County Correctional Peace Officers Association and Santa Clara County. Specifically, Plaintiffs sought a refund for fees paid before the United States Supreme Court issued its opinion in Janus v. Am. Fed’n of State, Cnty., & Mun. Emps., Council 31, 138 S. Ct. 2448 (2018) (prohibiting public-sector unions from collecting compulsory agency fees).In the district court, Defendants successfully moved for summary judgment, claiming they were entitled to a good-faith defense because their actions were expressly authorized by then-applicable United States Supreme Court law and state law. Plaintiffs appealed.On appeal, Plaintiffs acknowledge that Danielson v. Inslee, 945 F.3d 1096 (9th Cir. 2019) precludes their claim against the Union. The Ninth Circuit held that the rule announced in Danielson also applies to municipalities because "precedent recognizes that municipalities are generally liable in the same way as private corporations in sec. 1983 actions." Thus, the court affirmed the district court's dismissal of Plaintiffs' claim against both the Union and the County. View "SEAN ALLEN V. SANTA CLARA CNTY CORR. POA" on Justia Law

Plaintiff a former part-time employee of the City of Cedar Falls, brought an action against the City of Cedar Falls and certain city officials after her 2018 termination, alleging interference with and retaliation for the exercise of her rights under the Family and Medical Leave Act (FMLA) and claims of age discrimination, disability discrimination, hostile work environment, and retaliation under the Iowa Civil Rights Act (ICRA). The district court granted summary judgment in favor of Defendants on all of Plaintiff’s claims, and she appealed.
The Eighth Circuit affirmed. The court explained that it need not consider the substantive elements of the claim because Plaintiff has failed to demonstrate that she sustained any recoverable damages and it is undisputed that she did not seek any form of equitable relief.   Second, as to the retaliation claim, the court applied the McDonnell Douglas burden-shifting framework, which requires a plaintiff to make a prima facie showing of retaliation before the burden shifts back to the employer to offer a legitimate, non-discriminatory reason for its actions. Here, Plaintiff has failed to put forth any evidence of the kind that would demonstrate pretext. She offered nothing more than disagreement with the statements contained in the disciplinary reports. In the absence of any factual record demonstrating that these documented performance deficiencies were inaccurate, Plaintiff has failed to meet her burden of demonstrating pretext. Finally, Plaintiff has failed to show that the final three disciplinary reports were part of the same unlawful employment practice—harassment based on her age and disability. View "Michelle Brandt v. City of Cedar Falls" on Justia Law

The California Insurance Commissioner filed an ex parte conservation application to place the California Insurance Company (“CIC I”) in a conservatorship after CIC I’s president attempted to consummate a purchase transaction with Berkshire Hathaway without the Commissioner’s approval, and then attempted to bypass the California insurance regulatory scheme by merging CIC I with the California Insurance Company (“CIC II”), a New Mexico-domesticated shell company formed by the president. The Superior Court granted the Commissioner’s conservatorship application and appointed the Commissioner as Conservator of CIC I. Applied Underwriters, of which the president is the Chief Executive Officer, and CIC II filed separate actions in federal court asserting causes of actions under Section 1983.   The district court dismissed both actions pursuant to Federal Rule of Civil Procedure 12(b)(1). The Ninth Circuit held that because important considerations of federalism were at stake, the district court’s reliance on Younger abstention as a ground for dismissal was in error. The court held that an insurance conservatorship is not sufficiently akin to criminal prosecution to bring it within the purview of what constitutes a similar, Younger-eligible “civil enforcement proceeding.”   The court held that dismissal of Appellants’ claims was warranted on account of the prior exclusive jurisdiction rule. Further, Appellants’ interests were well represented in the conservatorship action; they had an adequate opportunity to raise constitutional challenges; they failed to sufficiently allege that the conservatorship action was brought in bad faith; they failed to demonstrate irreparable injury arising from extraordinary circumstances which might justify an exception to the prior exclusive jurisdiction rule. View "APPLIED UNDERWRITERS, INC. V. RICARDO LARA" on Justia Law