Justia Civil Rights Opinion Summaries

The plaintiff, Tammie Terrell, an African-American nurse, applied for a Chief Nurse position at the James A. Haley Veterans’ Hospital but was not selected. She sued the Secretary of Veterans Affairs under Title VII, alleging race and national-origin discrimination, retaliation, and a discriminatory and retaliatory hostile work environment. The district court granted summary judgment for the Secretary on all counts.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court found that Terrell failed to provide evidence that her race or national origin was a but-for cause of her non-selection or that it tainted the hiring process. The court also found that Terrell did not engage in any protected Equal Employment Opportunity (EEO) activity that could form the basis for a retaliation claim. Furthermore, the court found that Terrell did not provide evidence that she experienced a hostile work environment due to her race, national origin, or EEO activity.Finally, the court affirmed the district court's denial of Terrell's Rule 60(b) motion for relief from judgment, finding that Terrell was attempting to relitigate her case and present evidence that she could have raised at the summary-judgment stage. View "Terrell v. Secretary, Department of Veterans Affairs" on Justia Law

This case involves a dispute over an employer's vicarious liability under the Maine Human Rights Act (MHRA) for an employee's discriminatory behavior towards a customer. The plaintiffs, Tiffany Vargas and Erika Acevedo, alleged that they were subjected to racial discrimination by an employee of Riverbend Management, LLC, at a McDonald's restaurant owned and operated by Riverbend. The employee, Andrew Mosley, used a racial slur against Vargas and Acevedo.The case was initially filed with the Maine Human Rights Commission, which issued a right-to-sue letter, allowing the plaintiffs to commence an action in the Superior Court. Riverbend filed a motion for summary judgment, arguing that it was not vicariously liable for the race discrimination committed by its employee. The court partially granted the motion, entering judgment in favor of Riverbend on the gender discrimination claim but denied summary judgment on the race-discrimination claim.After a bench trial, the court found that while Mosley violated the MHRA when he used a racial slur against Vargas and Acevedo, Riverbend was not vicariously liable for Mosley’s actions. The court relied on both the Restatement (Second) of Agency and the Restatement (Third) of Agency in reaching its conclusion. Vargas and Acevedo appealed this decision.The Maine Supreme Judicial Court affirmed the lower court's judgment. The court applied the Third Restatement's standard for determining an employer’s vicarious liability under the MHRA for an employee’s act of discrimination against a customer. The court found that Mosley's discriminatory act reflected an independent course of conduct "not actuated by a purpose to serve" Riverbend, and therefore, Riverbend was not vicariously liable for Mosley’s conduct. View "Vargas v. Riverben Management LLC" on Justia Law

The case involves Songie Adebiyi, a former Vice President of Student Services at South Suburban College in Illinois, who was terminated in 2019 due to alleged performance issues. Adebiyi claimed that her termination was in retaliation for filing a charge with the United States Equal Employment Opportunity Commission and the Illinois Department of Human Rights. She sued the college and its president, alleging racial discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964, as well as breach of contract.The United States District Court for the Northern District of Illinois granted summary judgment to the college and its president, ruling that Adebiyi failed to show a causal link between her charge of discrimination and her termination. The court found that the evidence did not support Adebiyi’s retaliation claim. Adebiyi appealed the decision, arguing that the district court erred in dismissing her Title VII retaliation claim and abused its discretion when it denied her motion to amend the complaint and seek more discovery.The United States Court of Appeals for the Seventh Circuit affirmed the judgment of the district court. The appellate court agreed with the lower court's finding that Adebiyi failed to demonstrate a causal link between her protected activity and the adverse employment action. The court found no evidence of pretext in the college's reasons for termination or suspicious timing between Adebiyi's filing of her EEOC and IDHR charge and her termination. The court also found no abuse of discretion in the district court's denial of Adebiyi's motion to file an amended complaint and take additional discovery. View "Adebiyi v. South Suburban College" on Justia Law

Sergeant Jatonya Clayborn Muldrow, a police officer in the St. Louis Police Department, alleged that she was transferred from her position in the Intelligence Division to a uniformed job in another department because of her gender. Despite maintaining her rank and pay, Muldrow's responsibilities, perks, and schedule were significantly altered. She filed a Title VII suit against the City of St. Louis, claiming that the transfer constituted sex discrimination with respect to her employment terms and conditions.The District Court granted the City summary judgment, and the Eighth Circuit affirmed, holding that Muldrow had to show that the transfer caused her a "materially significant disadvantage." The courts ruled that since the transfer did not result in a reduction to her title, salary, or benefits and only caused minor changes in working conditions, Muldrow's lawsuit could not proceed.The Supreme Court of the United States disagreed with the lower courts' interpretation of Title VII. The Court held that an employee challenging a job transfer under Title VII must show that the transfer brought about some harm with respect to an identifiable term or condition of employment, but that harm need not be significant. The Court rejected the City's arguments based on statutory text, precedent, and policy, and vacated the judgment of the Eighth Circuit, remanding the case for further proceedings under the correct Title VII standard. The Court clarified that Muldrow only needed to show some injury respecting her employment terms or conditions, not that the harm was significant. View "Muldrow v. City of St. Louis" on Justia Law

The case involves Marcus Anderson and Reed Clark, current and former employees of Harris County, who allege that Constable Christopher Diaz violated their First Amendment rights. They claim that Diaz instituted reforms to ensure his re-election, which included requiring employees to work on his campaign and retaliating against those who impeded campaign functions. The plaintiffs assert that Diaz had final authority over employment decisions and that his actions resulted in various adverse employment actions, ranging from transfer to termination.The plaintiffs initiated a suit against Diaz and Harris County under 42 U.S.C. § 1983, claiming Diaz violated their First Amendment rights. Harris County filed a motion to dismiss, which the district court granted, finding that Diaz was not a policymaker for Harris County. The district court dismissed all claims against the county with prejudice. Two years later, the district court issued a final judgment regarding the claims against Harris County, allowing the plaintiffs to appeal.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court agreed with the lower court's finding that Diaz, as a constable of a single precinct, was not a final policymaker for Harris County. The court also rejected the plaintiffs' alternative argument that Harris County was liable for Diaz's employment decisions under a delegation or rubber-stamp theory. The court concluded that the plaintiffs failed to show that the alleged First Amendment violations were the result of an official county policy, and therefore, their claims against Harris County were dismissed. View "Anderson v. Harris County" on Justia Law

The case revolves around Lori Vogt, a deputy court clerk, who was fired by Lisa Rodebush, the McIntosh County Court Clerk, for not publicly supporting Rodebush's reelection campaign. Vogt had worked with Rodebush for thirteen years and had supported her in the past. However, during the 2020 reelection campaign, Vogt's best friend, a former employee of the County Court Clerk’s Office, ran against Rodebush. Vogt decided to support Rodebush privately but not publicly to maintain her friendship with Rodebush's opponent. Despite this, Vogt campaigned for Rodebush and provided advice for her campaign. Rodebush, however, was not satisfied with Vogt's level of support and eventually fired her after winning the election. Vogt then filed a lawsuit alleging that Rodebush violated her First Amendment rights of free speech and political affiliation.The United States District Court for the Eastern District of Oklahoma denied Rodebush's motion for summary judgment, where she asserted qualified immunity. Rodebush appealed this decision.The United States Court of Appeals for the Tenth Circuit affirmed the lower court's decision. The court found that a public official cannot condition a subordinate’s employment on her political beliefs, affiliation, or non-affiliation, unless the government has a vital interest in doing so. The court held that Rodebush violated Vogt's First Amendment right to political affiliation by firing her for not publicly supporting her reelection campaign. The court also found that Vogt's right was clearly established at the time of the violation, thus defeating Rodebush's claim of qualified immunity. View "Vogt v. McIntosh County Board" on Justia Law

Two campus police officers at Shepherd University, Jay Longerbeam and Donald Buracker, were terminated due to alleged "misconduct" and "unprofessionalism" during two incidents in 2018 and 2019. The officers claimed that their termination was a result of age and disability discrimination, retaliation under the West Virginia Human Rights Act (HRA), violation of the West Virginia Whistle-blower Law, and common law wrongful discharge. The Circuit Court of Jefferson County granted summary judgment against both officers on all claims.The officers appealed the decision, arguing that the lower court erred in finding no genuine issues of material fact and in its handling of the burden-shifting paradigm. They contended that their conduct during the incidents was legally proper and that the court failed to consider intervening acts of reprisal which were more temporally proximate to their protected activity than their discharge.The Supreme Court of Appeals of West Virginia found that the lower court erred in its handling of the "temporal proximity" issue and the burden-shifting paradigm. The court also found that the officers offered more than sufficient evidence upon which a rational trier of fact could find retaliatory motivation. Therefore, the court reversed the lower court's grant of summary judgment as to the officers’ whistle-blower and Harless claims and remanded for further proceedings. However, the court affirmed the lower court's grant of summary judgment as to Buracker’s HRA disability discrimination claim, finding his evidence insufficient to create an inference of disability discrimination. View "Jay Longerbeam v. Shepherd University" on Justia Law

A Black woman, Erika Buckley, filed a lawsuit against the Secretary of the Army, alleging that her former colleagues at Martin Army Hospital engaged in conduct that was racially discriminatory. Buckley, a speech pathologist, claimed her colleagues diverted white patients from her care, encouraged white male patients to complain about her, and engaged in other race-based harassing conduct. The Secretary moved for summary judgment, which the district court granted on all counts. Buckley appealed this decision.The United States Court of Appeals for the Eleventh Circuit upheld the lower court's decision regarding Buckley's retaliation claims, but vacated the lower court's decision on her race-based disparate treatment claim and her race-based hostile work environment claim. The court found that Buckley had provided enough evidence to suggest that her race played a role in the decision-making process leading to her dismissal, even if her race was not the but-for cause of the dismissal. The court also concluded that Buckley had provided sufficient evidence to establish a hostile work environment claim. The case was sent back to the district court for further proceedings consistent with the appeals court's opinion. View "Buckley v. Secretary of the Army" on Justia Law

In a case before the United States Court of Appeals for the Eleventh Circuit, Tyler Copeland, a transgender male, sued his employer, the Georgia Department of Corrections (GDOC), for workplace harassment. Copeland was a sergeant at a prison in Georgia and alleged that, after coming out as transgender at work, he endured constant and demeaning harassment from colleagues at various levels, despite repeated complaints to supervisors and HR personnel.He brought three claims under Title VII of the Civil Rights Act of 1964. The first was that his employer had created a hostile work environment. The district court granted summary judgment in favor of GDOC, concluding that the harassment Copeland experienced was not sufficiently severe or pervasive. However, the appellate court disagreed and vacated the summary judgment on this claim.The second claim was that Copeland had been denied promotion due to his transgender status. The district court also granted summary judgment on this count, as Copeland failed to provide evidence that those who decided not to promote him were aware of his protected conduct. The appellate court affirmed this decision.The third claim was that GDOC had retaliated against Copeland for engaging in a protected practice, namely opposing sex discrimination. The district court granted summary judgment on this count as well, and the appellate court affirmed the decision, citing lack of evidence of causation.In summary, the appellate court vacated the district court's grant of summary judgment on the hostile work environment claim but affirmed the summary judgments on the failure to promote and retaliation claims. The case was remanded for the district court to consider the fifth element of Copeland’s hostile work environment claim. View "Copeland v. Georgia Department of Corrections" on Justia Law

In this case, the plaintiff, Jason Schwebke, brought a lawsuit against his employer, United Wholesale Mortgage (UWM), alleging disability discrimination under state and federal law. Schwebke, who is deaf, claimed that UWM failed to provide him with necessary accommodations and retaliated against him. In response, UWM participated in extensive discovery procedures for several months without invoking its right to arbitration as per the parties' employment agreement.Seven months into the case, UWM moved to compel arbitration. The district court denied this motion, reasoning that UWM had implicitly waived its right to compel arbitration through its conduct. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision.The appellate court applied the principle from the Supreme Court's decision in Morgan v. Sundance, Inc., which held that a party may waive its contractual right to arbitrate by participating in litigation. In applying this rule, the court found that UWM's actions—participating in extensive discovery, failing to raise arbitration in its defense, and not moving to compel arbitration until seven months into the case—were completely inconsistent with reliance on the arbitration agreement. The court therefore concluded that UWM had implicitly waived its right to arbitration. View "Schwebke v. United Wholesale Mortgage LLC" on Justia Law