Justia Civil Rights Opinion Summaries

The plaintiff, Dania Mateo, filed a case against Davidson Media Group Rhode Island Stations, LLC and several of its employees, which included 22 counts alleging violations of Rhode Island's Fair Employment Practices Act (RIFEPA) and Civil Rights Act (RICRA) as well as claims of sexual harassment, civil conspiracy, intentional infliction of emotional distress, negligent infliction of emotional distress, assault and battery, negligence, false imprisonment, defamation, and conspiracy to commit defamation. The case was pending for nearly 14 years.Mateo appealed a Superior Court decision granting partial summary judgment in favor of certain defendants. The defendants cross-appealed, arguing that the hearing justice erred in granting partial final judgment because he failed to make an express determination that there was no just reason for delay, as required by Rule 54(b) of the Superior Court Rules of Civil Procedure.The Supreme Court of Rhode Island found the defendants’ cross-appeal meritorious. The Court ruled that the hearing justice erred in granting partial final judgment because he failed to determine whether the criteria clearly set forth in Rule 54(b) had been satisfied. The Court held that the judgment must be vacated and the case remanded to the Superior Court for further proceedings. As a result, the Court did not reach the issues raised in the plaintiff's appeal. View "Mateo v. Davidson Media Group Rhode Island Stations, LLC" on Justia Law

In the case before the United States Court of Appeals for the Federal Circuit, the plaintiff, Dr. Leslie Boyer, alleged that a violation of the Equal Pay Act (“EPA”) occurred when the United States government set her pay lower than a male comparator in the same job role. The Court of Federal Claims had granted a summary judgment in favor of the United States, stating that the pay differential was justified by a “factor other than sex,” namely Dr. Boyer’s prior salary. The Court of Federal Claims relied on the pay-setting statutes, 5 U.S.C. § 5333 and 38 U.S.C. § 7408, which allow consideration of prior pay in hiring, to arrive at this conclusion.On appeal, the United States Court of Appeals for the Federal Circuit reversed this judgment, stating that the EPA applies equally to the United States as to other employers and that mere reliance on prior compensation alone is not an affirmative defense to a prima facie case under the EPA unless the employer can demonstrate that the prior pay itself was not based on sex. The court concluded that the employer can only rely on prior pay if either (1) the employer can demonstrate that prior pay is unaffected by sex-based pay differentials or (2) prior pay is considered together with other, non-sex-based factors. The court remanded the case for further proceedings consistent with this interpretation. View "BOYER v. US " on Justia Law

This case involves Aaron Norgren and his father, Joseph Norgren, who worked for the Minnesota Department of Human Services (DHS). Both men filed Title VII discrimination and retaliation claims against DHS, as well as First Amendment retaliation and compelled speech claims against the DHS Commissioner, Jodi Harpstead. These claims stemmed from the denial of the Norgrens' religious exemption requests to workplace trainings on racism and gender identity. The lower court dismissed their complaints for failure to state a claim.Aaron Norgren argued he was denied a promotion due to his protected activities. The court found that Aaron plausibly established his case and reversed the dismissal of his Title VII discrimination and retaliation claims. However, his First Amendment retaliation claim was dismissed due to insufficient evidence of Commissioner Harpstead's personal involvement in the alleged discriminatory practices.Joseph Norgren's Title VII discrimination claim was dismissed as he did not plausibly allege that he was constructively discharged or that Commissioner Harpstead was personally involved. His First Amendment retaliation claim was also dismissed due to insufficient evidence.Both Norgrens' compelled speech claims were dismissed. The court ruled that while the trainings advanced expressive messages that the Norgrens objected to, there was no evidence they were forced to affirmatively agree with any of the statements in the trainings or were threatened with penalties if they expressed their own viewpoints.Therefore, the court reversed the dismissal of Aaron's Title VII discrimination and retaliation claims and affirmed the dismissal of the remaining claims. View "Norgren v. Minnesota Department of Human Services" on Justia Law

In this case, the United States Court of Appeals for the Sixth Circuit was presented with an appeal involving an Ohio hospital's mandate for its employees to get COVID-19 vaccines. The plaintiffs, a group of current and former employees who had requested religious exemptions from the mandate, sued the hospital for religious discrimination under Title VII and Ohio Revised Code § 4112 after the hospital initially rejected all religious exemptions. The district court dismissed the case for lack of subject matter jurisdiction and failure to state a claim, leading to this appeal.The appellate court affirmed the dismissal for the majority of plaintiffs, ruling they lacked standing to sue because they could not demonstrate sufficient injury. However, the court reversed the dismissal for two of the plaintiffs who had resigned after their religious exemption requests were denied but before the hospital changed its policy and granted all religious exemptions. The court held that these two plaintiffs had plausibly alleged that they were forced to resign, or "constructively discharged", and thus had standing to sue.Furthermore, the court found that these two plaintiffs had sufficiently alleged that the hospital failed to provide reasonable accommodations for their religious practices and treated them differently from other employees. Consequently, they had stated plausible claims for relief under Title VII and Ohio Revised Code § 4112. The case was remanded for further proceedings concerning these two plaintiffs. View "Savel v. MetroHealth System" on Justia Law

The case was heard in the United States Court of Appeals for the Fifth Circuit between former Blue Cube employee Elizabeth Cerda and her former employer, Blue Cube Operations, L.L.C. Cerda had been terminated for receiving pay for hours she did not work and threatening to expose her co-workers to COVID-19. She sued Blue Cube under the Family and Medical Leave Act (FMLA) and Title VII of the Civil Rights Act (Title VII). The district court granted summary judgment to Blue Cube, which Cerda appealed.The Appeals Court reviewed the case de novo and affirmed the district court's grant of summary judgment to Blue Cube. The Court found that Cerda failed to provide sufficient evidence for her FMLA claims. She did not adequately notify Blue Cube of her need or intent to take leave beyond her lunch breaks. The Court also dismissed Cerda's FMLA retaliation and Title VII sex discrimination claims due to lack of evidence of pretext. The Court found that Blue Cube had legitimate, non-retaliatory, and non-discriminatory reasons for terminating Cerda's employment.Furthermore, Cerda's Title VII sexual harassment claim was dismissed as she did not provide evidence that the harassment was based on her sex, was severe or pervasive enough to alter the conditions of her employment, or that Blue Cube had knowledge of the conduct. Lastly, the Court found no abuse of discretion in the district court's denial of Cerda's request to reconvene a deposition on a second day. Thus, the judgment of the district court was affirmed. View "Cerda v. Blue Cube Operations" on Justia Law

The plaintiff-Appellant, Kristen King, claimed that her employer, Aramark Services Inc., subjected her to a sex-based hostile work environment, discrimination, and retaliation in violation of the New York State Human Rights Law and Title VII of the Civil Rights Act of 1964. The United States District Court for the Western District of New York dismissed King’s claims. However, the United States Court of Appeals for the Second Circuit affirmed the lower court’s decision on the New York State Human Rights Law claims but vacated the decision on the Title VII claims.The Court of Appeals agreed with the lower court that the impact of Aramark’s alleged discriminatory acts were only incidentally felt in New York. Regarding the Title VII hostile work environment claim, the court found that King’s termination was not only a discrete act supporting a distinct claim for damages, but also part of the pattern of discriminatory conduct that comprises her hostile environment claim. The court held that because King’s termination occurred within the limitations period, the continuing violation doctrine rendered King’s hostile work environment claim timely. Therefore, the court affirmed the lower court’s dismissal of King’s New York State Human Rights Law claims but vacated the dismissal of King’s Title VII claims and remanded the case for further proceedings on those claims. View "King v. Aramark Services Inc." on Justia Law

The plaintiff, Peter Massaro, a police officer with the Fairfax County Police Department, alleged that his employer retaliated against him by transferring him to an inferior position after he filed a complaint about discrimination in promotion practices within the department. He sought relief under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act, and 42 U.S.C. § 1983. The district court granted summary judgment to Fairfax County, dismissing all of Massaro's claims. The court held that Massaro failed to establish a causal connection between his initial discrimination complaint and his subsequent job transfer.Upon appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court ruled that the time gap between Massaro's complaint and his transfer was too long to support a causal inference. It found no evidence that the transfer was a result of a scheme to punish Massaro for his complaint. Instead, the court concluded that Massaro's transfer was a result of his own subsequent behavior that led to a violation of departmental policy.The court also dismissed Massaro's First Amendment claim, ruling that his promotion complaint made via an internal grievance process did not reflect a matter of public concern, and thus did not meet the threshold for First Amendment protection. View "Massaro v. Fairfax County" on Justia Law

John D. Whitfield's application for a job as a Youth Development Specialist with the New York City Administration for Children’s Services (ACS) was rejected. Whitfield alleged that the rejection was discriminatory and violated his First and Fourteenth Amendment rights. He initially challenged the decision in New York State Supreme Court through an Article 78 proceeding, which was dismissed. He then initiated a federal court action, which was also dismissed by the District Court on res judicata grounds. The District Court determined that the state court proceeding was a “hybrid” proceeding where Whitfield could have pursued the claims he raises in the federal action.The United States Court of Appeals for the Second Circuit disagreed, concluding that the state court adjudicated the matter as a pure Article 78 proceeding, not as a hybrid. Therefore, the state court lacked the power to award Whitfield the full scope of relief he now seeks in this action, and the District Court erred by dismissing the amended complaint on res judicata grounds. The judgment of the District Court was vacated and the case was remanded for further proceedings. View "Whitfield v. City of New York" on Justia Law

The case involves a plaintiff, Nafeesa Syeed, an Asian-American woman who sued Bloomberg L.P., alleging employment discrimination. She claimed she was subjected to discrimination due to her sex and race while working for Bloomberg's Washington, D.C. bureau, and was denied promotions for positions she sought within Bloomberg's New York bureau.The United States District Court for the Southern District of New York dismissed her claims under both the State and City Human Rights Laws, stating that she could not show how Bloomberg's conduct impacted her in New York State or City, as she neither lived nor worked there. The court held that the Human Rights Laws applied only to people who live or work in New York.This decision was appealed, and the Second Circuit certified a question to the New York Court of Appeals: whether a nonresident plaintiff not yet employed in New York City or State satisfies the impact requirement of the New York City Human Rights Law or the New York State Human Rights Law if the plaintiff pleads and later proves that an employer deprived the plaintiff of a New York City- or State-based job opportunity on discriminatory grounds.The Court of Appeals held that the New York City and New York State Human Rights Laws each protect nonresidents who are not yet employed in the city or state but who proactively sought an actual city- or state-based job opportunity. The court reasoned that a nonresident who has been discriminatorily denied a job in New York City or State loses the chance to work, and perhaps live, within those geographic areas, and such a prospective inhabitant or employee fits within the Human Rights Laws' protection. The court highlighted that their decision was in line with the policy considerations addressed in the Human Rights Laws, protecting New York institutions and the general welfare of the state and city. View "Syeed v Bloomberg L.P." on Justia Law

This case was brought before the United States Court of Appeals for the Fourth Circuit. The plaintiff, David Duvall, a white man, was terminated from his position as Senior Vice President of Marketing and Communications at Novant Health, Inc. Duvall filed a lawsuit claiming he was fired due to his race and sex, in violation of Title VII of the Civil Rights Act of 1964. A North Carolina jury found in favor of Duvall, awarding him $10 million in punitive damages. Novant Health appealed this decision, arguing that the evidence presented at trial was insufficient to support the jury’s verdict.The evidence presented at trial showed that Duvall performed exceptionally well in his role, receiving strong performance reviews. Despite his performance, Duvall was abruptly fired and replaced by two women, one of whom was a racial minority and rated a lower performer than Duvall. This occurred during a diversity and inclusion initiative at Novant Health, which aimed to achieve racial and gender diversity within its leadership.The Court of Appeals upheld the jury's verdict of liability against Novant Health, finding sufficient evidence to support the claim that Duvall's race, sex, or both were motivating factors in his termination. However, the court vacated the jury's award of punitive damages, concluding that Duvall failed to prove that Novant Health discriminated against him despite perceiving a risk that its actions would violate federal law.The court also upheld the district court's award of back pay and front pay to Duvall, rejecting Novant Health's claim that Duvall failed to reasonably mitigate his damages. The court found that Duvall exercised reasonable diligence in seeking new employment after his termination. The case was remanded for entry of an amended judgment as to punitive damages. View "Duvall v. Novant Health, Inc." on Justia Law