Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court dismissing Plaintiff's claims against Activate Healthcare, LLC under W. Va. R. Civ. P. 12(b)(6), holding that the circuit court did not err in concluding that Plaintiff's factual allegations against Activate were insufficient to establish a claim of aiding and abetting under the West Virginia Human Rights Act.Plaintiff was working at Constellium Rolled Products Ravenswood, LLC when she requested a change in her duties to accommodate her medical condition. Plaintiff was directed to Activate, Constellium's on-site medical provider, for a physical activity report, but Activate issued more than one report. Constellium terminated Plaintiff based on one of the reports and later returned to work. After Plaintiff unsuccessfully filed a grievance seeking lost wages during her break in employment she sued Constellium, Activate, and other defendants, alleging retaliation and discrimination. The circuit court dismissed Plaintiff's aiding and abetting claim against Activate for failure to state a claim. The Supreme Court affirmed, holding that nothing in the complaint could be construed to establish the elements of an aiding and abetting claim. View "Boone vs. Activate Healthcare, LLC" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the Commission in an action brought by plaintiff, alleging that the Commission discriminated against her in violation of Title VII. Plaintiff argues that her suspension, probation, and termination were discrimination based on race and national origin. The Commission stated that plaintiff's termination was due to failure to comply with requests to provide company passwords to agency programs and documents. The court concluded that plaintiff did not show evidence of pretext or that she could satisfy the McDonnell Douglas burden-shifting framework before the district court or in her opening brief, and thus she cannot prove a circumstantial case of discrimination. View "Towery v. Mississippi County Arkansas Economic Opportunity Commission, Inc." on Justia Law

Plaintiffs, four Black firefighters who suffer from a skin condition that causes pain and sometimes scarring when they shave their facial hair, filed suit alleging that the FDNY discriminated against them in violation of the Americans with Disabilities Act (ADA), Title VII of the Civil Rights Act of 1964, and various other laws. Plaintiffs' claims stemmed from the FDNY's refusal to offer them a medical accommodation to the department's grooming policy. The policy requires firefighters to be clean shaven in the areas where an oxygen mask or "respirator" seals against their skin.The Second Circuit reversed the district court's grant of summary judgment in favor of plaintiffs on their ADA claim, holding that the OSHA regulation, 29 C.F.R. 1910.134(g)(1)(i)(A), unambiguously prohibits plaintiffs' proposed accommodation and that a binding federal regulation presents a complete defense to an ADA failure-to-accommodate claim. Furthermore, plaintiffs waived the issue of alternative accommodation because they failed to raise it until their reply brief on appeal. The court also concluded that plaintiffs' Title VII disparate impact claim mirrors their ADA claim and meets a similar fate. The court explained that, although plaintiffs have made a prima facie case, the FDNY has conclusively rebutted that case by showing that complying with the respiratory-protection standard is a business necessity. Just as in the ADA context, the court concluded that Title VII cannot be used to require employers to depart from binding federal regulations. Nor can the court agree with plaintiffs that the FDNY's failure to consistently enforce the respiratory-protection standard means that complying with the regulation is not a business necessity. Accordingly, the court affirmed in part and reversed in part. View "Bey v. City of New York" on Justia Law

After Houston Methodist fired plaintiff following a job candidate's allegation that he had sexually harassed him, plaintiff filed suit against Houston Methodist for sex discrimination, retaliation, and race discrimination under Title VII.The Fifth Circuit affirmed the district court's dismissal of the sex discrimination and retaliation claims because plaintiff failed to exhaust his administrative remedies. In this case, plaintiff failed to establish that he satisfied the EEOC verification requirements for a charge. The court also affirmed the district court's grant of summary judgment on the race discrimination claim where plaintiff failed to show that he was replaced or that a comparator received more favorable treatment. View "Ernst v. Methodist Hospital" on Justia Law

The Fourth Circuit held that "job sharing" a single full-time position with a willing partner does not qualify as a reasonable accommodation that an employer must provide under the Americans with Disabilities Act (ADA). The court explained that, if the job share in question did not exist at the time it was proposed as an accommodation, the ADA does not require the employer to create the new position to accommodate a disabled employee.In this case, the court concluded that providing plaintiff with the job share position with another employee was not a reasonable accommodation required by the ADA—not because the position was not "vacant" but because the position she sought did not exist. Therefore, summary judgment should have been granted to Sanofi on plaintiff's failure-to-accommodate claim on this ground. Furthermore, because plaintiff failed to demonstrate the existence of a reasonable accommodation, Sanofi cannot separately be liable for failing to engage in the interactive process. Accordingly, the court affirmed the district court's grant of summary judgment in favor of Sanofi. View "Perdue v. Sanofi-Aventis U.S., LLC" on Justia Law

The Eighth Circuit affirmed the district court's judgment following a jury verdict in favor of the City on plaintiff's claim of hostile work environment based on religion. At issue is whether the district court abused its discretion in precluding plaintiff from introducing testimony and a report by the City's retained but non-testifying expert psychiatrist who had conducted an independent medical examination of plaintiff.The court concluded that the expert's report would have been cumulative with other testimony regarding causation and damages, and any discussion of damages was immaterial because the jury never reached that issue. Therefore, the exclusion did not result in fundamental unfairness in the trial of the case, and the court need not consider whether the district court abused its substantial case management and discovery discretion in excluding the expert's independent medical examination report and testimony, an issue the court has not previously addressed. View "Cooper v. City of St. Louis, Missouri" on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Defendant in this case alleging a violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., holding that genuine issues of material fact precluded summary judgment.Plaintiff, who was Black, sued Bridgewater State university's Board of Trustees and Office of Equal Opportunity and a University administrator (collectively, Defendants) alleging that she was not hired for a University position because of her race. The district court granted summary judgment in favor of Defendants. The First Circuit reversed, holding that Plaintiff's aggregate package of proof sufficed to survive Defendants' motion for summary judgment. View "Taite v. Bridgewater State University" on Justia Law

Taylor was fired from his job as a Cook County Sheriff’s officer. He sued the Sheriff’s Office under Title VII of the Civil Rights Act and Ways, Whittler, and Ernst under 42 U.S.C. 1983 for violating the Equal Protection Clause. The defendants maintain that Taylor was terminated for having fired pellets with an air rifle at his neighbor, a charge that Taylor denies. Ernst was the lead investigator assigned to Taylor’s case. Taylor offered evidence that Ernst engineered his firing based on racial animosity. Taylor also asserted that Ways and Whittler, Sheriff’s Office officials, are liable because they reviewed Ernst’s final report and endorsed his recommendation of termination.On interlocutory appeal, the Seventh Circuit upheld the denial of qualified immunity as to Ernst. Taylor presented evidence of Ernst’s significant role in the investigative and disciplinary proceedings that brought about Taylor’s termination. Any reasonable official in Ernst’s position would have known that intentional racial discrimination toward another employee was unconstitutional and what Taylor alleges against Ernst is textbook racial discrimination: the word “n****r,” used by Ernst, a white man, aimed at Taylor on several occasions. The court reversed the denials of qualified immunity to Ways and Whittler; evidence that they played key roles in approving Ernst’s termination does not signal that either harbored any racial animus or that they knew or suspected that Ernst was motivated by race. Taylor’s Title VII claim remains pending. View "Taylor v. Ernst" on Justia Law

The First Circuit reversed the order of the district court excluding two documents from the summary judgment record and granting summary judgment for Defendant on all of Plaintiff's claims, holding that the district court erred in excluding the two documents from the summary judgment record.Defendant terminated Defendant's employment after he had been employed for thirty-three years. Plaintiff brought this lawsuit alleging wrongful termination of his employment under state law and age discrimination under federal and state law. Defendant moved to strike two of Plaintiff's documents on the grounds that they had been produced after the discovery cut-off date and that they were not properly authenticated. The district court granted the motion to strike the documents and then granted Defendant's motion for summary judgment. The First Circuit reversed the order excluding the documents and vacated the entry of summary judgment, holding that the court erred in striking the documents and that material issues of fact precluded summary judgment. View "Zampierollo-Rheinfeldt v. Ingersoll-Rand de Puerto Rico, Inc." on Justia Law

Jackson, an African American woman, was GCRC's Human Resources Director. Daly, GCRC’s chief administrative officer, was Jackson’s supervisor. There were pending internal discrimination complaints when Jackson started, including a complaint by African American employees about Bennett. Jackson ultimately negotiated a severance agreement with Bennett. A second issue involved McClane’s complaints about Williams, GCRC’s finance director, who subsequently resigned. Jackson was also responsible for approving Equal Employment Opportunity Plans submitted by vendors and contractors. Jackson realized that several vendors’ EEOPs had expired and became concerned that some GCRC directors were conducting business with vendors before their EEOPs were approved. Jackson implemented several changes in GCRC’s EEOP approval process. Several employees, vendors, board members, and union representatives complained to Daly about Jackson’s “abrasiveness” and communication style. Other employees reported having good experiences with Jackson. Daly fired Jackson without giving a reason other than she was an at-will employee. Jackson filed a retaliation claim under Title VII of the Civil Rights Act and Michigan’s Elliot-Larsen Civil Rights Act. The district court granted GCRC summary judgment.The Sixth Circuit reversed. Jackson engaged in protected activity and there remains a genuine factual dispute as to causation. Jackson’s actions could reasonably be viewed as steps to ensure there was no discrimination in hiring both within GCRC and among its vendors, and were protected activity under Title VII. A reasonable juror could find that Jackson has established a prima facie case of causation through circumstantial evidence including the temporal proximity between Jackson’s protected activity and termination. View "Jackson v. Genesee County Road Commission" on Justia Law