Justia Civil Rights Opinion Summaries

The First Circuit affirmed the judgment of the district court rejecting the jury's advisory verdict in this case, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff, a former intelligence specialist, sued his former employer, the United States Attorney's Office for the District of Puerto Rico pursuant to Title VII of the Civil Rights Act, alleging discriminatory retaliation and constructive discharge resulting from a hostile work environment. After a jury returned a verdict on liability for retaliation and awarding the statutory maximum in damages, the district court charged the jury to return an advisory verdict on the issue of damages for constructive discharge. The jury returned a verdict in favor of Plaintiff as to that issue, and thereafter, Plaintiff sought a judgment of front and back pay. The district court rejected the jury's advisory verdict, concluding that the verdict was not supported by the evidence, that Plaintiff was not constructively discharged, and that Plaintiff was not entitled to front or back pay. The First Circuit affirmed, holding (1) Plaintiff waived his objection to the district court's decision to submit the constructive discharge issue to an advisory jury; and (2) the district court's factual findings were not clearly erroneous. View "Reyes-Caparros v. Garland" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of the Town of Brookline, Massachusetts on Plaintiff's claim brought pursuant to 42 U.S.C. 1983 alleging discrimination on the basis of race in violation of the Fourteenth Amendment's Equal Protection Clause, holding that the district court did not err in granting summary judgment.Plaintiff brought this action alleging that Brookline violated his equal protection rights in terminating his employment. The district court granted summary judgment in favor of the Town. The First Circuit affirmed, holding that Plaintiff's evidence failed to establish that the Town's proffered reasons for failing to accommodate and then dismissing Plaintiff were a pretext for race discrimination. View "Fincher v. Town of Brookline" on Justia Law

Appellant Jeffrey Booth, then an installation service manager for Appellee Home Depot, U.S.A., noticed at a job site that a customer was being charged for window wraps that were not needed. Booth phoned and emailed his supervisor about the perceived overcharge. The next day, Appellee began an investigation of Booth for an email he sent ten days earlier critiquing a colleague's work performance. After a one-day investigation of the allegation in the email, and two days after the overcharge report, Appellant Booth was terminated. Booth sued Home Depot in Oklahoma state court claiming wrongful termination under Burk v. K-Mart Corp., 770 P.2d 24 (1989), alleging his job performance was good and that the email investigation was only a pretext for the real reason for termination -- his reporting of the overcharging of customers to his supervisor. Home Depot removed the Oklahoma County case to the federal district court under diversity jurisdiction. In his amended federal complaint, Booth claimed that the overcharging of customers violated the Oklahoma Home Repair Fraud Act and/or the Oklahoma Consumer Protection Act. Home Depot did not dispute that, if overcharging occurred, it would violate those acts. Home Depot argued that the violation of the statutes did not articulate a clear mandate of Oklahoma public policy sufficient to support a Burk tort. The federal district court agreed with Home Depot that the statutes did not articulate a clear public policy and dismissed the petition for failure to state a claim upon which relief could be granted. Booth then appealed to the United States Court of Appeals for the Tenth Circuit, which then certified a question about the statutes to the Oklahoma Supreme Court. The Supreme Court responded: the OHRFA and the OCPA protect specific individual consumers against fraud with criminal and civil remedies for those individual victims. "The Court will not expand our public policy exceptions to include protection from economic harm. Without a clear mandate from the Legislature, the Acts do not qualify as an established public policy." View "Booth v. Home Depot, U.S.A." on Justia Law

Plaintiff-appellant Tiffany Litzsinger worked for the Adams County Coroner’s Office from 2013 until she was terminated in 2018. During her time there, Litzsinger suffered from anxiety and depression, both of which worsened in the months leading up to her termination. After an anxiety episode, Adams County granted Litzsinger temporary leave under the Family and Medical Leave Act (FMLA). When Litzsinger returned from her FMLA leave, the Coroner placed Litzsinger on probation for myriad violations of workplace policies. Shortly after Litzsinger’s probation began, the Coroner terminated Litzsinger for violating the terms of her probation. Litzsinger sued the Coroner’s Office under the FMLA and Americans with Disabilities Act (ADA), claiming the Coroner terminated her in retaliation for exercising her rights under both statutes. The district court granted summary judgment for the Coroner’s Office because Litzsinger failed to demonstrate that the Coroner’s reason for terminating her was pretextual. The Tenth Circuit affirmed, finding a rational jury could not find that the Coroner’s proffered reason for firing Litzsinger was pretextual. View "Litzsinger v. Adams County Coroner's Office" on Justia Law

The Fifth Circuit affirmed the district court's denial of qualified immunity to defendants in a 42 U.S.C. 1983 action for conspiracy to commit retaliatory employment termination. The court concluded that plaintiff plausibly averred that defendants deprived him of his First Amendment rights, and that defendants had fair warning that using their respective government positions to violate plaintiff's First Amendment rights would be objectively unreasonable in light of clearly established law at the time. The court also concluded that plaintiff has also stated a claim for conspiracy under section 1983. View "Bevill v. Fletcher" on Justia Law

The Seventh Circuit affirmed the district court's grant of summary judgment in favor of USS on plaintiff's Americans with Disabilities Act (ADA) claim, concluding that USS carried its burden to show that plaintiff's seizure disorder would pose a direct threat to himself and others at its Midwest Plant. In this case, USS's judgment was premised on the consideration of adequate evidence, as contemplated by the ADA and supporting regulations. Furthermore, USS's imposition of restrictions was based on information pertinent to plaintiff's personal experience with his seizure disorder. Therefore, the assessment USS conducted was sufficiently individualized. The court agreed with the district court that whether plaintiff's seizure disorder was controlled is a material fact about which there is no genuine dispute.Applying the direct threat analysis and weighing factors such as duration of the risk, the nature and severity of potential harm, the likelihood of harm that will occur, and imminence of harm, the court concluded that all the factors weigh in favor of finding that there is a direct threat. Therefore, USS has shown through undisputed evidence that, if hired for the Utility Person position, plaintiff's seizure disorder would pose a direct threat to himself and others at the Midwest Plant. View "Pontinen v. United States Steel Corp." on Justia Law

The California Personnel Board (Board) sustained a complaint brought by Vickie Mabry-Height, M.D., against the Department of Corrections and Rehabilitation (Department) alleging discrimination based on age, race, and gender in violation of the California Fair Employment and Housing Act (FEHA). The Board concluded that Dr. Mabry-Height established a prima facie case of unlawful discrimination based on certain conduct, and the Department failed to rebut the presumption of discrimination by offering evidence that it had a legitimate, nondiscriminatory reason for this conduct. The Department petitioned the trial court for a writ of administrative mandamus seeking an order setting aside the Board’s decision. The petition was denied, and judgment was entered in favor of Dr. Mabry-Height. The Department appealed, but finding no reversible error, the Court of Appeal affirmed the trial court. View "Dept. of Corrections & Rehabilitation v. State Personnel Bd." on Justia Law

The Supreme Court held that Cal. Labor Code 1102.6 governs whistleblower retaliation claims brought pursuant to Cal. Labor Code 1102.5.Since 2003, section 1102.6 has prescribed a framework for presenting and evaluating retaliation claims brought under section 1102.5. Since 2003, some courts continued to apply the burden-shifting framework borrowed from the decision in McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973). The trial court granted summary judgment for Defendant on Plaintiff's whistleblower retaliation claim in this case, concluding that Plaintiff could not satisfy the third step of the McDonnell Douglas test. The Ninth Circuit Court of Appeal certified a question regarding the correct standard to the Supreme Court. The Supreme Court answered that section 1102.6 provides the governing framework for the presentation and evaluation of whistleblower retaliation claims brought under section 1102.5. View "Lawson v. PPG Architectural Finishes, Inc." on Justia Law

Nadendla, a physician, is of Indian origin. Nadendla was a member of WakeMed’s hospital's medical staff where she was granted clinical privileges in 2010, In 2017, citing “clinical concerns,” WakeMed informed Nadendla that she would not be reappointed clinical privileges; her appointment on the medical staff would expire. Nadendla requested a hearing, pursuant to the Bylaws. She alleges that WakeMed’s actions during the hearing process “exhibited an abject lack of fairness” and deprived her of adequate process in contravention of the Bylaws.Nadendla sued the hospital under 42 U.S.C. 1981, which guarantees to all persons in the United States “the same right . . . to make and enforce contracts . . . as is enjoyed by white citizens.’” The district court initially ruled that Nadendla sufficiently stated a section 1981 claim and state-law claims for breach of contract and for arbitrary and capricious conduct, but subsequently dismissed Nadendla’s section 1981 claim. The Fourth Circuit affirmed in part. The district court had the discretion to revisit its prior order and did not abuse its discretion in doing so. The complaint contained extensive, specific allegations regarding WakeMed’s failure to abide by the Bylaws but details regarding race are conspicuously absent. The court reversed the dismissal of Nadendla’s claim for breach of the implied covenant of good faith and fair dealing. View "Nadendla v. WakeMed" on Justia Law

Plaintiffs, former IBM employees who entered into severance agreements in which they agreed not to join any collective actions against IBM, filed suit challenging the validity of those collective-action waivers, alleging claims under the Age Discrimination in Employment Act of 1967 (ADEA). The district court granted IBM's motion to dismiss for failure to state a claim. In 14 Penn Plaza LLC v. Pyett, 556 U.S. 247 (2009), the Supreme Court held that section 626(f)(1) of the ADEA applied to substantive rights, like the statutory right to be free from workplace age discrimination, but not procedural ones, like the right to seek relief from a court in the first instance.The Second Circuit concluded that collective-action waivers, like arbitration clauses, address procedural, not substantive rights, and thus do not require special disclosures under section 626(f)(1) of the ADEA for their acceptance to be knowing and voluntary. Therefore, the district court correctly held that 14 Penn Plaza governs this case and granted IBM's motion to dismiss. View "Estle v. International Business Machines Corp." on Justia Law