Justia Civil Rights Opinion Summaries

The Supreme Court conditionally granted mandamus relief in this arbitration dispute, holding that the trial court abused its discretion in determining that pre-arbitration discovery was warranted in this case.After Plaintiff's employment was terminated she sued Defendant, her former employer, claiming discrimination and retaliation. Defendant moved to compel arbitration pursuant to the company's employee handbook acknowledgment and agreement, which contained an arbitration agreement. At issue was Plaintiff's second motion to compel pre-arbitration discovery claiming that an enforceable arbitration agreement did not exist. After the trial court granted the motion Defendant sought mandamus relief. The court of appeals denied the motion. The Supreme Court conditionally granted mandamus relief, holding that the trial court clearly abused its discretion in ordering pre-arbitration discovery because Plaintiff failed to provide the trial court with a reasonable basis to conclude that it lacked sufficient information to determine whether her claims were arbitrable. View "In re Copart, Inc." on Justia Law

Plaintiff treated children in the pediatric intensive care unit of a hospital owned by VHS under his professional services agreement with PICCS, which itself operated under a separate coverage agreement with VHS. After PICCS terminated plaintiff, he filed suit alleging claims of race discrimination under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. 1981. The district court granted summary judgment dismissing plaintiff's claims against VHS.The Fifth Circuit affirmed the district court's partial final judgment, concluding that plaintiff's Title VII claim fails for lack of an employment relationship with VHS under either integrated-enterprise or joint-employment theories. The court also concluded that plaintiff's section 1981 claim fails because he cannot identify an impaired contractual right enforceable against VHS. In this case, plaintiff failed to show any contractual right enforceable against VHS under his physician agreement. View "Perry v. VHS San Antonio Partners, LLC" on Justia Law

Plaintiffs, two Maryland public school teachers, filed suit under 42 U.S.C. 1983, alleging claims against the union defendants, a county school system, and various public officials, seeking relief for themselves and other non-union Maryland public school teachers who were compelled to pay "representation fees" to unions in order to be employed as Maryland public school teachers. Specifically, plaintiffs seek a refund of representation fees that they paid to the unions prior to the Supreme Court's decision in Janus v. American Federation of State, County, & Municipal Employees, Council 31, 138 S. Ct. 2448 (2018). In Janus, the Supreme Court decided that requiring non-union employees to pay representation fees to public-sector unions contravenes the First Amendment.The Fourth Circuit affirmed the district court's dismissal of the action based on failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). Assuming without deciding that Janus is entitled to retroactive application, the court agreed with its six sister circuits and recognized that the good-faith defense is available to a private-party defendant under section 1983; union defendants are entitled to utilize the good-faith defense with respect to plaintiffs' Janus claim; and defendants are not required to refund the representation fees that plaintiffs paid to the union defendants prior to the Janus decision. In this case, because plaintiffs are unable to point to any identifiable fund in the union defendants' possession, the court followed the reasoning of the Sixth and Seventh Circuits and concluded that, in substance, plaintiffs' claim for relief is a claim for damages. Therefore, the union defendants are entitled to interpose the good-faith defense against that claim. Finally, the court rejected plaintiffs' contention that the good-faith defense is not available to the union defendants because it was not recognized as a defense to the most closely analogous tort — the tort of conversion — in 1871 when Congress enacted section 1983. Rather, abuse of process most closely corresponds to the union defendants' use of a Maryland statute to collect representation fees from non-union teachers, like plaintiffs. View "Akers v. Maryland State Education Ass'n" on Justia Law

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