Justia Civil Rights Opinion Summaries

The Illinois Public Labor Relations Act allowed public unions to require nonmembers to pay “fair share” or “agency” fees to compensate for the representative services the union provides. In 1977 the Supreme Court concluded that a similar fair-share fees law did not violate nonmembers’ First Amendment rights. In 2018, in “Janus,” the Supreme Court overruled that decision and held that unions compelling the payment of fair share fees from nonmembers offended the First Amendment by compelling nonmembers to subsidize private speech on matters of substantial public concern.”Local 150 represents around 3,300 municipal employees in 133 bargaining units, employing nine staff members at an annual cost of about $5 million. Local 150 remains obligated to represent nonmembers but must now do so without any way of compelling fair share fees. Local 150 filed suit, 42 U.S.C. 1983, alleging that the duty of fair representation in Illinois law without the corresponding ability to collect fair share fees infringes the union’s First Amendment rights of free speech and association.The district court entered summary judgment against the union. The Seventh Circuit vacated and remanded with instructions to dismiss the union’s complaint for lack of subject matter jurisdiction. The union has not alleged any concrete and particular facts showing that it faces a post-Janus freeriding predicament. The court declined to address the substantial legal question in the abstract. View "Sweeney v. Raoul" on Justia Law

Plaintiff filed suit against her former employer, Union Pacific, alleging that Union Pacific violated Title VII of the Civil Rights Act of 1964 by suspending her, and later terminating her, in retaliation for her 2016 lawsuit against the company and her 2018 internal complaint. Plaintiff also alleged that Union Pacific violated the Railway Labor Act (RLA) and the Texas Labor Code (TLC) by retaliating against her because of her requests for union representation. The district court granted Union Pacific's motion to dismiss.The Fifth Circuit reversed the district court's Federal Rule of Civil Procedure 12(b)(6) dismissal of plaintiff's Title VII claim, concluding that she plausibly alleged a causal link between her 2018 internal EEO complaint and her subsequent suspension and termination. However, the court concluded that the district court properly dismissed the RLA claim for lack of jurisdiction, and that plaintiff's RLA claim is preempted by plaintiff's TLC claim. The court affirmed the district court's dismissal of plaintiff's remaining claims. View "Wright v. Union Pacific Railroad Co." on Justia Law

The Supreme Judicial Court held that the ministerial exception did not apply to Plaintiff, an associate professor of social work at a private Christian liberal arts college, and therefore, the superior court judge did not err in dismissing on summary judgment Gordon College's affirmative defense of the ministerial exception in this retaliation complaint.The ministerial exception prohibits government interference with employment relationships between religious institutions and their ministerial employees. Plaintiff, a tenured associate professor of social work at Gordon, alleged that Defendants - Gordon and its president and provost (collectively, Gordon) - unlawfully retaliated against her for her opposition to Gordon's policies and practices regarding LGBTQ+ individuals. The parties cross-moved for summary judgment on the question of whether the ministerial exception barred Plaintiff's claims. The superior court allowed Plaintiff's motion but denied Gordon's, concluding that Gordon was a religious institution but that Plaintiff was not a ministerial employee. The Supreme Judicial Court affirmed, holding that the superior court judge did not err in dismissing the affirmative defense of the ministerial exception. View "DeWeese-Boyd v. Gordon College" on Justia Law

The issue in this case was whether the Washington legislature extended a privilege or immunity to religious and other nonprofit, secular employers and whether, in providing the privilege or immunity, the legislature affected a fundamental right without a reasonable basis for doing so. Lawmakers enacted Washington’s Law Against Discrimination (WLAD) to protect citizens from discrimination in employment, and exempted religious nonprofits from the definition of “employer.” In enacting WLAD, the legislature created a statutory right for employees to be free from discrimination in the workplace while allowing employers to retain their constitutional right, as constrained by state and federal case law, to choose workers who reflect the employers’ beliefs when hiring ministers. Matthew Woods brought an employment discrimination action against Seattle’s Union Gospel Mission (SUGM). At trial, SUGM successfully moved for summary judgment pursuant to RCW 49.60.040(11)’s religious employer exemption. Woods appealed to the Washington Supreme Court, contesting the constitutionality of the statute. SUGM argued RCW 49.60.040(11)’s exemption applied to its hiring decisions because its employees were expected to minister to their clients. Under Our Lady of Guadalupe School v. Morrissey-Berru, 140 S. Ct. 2049 (2020), plaintiff’s employment discrimination claim must yield in a few limited circumstances, including where the employee in question was a minister. Whether ministerial responsibilities and functions discussed in Our Lady of Guadalupe were present in Woods’ case was not decided below. The Supreme Court determined RCW 49.60.040(11) was constitutional but could be constitutionally invalid as applied to Woods. Accordingly, judgment was reversed and the case remanded to the trial court to determine whether SUGM met the ministerial exception. View "Woods v. Seattle's Union Gospel Mission" on Justia Law

The First Circuit affirmed in part and reversed in part the judgment of the district court granting judgment in favor of Plaintiff in this discrimination and retaliation action, holding that Defendant was entitled to judgment as a matter of law in part.Plaintiff filed suit against Abbott Laboratories alleging age discrimination and retaliation under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-34, Puerto Rico Law 100 and Puerto Rico Law 155. A jury found for Plaintiff and awarded $4 million for emotional distress and $250,000 for back pay. The district court entered judgment against Abbott on all counts but reduced the damages to just over $500,000. The First Circuit reversed in part, holding (1) Abbott was entitled to judgment as a matter of law on Plaintiff's ADEA claims and her corresponding claims under Law 100 and Law 115; but (2) Abbott failed to preserve its challenge to a separate finding that Abbott retaliated against Plaintiff for reporting to the State Insurance Fund. View "Gonzalez-Bermudez v. Abbott Laboratories P.R. Inc." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Casco, Inc.'s claim for dolus under Article 1902 of the Puerto Rico Civil Code, P.R. Laws Ann. tit. 31, 3408, awarding relief to Casco on its claims for unjust impairment and unjust termination under Puerto Rico's Dealer Protection Act, P.R. Laws Ann. tit. 10, 278 (Law 75) and granting judgment on John Deere Construction & Forestry Company's counterclaim to recover amounts owed to it by Casco, holding that Casco was not entitled to relief on its allegations of error.Specifically, the First Circuit held (1) the jury's findings of liability against Deere under Law 75 were not unreasonable, and the district court correctly denied Deere's post-judgment motions regarding the Law 75 claims; (2) the district court properly dismissed Casco's dolus claim as not legally viable; (3) the district court correctly granted relief on Deere's counterclaim; and (4) the district court did not abuse its discretion by declining to upset the jury award or order a new trial on damages. View "Casco, Inc. v. John Deere Construction & Forestry Co." on Justia Law

The First Circuit vacated the order of the district court granting summary judgment in favor of Lincare, Inc. and rejecting Jeffrey Joseph's racial discrimination challenge to the termination of his employment, holding that the district court erred in excluding several documents from the summary judgment record and that Joseph had enough evidence to warrant a trial.On appeal, Joseph argued, among other things, that the district court erred in excluding several documents as unauthenticated hearsay evidence and in granting summary judgment. The First Circuit agreed and remanded the case for further proceedings, holding (1) the district court erred in excluding the documents as "unauthenticated and hearsay evidence," and the error was not harmless; and (2) the record, supplemented with the stricken documents, provides a reasonable basis for a jury finding in Joseph's favor. View "Joseph v. Lincare, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment to Gold Medal Bakery, Inc. and dismissing Robert Thompson's claims brought after he was fired, holding that the district court did not err or abuse its discretion.After he was fired, Thompson brought this complaint alleging that Gold Medal terminated his employment in violation of the anti-retaliation provision of the Family and Medical Leave Act (FMLA) and federal and state disability discrimination laws. The district court granted summary judgment to Gold Medal on all claims. The First Circuit affirmed, holding (1) the district court properly determined that, as a matter of law, Thompson could not establish that he was a "qualified individual" under the Americans with Disabilities Act at the time of his firing; (2) the district court did not err in granting summary judgment to Gold Medal on Thompson's FMLA retaliation claim; and (3) Thompson's remaining arguments were unavailing. View "Thompson v. Gold Medal Bakery, Inc." on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Plaintiff's complaint claiming failure to accommodate, gender discrimination, hostile work environment, and retaliation, holding that the circuit court did not err.In dismissing the complaint, the circuit court found that Plaintiff's claims were barred by the doctrine of res judicata because they could have been raised in an earlier lawsuit between the same parties. Plaintiff appealed, arguing (1) she was foreclosed from raising her claims during the earlier proceeding because the deadline for amendments to the pleadings had passed, and (2) the claims were different from those raised in the earlier lawsuit. The Supreme Court affirmed, holding that the circuit court properly found that res judicata was a bar to the litigation of Plaintiff's claims. View "Baker v. Chemours Co. FC, LLC" on Justia Law

After BNSF terminated plaintiff based on violation of company attendance guidelines, plaintiff filed suit alleging that BNSF failed to provide reasonable accommodations for his disability. Plaintiff, who is an epileptic, worked as a train dispatcher for BNSF.The Fifth Circuit affirmed the district court's grant of summary judgment for BNSF, holding plaintiff failed to show that he was a "qualified individual" for either of his failure-to-accommodate claims. In this case, plaintiff failed to show that he could perform the essential functions of his job in spite of his disability or that a reasonable accommodation of his disability would have enabled him to perform the essential functions of the job. View "Weber v. BNSF Railway Co." on Justia Law