Justia Civil Rights Opinion Summaries

The case involves Benjamin Stanley, who was employed by Western Michigan University (WMU) for about a month before his employment was terminated. Stanley, who has severe ADHD, claimed that WMU and certain supervisors discriminated and retaliated against him in violation of the Americans with Disabilities Act (ADA). He also brought a claim under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), as well as a claim for intentional infliction of emotional distress. The district court dismissed Stanley’s federal claims for lack of subject-matter jurisdiction based on Eleventh Amendment immunity and dismissed his state-law claims for failure to comply with the Michigan Court of Claims Act’s notification statute.The district court's dismissal of Stanley's claims was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court’s dismissal of Stanley’s federal claims and the denial of Stanley’s motion for leave to amend his complaint. However, the court vacated the judgment in part and remanded to the district court to dismiss Stanley’s federal and state-law claims without prejudice. The court found that the district court lacked subject-matter jurisdiction to adjudicate Stanley’s ADA claims because the defendants were entitled to Eleventh Amendment immunity, and Stanley lacked standing to request injunctive relief from the individual defendants. The court also found that the district court lacked jurisdiction to decide Stanley’s state-law claims because it lacked subject matter jurisdiction over any federal issues. View "Stanley v. Western Michigan University" on Justia Law

The case involves Sharon Lewis, an African-American woman who worked as an assistant athletic director for Louisiana State University’s (LSU) football team. Lewis alleges that she experienced and witnessed numerous instances of racist and sexist misconduct from former head football coach Les Miles and that she received complaints of sexual harassment from student workers that she oversaw. In 2013, LSU retained Vicki Crochet and Robert Barton, partners of the law firm Taylor, Porter, Brooks & Phillips LLP, to conduct a Title IX investigation of sexual harassment allegations made against Miles. The report and its contents were kept confidential, and allegations brought by the student complainants were privately settled.The district court dismissed Lewis's Racketeer Influenced and Corrupt Organization Act (RICO) claims against Crochet and Barton because Lewis’s claims were time-barred and she failed to establish proximate causation. On appeal of the dismissal order, a panel of this court affirmed the district court on the grounds that Lewis knew of her injuries from alleged racketeering as early as 2013, and thus the four-year statute of limitations had expired before she filed suit in 2021.The district court ordered Lewis to file a motion to compel addressing the lingering “issues of discoverability and the application of [its Crime-Fraud Exception Order].” The district court denied Crochet and Barton’s motion for a protective order and compelled the depositions of Crochet and Barton and the disclosure of documents drafted during the 2013 investigation. Crochet and Barton timely appealed.The United States Court of Appeals for the Fifth Circuit reversed the district court’s Crime-Fraud Exception Order and remanded for proceedings consistent with this opinion. The court concluded that the district court clearly erred in holding that Lewis established a prima facie case that the Board violated La. R.S. 14:132(B) and that the alleged privileged communications were made in furtherance of the crime and reasonably related to the alleged violation. View "Lewis v. Crochet" on Justia Law

The case revolves around an incident involving Michael Miller, a white Correctional Security Operations Supervisor at Chittenden Regional Correctional Facility (CRCF), and a black coworker. Miller asked the coworker if the food he was heating in the microwave was fried chicken, a comment the coworker perceived as racially discriminatory. Following an investigation, the State of Vermont terminated Miller's employment, citing violations of several personnel policies and work rules, including allegations of racial discrimination and harassment.The Vermont Labor Relations Board, however, reversed the State's decision. It found that while Miller's comments were inappropriate and unprofessional, they did not constitute racial discrimination or harassment as defined by the applicable personnel policies. The Board also found that the State failed to prove that Miller was untruthful during the investigation. Consequently, the Board reduced Miller's penalty to a twenty-day suspension.The State appealed the Board's decision to the Vermont Supreme Court, arguing that the Board misinterpreted the meaning of racial discrimination and harassment in the personnel policies. The Supreme Court affirmed the Board's decision, stating that the Board's interpretation of the policies was within its discretion and was supported by analogous definitions under Title VII of the Civil Rights Act of 1964. The Court also noted that the State could amend the language of the policies to more clearly define what constitutes racial discrimination or harassment. View "In re Grievance of Miller" on Justia Law

Leroy Johnson, a supervisor at Westinghouse Air Brake Technologies Corporation (Wabtec), was terminated after failing to fully disclose his contact with a COVID-19 positive individual, violating the company's COVID-19 protocols and a Last Chance Agreement he had signed. Johnson, the only salaried black employee at the plant, sued Wabtec for wrongful termination under the Missouri Human Rights Act (MHRA), Title VII of the Civil Rights Act of 1965, and the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment in favor of Wabtec.The district court's decision was based on the conclusion that Johnson had not established a prima facie case of discrimination. Johnson had argued that he was treated less favorably than similarly situated white employees, but the court found that the employees he cited were not similarly situated as they were not terminated for misconduct. The court also found that Johnson's failure to fully disclose his potential COVID-19 exposure constituted a safety concern and misconduct, which was grounds for termination under the Last Chance Agreement.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that Johnson had not established a prima facie case of discrimination and that his termination was due to his misconduct, not his race or age. The court also noted that Johnson had waived his ADEA claim by failing to address its merits in his opening brief. View "Johnson v. Westinghouse Air Brake Technologies Corporation" on Justia Law

Jeffrey Capen, a former employee of Saginaw County, Michigan, sued the county and Robert V. Belleman, the county's Controller and Chief Administrative Officer, under 42 U.S.C. § 1983. Capen claimed that his procedural due process rights under the Fourteenth Amendment were violated when he was scheduled for two fitness-for-duty evaluations. The evaluations were ordered after a co-worker reported that Capen had threatened to kill other employees. Capen was subsequently placed on paid administrative leave and later terminated for failing to participate in an "interactive process" meeting to identify potential reasonable accommodations for his work, as required by the Americans with Disabilities Act.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the defendants. The court concluded that Capen lacked a constitutionally protected interest, that he received the process he was due, and that Belleman was entitled to qualified immunity.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The appellate court found that Capen's ability to refuse his fitness-for-duty evaluations did not constitute a protected interest under the Due Process Clause. The court noted that while the evaluations were stressful and deeply personal for Capen, he failed to demonstrate that his constitutional rights were violated. The court also observed that compelling circumstances justified the county's decision to require the evaluations, given the reported threats of violence. View "Capen v. Saginaw County, Michigan" on Justia Law

Samantha Howard, a pharmacist with Type I diabetes and hypoglycemic unawareness, began working at Bothwell Regional Medical Center, operated by the City of Sedalia, Missouri. Howard requested to keep food and drink at her desk, which was granted. Later, she requested to bring a service dog into the pharmacy to help her manage her diabetes. Bothwell denied this request, citing potential risks of contamination. Unable to agree on an alternative accommodation, Howard resigned and filed a lawsuit alleging that Bothwell's failure to make a reasonable accommodation violated the Americans with Disabilities Act (ADA). The jury ruled in favor of Howard, awarding her compensatory and emotional damages. Bothwell appealed the district court's denial of its motion for judgment as a matter of law.The United States Court of Appeals for the Eighth Circuit reviewed the denial of a motion for judgment as a matter of law de novo. The court found that the case was governed by its recent decision in Hopman v. Union Pac. R.R., which clarified the definition of "reasonable accommodation" under the ADA. The court concluded that Howard failed to identify any employer-sponsored benefit or program to which she lacked access due to the absence of her service dog. The court ruled that providing a service dog at work so that an employee with a disability has the same assistance the service dog provides away from work is not a cognizable benefit or privilege of employment. Therefore, the court reversed the district court's order and remanded the case with instructions to enter judgment in favor of Bothwell. View "Howard v. City of Sedalia, Missouri" on Justia Law

The case involves Roman Sharikov, an employee of Philips Medical Systems MR, Inc., who was terminated after refusing to comply with the company's COVID-19 health and safety policies, including a vaccination mandate. Sharikov alleged that Philips discriminated against him because it regarded him as having a disability or a record of a disability and retaliated against him after he objected to the measures.The United States District Court for the Northern District of New York dismissed Sharikov's claims, stating that he failed to state a claim upon which relief could be granted. The court found that Philips' company-wide COVID safety and vaccine policies did not infringe on Sharikov's rights under the Americans with Disabilities Act (ADA). The court also concluded that Sharikov failed to plead a plausible retaliation claim because the company-wide policies that he failed to comply with, resulting in the termination of his employment, were in place before he began his alleged protected activity.On appeal, the United States Court of Appeals for the Second Circuit affirmed the lower court's decision. The court agreed that Philips' company-wide COVID-19 health and safety measures did not discriminate against Sharikov under the ADA. The court also found that Sharikov failed to establish a causal connection between his protected activity and his termination, thus failing to state a plausible retaliation claim. View "Sharikov v. Philips Medical Systems MR, Inc." on Justia Law

The case revolves around Yvonne Craddock, an African American woman who was terminated from her employment at FedEx Corporate Services following a workplace altercation. Craddock alleged that her termination was racially motivated, in violation of Title VII of the Civil Rights Act of 1964. The case was presented to a jury, which concluded that FedEx's reason for termination was pretextual, but that Craddock had failed to demonstrate that FedEx intentionally discriminated against her because of her race. Craddock appealed, arguing that the district court had made several errors, including forcing her to bifurcate the liability and damages portions of her trial and excluding testimony and evidence pertaining to events post-termination.The district court had granted FedEx’s motion to dismiss Craddock’s libel claim, Family Medical Leave Act claim, 42 U.S.C. § 1981 claim, and spoliation claim, but denied dismissal of her Title VII claims. After discovery, the court granted FedEx’s motion for summary judgment on Craddock’s Title VII claims. The case was then taken to the United States Court of Appeals for the Sixth Circuit.The Court of Appeals held that the district court did not abuse its discretion regarding the claims raised by Craddock, and affirmed the jury’s verdict. The court found that the district court's decision to bifurcate the trial was not an abuse of discretion, and that the court's exclusion of testimony and exhibits postdating the termination was not erroneous. The court also found no error in the district court's trial rulings and case management decisions, and concluded that the jury verdict form was not plainly erroneous. The court further held that the cumulative effect of the alleged errors did not deprive Craddock of a trial consistent with constitutional guarantees of due process. View "Craddock v. FedEx Corporate Services, Inc." on Justia Law

The plaintiff, Ronald Hittle, was the Fire Chief for the City of Stockton, California. He alleged that he was terminated from his position due to his religion, specifically his attendance at a religious leadership event. The City of Stockton, former City Manager Robert Deis, and former Deputy City Manager Laurie Montes were named as defendants. The City had hired an independent investigator, Trudy Largent, to investigate various allegations of misconduct against Hittle. Largent's report sustained almost all of the allegations, including Hittle's use of city time and a city vehicle to attend a religious event, his failure to properly report his time off, potential favoritism of certain Fire Department employees based on a financial conflict of interest not disclosed to the City, and endorsement of a private consultant's business in violation of City policy.The United States District Court for the Eastern District of California granted summary judgment in favor of the defendants. The court found that Hittle failed to present sufficient direct evidence of discriminatory animus in the defendants' statements and the City's notice of intent to remove him from City service. The court also found that Hittle failed to present sufficient specific and substantial circumstantial evidence of religious animus by the defendants.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court held that employment discrimination claims under Title VII and the California Fair Employment and Housing Act are analyzed under the McDonnell Douglas burden-shifting framework. The court concluded that Hittle failed to present sufficient direct evidence of discriminatory animus in the defendants' statements and the City's notice of intent to remove him from City service. Hittle also failed to present sufficient specific and substantial circumstantial evidence of religious animus by the defendants. The court found that the district court's grant of summary judgment in the defendants' favor was appropriate where the defendants' legitimate, non-discriminatory reasons for firing Hittle were sufficient to rebut his evidence of discrimination, and he failed to persuasively argue that these non-discriminatory reasons were pretextual. View "HITTLE V. CITY OF STOCKTON" on Justia Law

Two employees, Richard Miller and Brent Whitman, filed a lawsuit against the Michigan Department of Corrections (MDOC), alleging they were terminated in retaliation for their close friendship with Cedric Griffey, a deputy warden who was targeted by the MDOC after his wife, Lisa Griffey, filed a complaint and lawsuit against the MDOC for racial harassment. The plaintiffs claimed their termination was a violation of the Elliott-Larsen Civil Rights Act (ELCRA).The Genesee Circuit Court denied the MDOC's motion for summary disposition, which argued that the plaintiffs had failed to state a claim under the ELCRA because they had not personally engaged in any protected conduct. The MDOC appealed this decision, and the Court of Appeals reversed the lower court's ruling, concluding that the ELCRA did not authorize the plaintiffs' claims.The Michigan Supreme Court, however, disagreed with the Court of Appeals. The Supreme Court held that the ELCRA does provide a cause of action for associational or "third party" retaliation claims. The court found that the plaintiffs had sufficiently alleged such a claim, stating that they had a close relationship with Cedric Griffey and that the MDOC took adverse action against them in response to Griffey's protected acts. The court concluded that the plaintiffs' firings were part of the effort to retaliate against Griffey, and thus, they had stated a cause of action under the ELCRA. The Supreme Court reversed the judgment of the Court of Appeals and remanded the case back to the circuit court for further proceedings. View "Miller v. Michigan Department Of Corrections" on Justia Law