Justia Civil Rights Opinion Summaries

The Fourth Circuit held that "job sharing" a single full-time position with a willing partner does not qualify as a reasonable accommodation that an employer must provide under the Americans with Disabilities Act (ADA). The court explained that, if the job share in question did not exist at the time it was proposed as an accommodation, the ADA does not require the employer to create the new position to accommodate a disabled employee.In this case, the court concluded that providing plaintiff with the job share position with another employee was not a reasonable accommodation required by the ADA—not because the position was not "vacant" but because the position she sought did not exist. Therefore, summary judgment should have been granted to Sanofi on plaintiff's failure-to-accommodate claim on this ground. Furthermore, because plaintiff failed to demonstrate the existence of a reasonable accommodation, Sanofi cannot separately be liable for failing to engage in the interactive process. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Sanofi. View "Perdue v. Sanofi-Aventis U.S., LLC" on Justia Law

The Eighth Circuit affirmed the district court's judgment following a jury verdict in favor of the City on plaintiff's claim of hostile work environment based on religion. At issue is whether the district court abused its discretion in precluding plaintiff from introducing testimony and a report by the City's retained but non-testifying expert psychiatrist who had conducted an independent medical examination of plaintiff.The court concluded that the expert's report would have been cumulative with other testimony regarding causation and damages, and any discussion of damages was immaterial because the jury never reached that issue. Therefore, the exclusion did not result in fundamental unfairness in the trial of the case, and the court need not consider whether the district court abused its substantial case management and discovery discretion in excluding the expert's independent medical examination report and testimony, an issue the court has not previously addressed. View "Cooper v. City of St. Louis, Missouri" on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Defendant in this case alleging a violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., holding that genuine issues of material fact precluded summary judgment.Plaintiff, who was Black, sued Bridgewater State university's Board of Trustees and Office of Equal Opportunity and a University administrator (collectively, Defendants) alleging that she was not hired for a University position because of her race. The district court granted summary judgment in favor of Defendants. The First Circuit reversed, holding that Plaintiff's aggregate package of proof sufficed to survive Defendants' motion for summary judgment. View "Taite v. Bridgewater State University" on Justia Law

Taylor was fired from his job as a Cook County Sheriff’s officer. He sued the Sheriff’s Office under Title VII of the Civil Rights Act and Ways, Whittler, and Ernst under 42 U.S.C. 1983 for violating the Equal Protection Clause. The defendants maintain that Taylor was terminated for having fired pellets with an air rifle at his neighbor, a charge that Taylor denies. Ernst was the lead investigator assigned to Taylor’s case. Taylor offered evidence that Ernst engineered his firing based on racial animosity. Taylor also asserted that Ways and Whittler, Sheriff’s Office officials, are liable because they reviewed Ernst’s final report and endorsed his recommendation of termination.On interlocutory appeal, the Seventh Circuit upheld the denial of qualified immunity as to Ernst. Taylor presented evidence of Ernst’s significant role in the investigative and disciplinary proceedings that brought about Taylor’s termination. Any reasonable official in Ernst’s position would have known that intentional racial discrimination toward another employee was unconstitutional and what Taylor alleges against Ernst is textbook racial discrimination: the word “n****r,” used by Ernst, a white man, aimed at Taylor on several occasions. The court reversed the denials of qualified immunity to Ways and Whittler; evidence that they played key roles in approving Ernst’s termination does not signal that either harbored any racial animus or that they knew or suspected that Ernst was motivated by race. Taylor’s Title VII claim remains pending. View "Taylor v. Ernst" on Justia Law

The First Circuit reversed the order of the district court excluding two documents from the summary judgment record and granting summary judgment for Defendant on all of Plaintiff's claims, holding that the district court erred in excluding the two documents from the summary judgment record.Defendant terminated Defendant's employment after he had been employed for thirty-three years. Plaintiff brought this lawsuit alleging wrongful termination of his employment under state law and age discrimination under federal and state law. Defendant moved to strike two of Plaintiff's documents on the grounds that they had been produced after the discovery cut-off date and that they were not properly authenticated. The district court granted the motion to strike the documents and then granted Defendant's motion for summary judgment. The First Circuit reversed the order excluding the documents and vacated the entry of summary judgment, holding that the court erred in striking the documents and that material issues of fact precluded summary judgment. View "Zampierollo-Rheinfeldt v. Ingersoll-Rand de Puerto Rico, Inc." on Justia Law

Jackson, an African American woman, was GCRC's Human Resources Director. Daly, GCRC’s chief administrative officer, was Jackson’s supervisor. There were pending internal discrimination complaints when Jackson started, including a complaint by African American employees about Bennett. Jackson ultimately negotiated a severance agreement with Bennett. A second issue involved McClane’s complaints about Williams, GCRC’s finance director, who subsequently resigned. Jackson was also responsible for approving Equal Employment Opportunity Plans submitted by vendors and contractors. Jackson realized that several vendors’ EEOPs had expired and became concerned that some GCRC directors were conducting business with vendors before their EEOPs were approved. Jackson implemented several changes in GCRC’s EEOP approval process. Several employees, vendors, board members, and union representatives complained to Daly about Jackson’s “abrasiveness” and communication style. Other employees reported having good experiences with Jackson. Daly fired Jackson without giving a reason other than she was an at-will employee. Jackson filed a retaliation claim under Title VII of the Civil Rights Act and Michigan’s Elliot-Larsen Civil Rights Act. The district court granted GCRC summary judgment.The Sixth Circuit reversed. Jackson engaged in protected activity and there remains a genuine factual dispute as to causation. Jackson’s actions could reasonably be viewed as steps to ensure there was no discrimination in hiring both within GCRC and among its vendors, and were protected activity under Title VII. A reasonable juror could find that Jackson has established a prima facie case of causation through circumstantial evidence including the temporal proximity between Jackson’s protected activity and termination. View "Jackson v. Genesee County Road Commission" on Justia Law

Plaintiff filed suit against the school district, claiming discrimination under the Americans with Disabilities Act (ADA) and the Rehabilitation Act; interference with her Family and Medical Leave Act (FMLA) rights; and retaliation in violation of all three statutes. Principally, plaintiff alleged that, in ending her employment, the school district discriminated against her because she suffers from major depressive disorder and retaliated against her for asserting her statutory rights.The Eleventh Circuit affirmed the district court's grant of summary judgment in favor of the school district. The district court concluded that the school district had terminated plaintiff's employment because of her conduct—the threats she made against her own life and the lives of others—not because she had major depressive disorder or because she had participated in statutorily protected activity. In regard to plaintiff's disability discrimination claims under the ADA and Rehabilitation Act, the court ultimately concluded that plaintiff failed to present sufficient evidence to create a genuine dispute of material fact as to whether the school district's proffered reasons for terminating her employment were pretextual. In regard to plaintiff's retaliation claims, the court concluded that, besides the temporal proximity between when plaintiff asserted her ADA rights and when the school district asked her to resign, no evidence suggests that the school district's stated reasons for ending her employment were merely an excuse to cover up retaliation. In regard to the FMLA interference claim, the court concluded that plaintiff cites nothing from the record to show that the school district's decision to end her employment related in any way to her decision to take FMLA leave. View "Todd v. Fayette County School District" on Justia Law

After plaintiff, a York County Sheriff's Office (YCSO) employee, disclosed confidential information about an ongoing investigation into an inmate's death to his wife, who worked at a local news station, and then lied to internal investigators about the disclosure, defendant terminated plaintiff's employment. Plaintiff filed suit against defendant under 42 U.S.C. 1983, alleging that he was fired in retaliation for exercising his First Amendment rights. The district court ruled in favor of plaintiff, but the Fourth Circuit vacated and remanded. On remand, the district court concluded that plaintiff's speech was not protected speech after applying the proper standard. The district court found the speech in question caused a reasonable apprehension of disruption in the YCSO and that defendant's interest in avoiding such a disruption outweighed plaintiff's circumstantially diminished First Amendment interest. Plaintiff appealed, challenging the district court's balancing of the parties' interests.The Fourth Circuit afforded diminished weight to plaintiff's First Amendment interest and concluded that it was outweighed by defendant's reasonable apprehension of disruption. In this case, plaintiff acted on limited and unconfirmed information when disclosing confidential details, and did so knowing that an investigation into the incident was underway, making no effort whatsoever to proceed through the chain of command or any law enforcement channel. Furthermore, the record reveals a reasonable apprehension of disruption in the YCSO, particularly considering plaintiff's speech propelled a frenzy of media attention about unconfirmed facts related to the inmate's death. The court explained that the disruption ballooned into separate internal investigation into the unauthorized disclosure, undercutting manpower and resources to continue the ongoing investigation into the incident. Accordingly, plaintiff's First Amendment retaliation claim failed and the court affirmed the district court's judgment. View "Billioni v. Bryant" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims against the Board of Regents of the University of Minnesota, alleging that the University constructively terminated her and subjected her to a hostile work environment. Plaintiff, the head coach of the women's cross-country and track-and-field teams, resigned after the University threatened to terminate her following an outside-law-firm's investigation into her alleged misconduct.The court concluded that, although plaintiff's factual allegations show the University treated her and her teams differently from other coaches and teams, the complaint does not plausibly give rise to the inference of discrimination on the basis of sex as the reason for her termination. Furthermore, even if the stated reason for her termination was pretextual, she has not stated a claim for relief that is plausible on its face. The court also concluded that plaintiff's allegations, though perhaps describing vile or inappropriate behavior, do not rise to the level of actionable hostile work environment as a matter of law. View "Warmington v. Board of Regents of the University of Minnesota" on Justia Law

The First Circuit resolved a portion of Appellant's appeal in this opinion addressing the district court's grant of summary judgment in favor of the Town of Brookline, Massachusetts, the Brookline Board of Selectmen, the Town's counsel and Human Resources director, and select members of the Board, holding that the summary judgment is affirmed in part, vacated in part and remanded for further proceedings.Plaintiff, black man, brought this suit alleging that during his employment as a firefighter, he had been discriminated against and retaliated against for reporting discriminatory conduct. The district court entered summary judgment in favor of Defendants. The First Circuit affirmed in part and vacated in part the summary judgment granted in favor of Defendants, holding that the district court erred in granting summary judgment as to Plaintiff's retaliation claims under 42 U.S.C. 1983 against the Town, the Board, and certain members of the Board, in their personal and official capacities. The Court then remanded the case for further proceedings. View "Alston v. Town of Brookline, Mass." on Justia Law