Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the order of the superior court dismissing Plaintiff's complaint alleging that Defendant, Rhode Island Public Transit Authority (RIPTA), failed to compensate her for past workplace injuries, holding that the trial justice properly dismissed the complaint.The trial justice found that the superior court did not have jurisdiction over certain claims because they were committed to the Workers' Compensation Court, that Plaintiff did not properly articulate other claims, and that the complaint failed adequately to inform Defendant of the nature of Plaintiff's claims. The Supreme Court affirmed, holding that Plaintiff's claims on appeal were without merit. View "Barnes v. Rhode Island Public Transit Authority" on Justia Law

Knudtson worked for Trempealeau County for over 45 years. She eventually became a paralegal/office manager in the District Attorney’s Office. When his friend, the Jackson County District Attorney, died, McMahon, the Trempealeau County District Attorney, closed his office for a day and encouraged his staff to attend the funeral. Knudtson refused to attend because she wanted to complete work at the office. McMahon offered Knudtson three choices: work from home, attend the funeral, or take a vacation day. The disagreement became a bitter dispute. The County placed Knudtson on paid leave. Knudtson declined another position at the same pay grade. The County had no other available position and terminated her employment.Knudtson filed suit, citing the Establishment Clause because the funeral took place at a church and involved a religious service. The Seventh Circuit affirmed summary judgment in favor of the defendants. Knudtson acknowledged that when she stated that she did not want to attend the funeral, she did not know that it would be a religious service; her decision not to attend had nothing to do with its religious nature. Organizing a delegation from a public office to attend a funeral normally raises no implication that the government, or any officials, endorse the deceased person's religion. View "Knudtson v. Trempealeau County" on Justia Law

Williams, a Chicago school social worker, suffers from depression, anxiety, and chronic sinusitis. For the 2013–14 school year, Williams received an evaluation score that placed him in the “developing” category, and was given a Professional Development Plan. Social workers' hours depend on the school they are serving on a particular day. The Board denied Williams's first accommodation request, for consistent work hours. During the 2014–15 school year, Williams was cited for interrupting a teacher, failing to read a student’s individual educational plan before a meeting, speaking inappropriately about his personal life, making personal calls during school hours, and failing to report to work. Williams was twice denied titles that may be awarded to “proficient” social workers. Williams filed a discrimination charge and another accommodation request, seeking a consistent start time, a reduced caseload, and assignment to a single school. The Board denied these requests but assigned him to schools with 7:45 a.m. start times. Williams's third accommodation request sought a private office, dedicated equipment, and exemption from evaluations. The Board supplied Williams with HEPA filters, computer monitors, and access to a private meeting space; it denied his other requests. Williams was not selected for special assessment teams because he did not have the “proficient” rating and was not bilingual. He filed his second charge of discrimination.The Seventh Circuit affirmed the dismissal of his suit under the Americans with Disabilities Act. 42 U.S.C. 12101, and Title VII, 42 U.S.C. 2000e, rejecting claims that the Board discriminated against Williams because of his disability and gender, failed to accommodate his disability, and retaliated against him for filing discrimination claims. View "Williams v. Board of Education of the City of Chicago" on Justia Law

Plaintiff filed suit against her former employer, UMC, alleging age discrimination in violation of the Age Discrimination in Employment Act of 1967 (ADEA). Plaintiff claimed that she and several other elderly employees were fired and replaced by younger respiratory therapists, whom UMC paid at a lower rate. Both parties agreed that plaintiff demonstrated a prima facie case of age discrimination and that UMC articulated a legitimate, non-discriminatory basis for her termination.The Fifth Circuit affirmed the district court's judgment in favor of UMC, holding that plaintiff failed to adduce sufficient evidence to create a genuine dispute over the veracity of UMC's proffered reasons for plaintiff's discharge. In this case, UMC's articulated reasons for plaintiff's termination were her poor performance and demonstrated lack of effort to change her behavior. The court concluded that plaintiff failed to present sufficient evidence to create doubt as to whether this reason was a mere pretext for discrimination. View "Salazar v. Lubbock County Hospital District" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendant's motion for judgment as a matter of law and dismissing Plaintiff's claim that she was fired from her position because of her age, holding that Plaintiff's claims were without merit.After she was discharged, Plaintiff brought suit in the federal district court pursuant to the Age Discrimination in Employment Act, 29 U.S.C. 623(a)(1). Plaintiff also asserted a number of supplemental claims under Puerto Rico law. At trial, once Plaintiff rested, Defendant moved for judgment as a matter of law. The district court granted the motion. The First Circuit affirmed, holding that the district court (1) did not contradict the law of the case doctrine when it excluded certain evidence at trial; (2) did not abuse its discretion in refusing to admit the evidence at trial; and (3) did not err in entering judgment as a matter of law. View "Daumont-Colon v. Coop de Ahorro y Cred Caguas" on Justia Law

Plaintiff appealed the district court's grant of summary judgment to Selig on her claims under the Americans with Disabilities Act (ADA) and the Family and Medical Leave Act (FMLA).The Eleventh Circuit reversed the district court's grant of summary judgment on plaintiff's claim of retaliation under the FMLA where a reasonable jury could find that plaintiff suffered retaliation for intending to use FMLA leave in the future. In this case, there are a number of factual disputes that are material to plaintiff's FMLA retaliation claim and thus summary judgment was not appropriate. However, the court affirmed in all other respects, holding that plaintiff is not disabled under the ADA and that plaintiff has not identified any evidence that she was terminated as a result of Selig's failure to give her notice of her FMLA rights. The court remanded for further proceedings. View "Munoz v. Selig Enterprises, Inc." on Justia Law

The Second Circuit affirmed the district court's grant of summary judgment to the New York City Department of Education and a school principal in an action brought by plaintiff, alleging a claim of First Amendment retaliation and Title VII claims of a sex-based hostile work environment and retaliation.The court concluded that plaintiff's speech consisted of grievances about employment disputes that are not matters of public concern, and therefore his speech was not protected against retaliation by the First Amendment. Even if some of plaintiff's speech were so protected, the court concluded that the district court still would have been correct to grant qualified immunity to the principal. Furthermore, the district court correctly concluded that plaintiff's Monell claim against the Department of Education fails because the principal was not a policymaker, and thus plaintiff cannot identify any municipal policy that allegedly caused a constitutional violation. The court also concluded that summary judgment was properly granted on plaintiff's Title VII claims. The court explained that plaintiff's sex-based hostile work environment claim fails because the principal's actions were not sufficiently severe or pervasive to alter the terms of plaintiff's employment. Finally, the retaliation claim also fails because there is insufficient evidence of a causal link between plaintiff's protected activity and the alleged retaliatory acts. View "Agosto v. New York City Department of Education" on Justia Law

The Court of Appeal affirmed the trial court's judgment denying plaintiff's request for leave to amend and granting Aerospace's motion for summary judgment, in an action alleging that plaintiff was selected for a company-wide reduction in force (RIF) because of his age.The court held that the trial court did not abuse its discretion in denying leave to amend. In this case, plaintiff's original and first amended DFEH complaints cannot support class and disparate impact theories of recovery, and thus the new allegations in his second amended DFEH complaint are untimely. As a result, plaintiff cannot show he exhausted his administrative remedies with respect to his proposed class and disparate impact claims. The court also held that the trial court did not err in granting Aerospace's motion for summary judgment where the trial court properly sustained Aerospace's objections to certain exhibits and plaintiff failed to create a triable issue of fact to withstand summary judgment. Aerospace submitted evidence showing it instituted the company-wide RIF after learning it faced potentially severe cuts to its funding, and plaintiff failed to offer substantial evidence showing that Aerospace's reasons were untrue or pretextual. View "Foroudi v. The Aerospace Corp." on Justia Law

Vargas began working as a mail carrier in 2005. Mail carriers must be able to carry up to 35 pounds in their shoulder bags. Vargas’s route also required shuttling mail and equipment weighing up to 75 pounds between the post office and a satellite location. Vargas sustained an on-the-job foot injury in 2008. He was diagnosed with plantar fasciitis, received treatment, submitted a successful workers’ compensation claim, and continued working. In 2011, Vargas filed an EEO complaint, raising miscellaneous workplace grievances and alleging race- and disability-related discrimination. He withdrew this complaint. Vargas’s plantar fasciitis subsequently flared up. His doctor placed him on work restrictions, March 1-22, prohibiting him from carrying more than 15 pounds. On March 14, Vargas returned to work from a vacation; he wanted his route restructured to eliminate carrying heavy loads. His superiors did not oblige and he applied for workers’ compensation. He also made daily requests for “light duty” but there was no light duty work available, so he took paid sick leave.Vargas, who is Hispanic, sued, alleging disability-based discrimination under the Americans with Disabilities Act, with retaliation and racial discrimination claims under Title VII. Vargas still works for the Postal Service. The Seventh Circuit affirmed summary judgment rejecting his claims. Vargas could not perform the only job available to him, with or without reasonable accommodation, and there is no evidence he was treated differently because of his race or suffered unlawful workplace retaliation. View "Vargas v. DeJoy" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court denying the plea to the jurisdiction filed by Defendant, a governmental employer, and dismissed Plaintiff's age-discrimination claim for lack of jurisdiction, holding that the Texas Commission on Human Rights Act did not waive Defendant's sovereign immunity from this suit.Plaintiff sued for age discrimination. Defendant filed a plea to the jurisdiction. The trial court denied the plea, and the court of appeals affirmed. The Supreme Court reversed, holding (1) Plaintiff failed to submit legally sufficient evidence to establish a prima facie case of discrimination; and (2) because the legislature has not waived governmental immunity in the absence of such evidence, Plaintiff's age-discrimination claim must be dismissed for lack of jurisdiction. View "Texas Tech University Health Sciences Center-El Paso v. Flores" on Justia Law