Justia Civil Rights Opinion Summaries

After being fired from the CTA, Miller and McGuire (both Caucasian) sued their former employer, alleging racial discrimination and retaliation in violation of federal (42 U.S.C 1981 and 1983, Title VII of the Civil Rights Act of 1964) and Illinois state law. Following discovery, the defendants moved for summary judgment. Despite receiving two extensions, however, Miller and McGuire failed to respond. Finding no persuasive excuse for this failure, the district court denied their third extension and took up the motion without a responsive pleading. The court concluded that the undisputed evidence did not support the claims and granted CTA summary judgment.The Seventh Circuit affirmed. The district court did not abuse its discretion in denying an extension, and evidence of basic elements of a retaliation claim was lacking. Miller and McGuire could not avoid summary judgment based on the suspicious timing of their discharges alone unless, “[a]t minimum,” they first produced evidence supporting a reasonable inference that Bonds (a CTA officer) knew of their EEO complaints. They did not. Undisputed evidence showed that CTA had legitimate (nonracial) reasons for terminating Miller and McGuire’s employment and these reasons were not pretextual. View "Miller v. Chicago Transit Authority" on Justia Law

The Fifth Circuit affirmed the district court's grant of the Department's motion for judgment on the pleadings, holding that Louisiana has not waived its sovereign immunity for claims under Title I of the Americans with Disabilities Act. In this case, plaintiff filed suit for disability discrimination under the Act after he was terminated from his job of nearly twenty-four years based on his medical problems. The court also denied plaintiff's request to certify a question to the Louisiana Supreme Court, concluding that this case does not present a genuinely unsettled matter of Louisiana law and thus certification is not appropriate. View "Fletcher v. Louisiana Department of Transportation and Development" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment in favor of defendants in an action alleging retaliation, defamation, and intentional infliction of emotional distress claims against plaintiff's former employer, Workforce Development and the state of Iowa, as well as against certain former supervisors and coworkers. Plaintiff's claims stemmed from her termination as an ALJ based on allegations that she fraudulently filed insurance enrollment forms and had deliberately falsified her daughter's marital status. Plaintiff alleged that her termination was based on retaliation for her testimony before the Oversight Committee and that the insurance fraud investigation constituted a mere pretext.In regard to the whistleblower retaliation claim, the court concluded that plaintiff failed to present evidence from which a reasonable jury could find that she was suspended or terminated in reprisal for her testimony. In regard to the defamation claim, the court concluded that Defendant Wahlert was entitled to summary judgment with respect to her allegedly defamatory testimony to the Oversight Committee where her testimony and related actions were within the scope of her employment. The court also concluded that plaintiff failed to establish any constitutional violation as to the First Amendment retaliation claim; defendants' conduct was not sufficiently egregious to satisfy the outrageousness prong of the Iowa tort of intentional infliction of emotional distress; and the district court did not err in granting summary judgment on plaintiff's retaliation claim based on the Iowa Constitution's free speech clause. View "Ackerman v. Iowa" on Justia Law

Davis, a former Congressman, mayoral candidate, candidate for governor of Alabama, and federal prosecutor, is Black. In 2016, he became Executive Director of LSA, a non-profit law firm serving low-income Alabamians. Davis experienced problems with some of his subordinates and colleagues; some complained to LSA’s Executive Committee. On August 18, 2017, as Davis left work, he was informed that the Executive Committee had voted to suspend him with pay pending an investigation of those complaints. A “Suspension Letter” cited spending decisions outside the approved budget, failure to follow LSA's hiring policies and procedures, creating new initiatives without Board approval, and creating a hostile work environment for some LSA employees. LSA posted a security guard in front of its building and hired Mowery, an Alabama political consultant, to handle public relations related to Davis’s suspension. Mowery had handled one of Davis’s failed political campaigns until their relationship soured; Mowery had worked for the campaign of Davis’s opponent in another race.Days later, Davis notified the Board of his resignation. He filed suit, alleging race discrimination under 42 U.S.C. 1981 and under Title VII, and defamation. The Eleventh Circuit affirmed summary judgment for the defendants. Being placed on paid leave was not an adverse employment action and Davis did not raise a fact issue on his constructive discharge claim. LSA’s disclosures to Mowery did not constitute “publication”—an essential element of defamation. View "Davis v. Legal Services Alabama, Inc." on Justia Law

Plaintiff-Appellant Viktorya Reznik appealed the district court’s dismissal of her Title VII retaliation action against her former employer, Defendant-Appellee inContact, Inc. (inContact). From January 2018 to May 2019, Reznik worked as a Director of Project Management for inContact, a Utah-based corporation offering cloud-based services to companies using call centers. In April 2019, Reznik received internal complaints about racial slurs in the workplace from two native Filipino employees who worked in the company’s Manila, Philippines office. They claimed that an inContact manager, Scott Mendenhall, had repeatedly subjected them and other native Filipino employees to racial slurs, calling them “monkeys” and “not human.” Mendenhall worked in the same Salt Lake County facility as Reznik. Weeks after Reznik reported the harassment to company management, she was terminated as "not a good culture fit" and "not a good fit." Following Reznik’s termination and administrative exhaustion, she filed her Title VII complaint in federal district court. inContact moved to dismiss and the district court granted the motion. According to the district court, Reznik failed to state a claim because she did not show an objectively reasonable belief that she opposed conduct unlawful under Title VII. Finding Reznik's belief she was opposing conduct unlawful under Title VII was objectively reasonable, the Tenth Circuit reversed the district court's dismissal. View "Reznik v. inContact" on Justia Law

Plaintiffs, formerly employed as deputy sheriffs, filed a 42 U.S.C. 1983 action alleging that defendants violated their First Amendment rights based on Defendant Cole's retaliatory employment actions taken after plaintiffs supported his political opponent. The district court granted defendants' motion for summary judgment and dismissed the complaints.The Eighth Circuit affirmed, concluding that the district court did not err in interpreting Curtis v. Christian County, 963 F.3d 777 (8th Cir. 2020), by concluding that even if plaintiff is a first responder and other provisions of Missouri law protect against discharge for engaging in political activity, because he was a Missouri deputy sheriff, plaintiff was legally terminated and Cole did not violate plaintiff's constitutional rights. The court explained that whether Cole violated plaintiffs' state statutory political activity rights is an inquiry separate from whether he violated their First Amendment rights. The court's conclusion that Cole committed no unconstitutional act necessarily resolves the municipal liability issue involving Christian County and the Christian County Commissioners, sued in their official capacities. Because Cole is entitled to qualified immunity under Curtis, the court did not address plaintiffs' second argument about affirmative defenses. View "Burns v. Cole" on Justia Law

The Community Hospital of the Monterey Peninsula (the Hospital) terminated the employment of registered nurse Kimberly Wilkin (Wilkin) after discovering she had violated the Hospital’s policies governing the handling and documentation of patient medications. Wilkin sued the Hospital, alleging her discharge constituted disability discrimination, retaliation, and otherwise violated the Fair Employment and Housing Act (FEHA); resulted in the unlawful denial of medical leave and retaliation in violation of the Moore- Brown-Roberti Family Rights Act (CFRA); and constituted a wrongful termination in violation of public policy. Over a year after Wilkin filed her complaint, the Hospital moved for summary judgment, producing undisputed evidence, including Wilkin’s deposition testimony, showing she had violated policies governing the handling of medication, and, for over a year before she was discharged, had been regularly counseled for her chronic absenteeism and other issues. The trial court concluded the Hospital carried its burden of producing evidence showing its decision was based on legitimate, nondiscriminatory reasons. After Wilkin did not produce any evidence showing the Hospital’s reasons were fabricated or otherwise pretextual, the trial court concluded a reasonable trier of fact could not find in favor of Wilkin on any of her claims and granted summary judgment in favor of the Hospital. To this, the Court of Appeal affirmed. "As all of Wilkin’s claims depended on there being a triable issue of fact regarding the lawfulness of her discharge, and our record does not show such a triable issue of fact exists, summary judgment was properly granted." View "Wilkin v. Community Hospital of the Monterey Peninsula" on Justia Law

Reinebold, then 56 years old, applied to be the head baseball coach of Indiana University South Bend (IUSB). After IUSB declined to hire Reinebold, he sued IUSB, Athletic Director Bruce, and Assistant Athletic Director Norris under the Age Discrimination in Employment Act (ADEA) and 42 U.S.C. 1983. The district court dismissed all of Reinebold’s claims with his concession except for his section 1983 claims against Bruce and Norris in their individual capacities. The district court then entered summary judgment in favor of Bruce and Norris, finding that Reinebold did not identify a suitable comparator and did not show that he was intentionally treated differently because of his age.The Seventh Circuit affirmed. The hiring committee distinguished Reinebold and his proposed comparator Buysse (age 31) based on their respective performances during their interviews. The evidence shows that Reinebold performed poorly during his phone interview. Buysse performed well. An employer is not required to score a job interview using objective criteria. View "Reinebold v. Bruce" on Justia Law

In this vaccination dispute, the First Circuit denied the motion brought by Appellants seeking an injunction pending appeal, holding that Appellants were not entitled to the injunction.Appellants, eight employees of Mass General Brigham, Inc. (MGB), challenged MGB's application of its mandatory vaccination policy to them individually. The policy was issued in June 2021 requiring all MGB employees to be vaccinated against COVID-19 unless they qualified for a medical or religious exemption. After Appellants' requests for exemptions were denied and they still refused to get vaccinated, MGB placed them on unpaid leave. Appellants sued under Title VII of the Civil Rights Act and the Americans with Disabilities Act, arguing that MGB unlawfully denied their individual exemption requests. The district court denied Appellants' motion for a preliminary injunction, which would have required Appellants' reinstatement from unpaid leave status. The First Circuit denied Appellants' motion for injunction pending appeal, holding that adequate legal remedies foreclosed injunctive relief. View "Together Employees v. Mass General Brigham Inc." on Justia Law

Fried worked as a manicurist, 2005-2017. Fried complained about female manicurists receiving most of the appointments and that other male manicurists also complained. In 2017, Fried became frustrated and threw a pencil at a computer because customers were requesting female manicurists more often than male manicurists. His manager disciplined him and commented that he might want to find other work. He alleges that his coworkers and customers made harassing comments and that he was told to finish a pedicure for a male customer who had solicited him for sex. Fried filed suit under Title VII, 42 U.S.C. 2000e, alleging sex discrimination, retaliation, and hostile environment.The Ninth Circuit reversed the summary judgment against Fried. A reasonable factfinder could decide that Fried’s employer created a hostile work environment. An employer can create a hostile work environment by failing to take immediate and corrective action in response to a coworker’s or third party’s sexual harassment or racial discrimination that the employer knew or should have known about. While comments made by a manager and coworkers on two occasions were insufficiently severe or pervasive to support a hostile work environment claim, an employer’s response to unwelcome sexual advances toward an employee can independently create a hostile work environment. Fried’s manager failed to take immediate corrective action and also directed Fried to return to the customer and complete his pedicure. The district court should reconsider the cumulative effect of the coworkers’ comments. View "Fried v. Wynn Las Vegas, LLC" on Justia Law