Justia Civil Rights Opinion Summaries

Plaintiff filed suit against Lowe's for violation of the Americans with Disabilities Act (ADA), claiming that Lowe's had forced him out of his director-level job even though, with reasonable accommodations for him after his knee surgery, he could still perform its essential functions. Plaintiff also alleged that Lowe's violated the ADA when it refused to reassign him to another director-level position, and that Lowe's discriminated against him in violation of the Age Discrimination in Employment Act (ADEA).The Fourth Circuit affirmed the district court's grant of summary judgment in favor of Lowe's, holding that no reasonable jury could find that working over eight hours each day was anything less than an essential function of the Market Director of Stores (MDS) position; plaintiff could no longer perform the essential functions of his job without reasonable accommodation; and no reasonable accommodation, consistent with plaintiff's doctor's orders, would have allowed him to perform his job's essential functions. Furthermore, the court rejected plaintiff's contention that Lowe's violated his rights under the ADA by failing to reassign him to another vacant and comparable position where the record demonstrates that Lowe's extended reasonable accommodations to plaintiff, acting at every stage to ensure that his disability did not unfairly compromise his equality of opportunity at Lowe's. Finally, plaintiff failed to prove a prima facie case under the ADEA where he was not able to perform the essential functions of his MDS job with our without reasonable accommodations. View "Elledge v. Lowe's Home Centers, LLC" on Justia Law

Calderone, a Chicago police communications operator, was off duty, driving her car when another motorist, Garcia, threw a drink into Calderone’s vehicle, then pulled to the side of the road. Calderone stopped behind Garcia’s car. The women exited their cars and argued. Garcia returned to her vehicle and tried to drive away. Calderone blocked Garcia’s exit. Garcia again got out of her vehicle, grabbed Calderone by the hair, and threw her to the ground. Calderone then shot Garcia with her handgun, which she was legally permitted to carry. The bullet lacerated Garcia's vital organs; she was hospitalized for several months.Calderone was indicted for attempted murder. The city administratively charged her with violations of Personnel Rules and, after a hearing, fired Calderone. Calderone asserts the city did not respond to her claim that the discharge was in self-defense. An Illinois state court acquitted Calderone of attempted murder based on self-defense. The city subsequently reinstated Calderone and held a hearing to determine her back pay.Calderone sued, arguing that her termination deprived her of her Second Amendment right to keep and bear arms, that the city deprived her of property and liberty rights without due process, and that the Personnel Rules were vague. The Seventh Circuit affirmed the dismissal of the claims. Even if Calderone has a constitutional right to discharge her firearm in self-defense, qualified immunity shielded her supervisors from suit because precedent has not clearly established that right. View "Calderone v. City of Chicago" on Justia Law

Sandefur, a Cook County corrections officer, suffers from spinal disk desiccation and osteoarthritis in his knees. In 2011, Sandefur received a handicapped parking placard from the Illinois Secretary of State. His application asserted that he could not walk without an assistive device and that the impairment was permanent. In 2015, at age 55, Sandefur was accepted to the Police Academy. An instructor noticed the handicapped parking placard in Sandefur’s car. Sandefur said it was there for his wife. When another officer asked about the placard, Sandefur said that it was his wife’s but that he also used it. Wanting to confirm that Sandefur was medically cleared to participate in the Academy’s physical training, Academy officials met with Sandefur, who stated that he was not requesting any accommodations in the Academy. During a formal investigation, Sandefur’s explanations did not improve or become consistent. An investigator concluded that Sandefur had demonstrated an “inability to provide truthful responses to basic questions.” The Sheriff’s Office dismissed Sandefur from the Academy. He returned to his corrections job.The Seventh Circuit affirmed the summary judgment rejection of Sandefur’s suit, which alleged violations of the Americans with Disabilities Act, 42 U.S.C. 12112, and his due process rights. The Sheriff’s Office dismissed Sandefur based on its honest belief that he had lied about his disability, not because he had a disability. There is no evidence that anyone involved in the investigation or dismissal harbored any unlawful animus. View "Sandefur v. Dart" on Justia Law

Williamson County District Attorney Helper told other officials that she distrusted Fairview Police officers Stockdale and Dunning and that she would not “take their cases.” Helper wrote to the city manager (Collins): “per our discussion, this Office has concerns about reports initiated/investigated solely by” Dunning or Stockdale and that defense counsel would be entitled to a copy of an earlier investigation report concerning the officers. Helper stated, “[w]ithout independent corroboration from another law enforcement officer and/or independent witness, the[ir] testimony . . . may be impeached.” Collins disputed Helper’s assessment but Helper refused to back down. Collins fired the officers, explaining the email provided the “sole reason.”Stockdale and Dunning sued. They settled their claims against the city, leaving a First Amendment claim and state law claims against Helper. The district court denied Helper’s claim of absolute immunity and her claim for qualified immunity from the federal First Amendment retaliation claim. It also denied her summary judgment with respect to state law claims for official oppression and tortious interference with a business relationship. The Sixth Circuit affirmed in part. Because Helper’s actions were not closely tied to the judicial process, absolute immunity does not apply; because her conduct did not violate any clearly established law, qualified immunity protects her. View "Stockdale v. Helper" on Justia Law

Four female employees, including plaintiff, filed suit alleging hostile work environment claims. The jury awarded plaintiff a total of $400,000 on her claims against defendants under Title VII of the Civil Rights Act and 42 U.S.C. 1983. The County then filed motions for judgment as a matter of law or, alternatively, for a new trial, under Federal Rule of Civil Procedure 50(b) and 59(b). The district court then sua sponte denied the motions based on the restrictions established by Rule 6(b)(2) on extending time for filing such motions. The Second Circuit vacated the denial order and remanded. On remand, the district court found that plaintiff "constructively waived" her objection to the timeliness of the County's motions and entered orders reducing plaintiff's Title VII award to $75,000 and overturning the jury verdict in her favor on her section 1983 claim for want of evidence of an unlawful municipal custom or practice under Monell v. Department of Social Services, 436 U.S. 658 (1978). Both plaintiff and the County appealed.The Second Circuit held that plaintiff forfeited her right to object to the untimeliness of the County's post-trial motions by failing to raise the issue contemporaneously with the district court's grant of the extension. The court further rejected the County's position that plaintiff's acceptance of remittitur on her Title VII claims forecloses her appeal of the judgment insofar as it relates to her section 1983 claim. On the merits, the court affirmed the judgment in plaintiff's favor on her Title VII claim and rejected the County's cross-appeal seeking judgment in its favor on that claim as a matter of law. In regard to the section 1983 claim, the court concluded that the district court erred in entering judgment as a matter of law for the County, because the jury had a reasonable basis for its finding of sufficient municipal involvement to support its award to plaintiff. Accordingly, the court affirmed in part, vacated in part, and remanded. View "Legg v. Ulster County" on Justia Law

The Fourth Circuit affirmed the district court's grant of summary judgment for the County in an action brought by plaintiff, alleging claims of discrimination and retaliation in violation of the Americans with Disabilities Act (ADA). Plaintiff, an employee of the County who suffers from multiple sclerosis, filed suit alleging that she faced unlawful discrimination based on her disability when the County laterally transferred her to another department, and that the transfer came in retaliation for filing a complaint with the Equal Employment Opportunity Commission (EEOC).The court held that a transfer is not an adverse action when it is voluntarily requested and agreed upon. In this case, plaintiff requested a lateral transfer, and the County agreed to place her in a position with the same pay and similar responsibilities. Therefore, plaintiff failed to show an adverse action and the district court correctly determined that she failed to make out a prima facie case of discrimination and retaliation. View "Laird v. Fairfax County" on Justia Law

The Eighth Circuit affirmed the district court's grant of U.S. Bank's motion for summary judgment in an action brought by plaintiff, alleging that the Bank fired her because of her age and in retaliation for reporting discrimination in violation of the Minnesota Human Rights Act.The court held that the Bank articulated a legitimate, nondiscriminatory reason to terminate plaintiff with adequate support in the record: performance issues. The court also held that plaintiff failed to show that the Bank's explanation for her firing is mere pretext for intentional discrimination. In this case, none of the employees that she compares herself to are similarly situated in all relevant respects, and the evidence does not present a change in basis for firing her. Furthermore, plaintiff offered no evidence to support causation for her retaliation claim under the Minnesota Human Rights Act. Finally, the Bank's decision not to hire plaintiff in another position was not based on a discriminatory and retaliatory motive, and plaintiff failed to establish pretext. View "McKey v. U.S. Bank National Association" on Justia Law

Washington ballot initiative 1501 prohibits public access to certain government-controlled information, including the personal information of in-home care providers, but permits that information to be disclosed to the providers’ certified exclusive bargaining representatives. The law was challenged under 42 U.S.C. 1983 by in-home providers, required by Washington law to participate in statewide collective bargaining, who are not members of their respective unions and do not pay agency fees. They wanted to inform other individual in-home providers of their right to not pay union agency fees and were unable to obtain the necessary contact information.The Ninth Circuit affirmed summary judgment in favor of the defendants. The First Amendment does not guarantee a general right of access to government-controlled information. Whether to disclose government-controlled information is generally left to the political processes but the First Amendment forbids a state from discriminating invidiously among viewpoints. A state does not engage in viewpoint discrimination by disclosing the personal information of public or quasi-public employees to the employees’ certified bargaining representative while denying equal access to the public. Initiative 1501 does not implicate the plaintiffs’ associational freedom; the plaintiffs lack standing to assert the rights of other in-home care providers. Initiative 1501 does not violate the Equal Protection Clause; the challenged provisions satisfy rational-basis review. The state has a legitimate interest in protecting seniors and other vulnerable individuals from identity theft and other financial crimes. There was no evidence that those who voted in favor of Initiative 1501 were motivated by an irrational prejudice or desire to harm the plaintiffs or their message. View "Boardman v. Inslee" on Justia Law

In this case involving a subsidy to offset part of the cost of health insurance that Ohio Public Employees Retirement System (OPERS) provides to retirees receiving an OPERS pension the Supreme Court affirmed the decision of the court of appeals reversing the trial court's dismissal of the action for failure to state a claim, holding that the court of appeals correctly determined that Plaintiff stated a claim under Civ.R. 12(B)(6).Plaintiff filed a class action suit against OPERS arguing that reducing the subsidy of any retiree who is reemployed by a public employer that is a member of the OPERS network violates the Equal Protection Clause of the Ohio Constitution. The trial court dismissed the case under Civ.R. 12(B)(6). The appellate court reversed, holding that Plaintiff stated a claim under Ohio's Equal Protection Clause. The Supreme Court affirmed, holding that Plaintiff alleged facts that, if accepted as true, would entitle him to relief. View "Sherman v. Ohio Public Employees Retirement System" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment on Plaintiff's racial discrimination and retaliation claims against the Massachusetts Bay Transportation Authority (MBTA), holding that both challenges were meritless.Plaintiff brought claims of racial discrimination, unlawful retaliation, and negligent infliction of emotional distress against the MBTA. The district court granted summary judgment to the MBTA on all claims. The First Circuit affirmed, holding (1) Plaintiff did not produce sufficient evidence to get to a jury on his claim that he was denied a promotion based on his race; and (2) Plaintiff did not establish a prima facie case of retaliation. View "Henderson v. Massachusetts Bay Transportation Authority" on Justia Law