Justia Civil Rights Opinion Summaries

Sergeant Jatonya Clayborn Muldrow, a police officer in the St. Louis Police Department, alleged that she was transferred from her position in the Intelligence Division to a uniformed job in another department because of her gender. Despite maintaining her rank and pay, Muldrow's responsibilities, perks, and schedule were significantly altered. She filed a Title VII suit against the City of St. Louis, claiming that the transfer constituted sex discrimination with respect to her employment terms and conditions.The District Court granted the City summary judgment, and the Eighth Circuit affirmed, holding that Muldrow had to show that the transfer caused her a "materially significant disadvantage." The courts ruled that since the transfer did not result in a reduction to her title, salary, or benefits and only caused minor changes in working conditions, Muldrow's lawsuit could not proceed.The Supreme Court of the United States disagreed with the lower courts' interpretation of Title VII. The Court held that an employee challenging a job transfer under Title VII must show that the transfer brought about some harm with respect to an identifiable term or condition of employment, but that harm need not be significant. The Court rejected the City's arguments based on statutory text, precedent, and policy, and vacated the judgment of the Eighth Circuit, remanding the case for further proceedings under the correct Title VII standard. The Court clarified that Muldrow only needed to show some injury respecting her employment terms or conditions, not that the harm was significant. View "Muldrow v. City of St. Louis" on Justia Law

The case involves Marcus Anderson and Reed Clark, current and former employees of Harris County, who allege that Constable Christopher Diaz violated their First Amendment rights. They claim that Diaz instituted reforms to ensure his re-election, which included requiring employees to work on his campaign and retaliating against those who impeded campaign functions. The plaintiffs assert that Diaz had final authority over employment decisions and that his actions resulted in various adverse employment actions, ranging from transfer to termination.The plaintiffs initiated a suit against Diaz and Harris County under 42 U.S.C. § 1983, claiming Diaz violated their First Amendment rights. Harris County filed a motion to dismiss, which the district court granted, finding that Diaz was not a policymaker for Harris County. The district court dismissed all claims against the county with prejudice. Two years later, the district court issued a final judgment regarding the claims against Harris County, allowing the plaintiffs to appeal.The United States Court of Appeals for the Fifth Circuit affirmed the district court's decision. The court agreed with the lower court's finding that Diaz, as a constable of a single precinct, was not a final policymaker for Harris County. The court also rejected the plaintiffs' alternative argument that Harris County was liable for Diaz's employment decisions under a delegation or rubber-stamp theory. The court concluded that the plaintiffs failed to show that the alleged First Amendment violations were the result of an official county policy, and therefore, their claims against Harris County were dismissed. View "Anderson v. Harris County" on Justia Law

The case revolves around Lori Vogt, a deputy court clerk, who was fired by Lisa Rodebush, the McIntosh County Court Clerk, for not publicly supporting Rodebush's reelection campaign. Vogt had worked with Rodebush for thirteen years and had supported her in the past. However, during the 2020 reelection campaign, Vogt's best friend, a former employee of the County Court Clerk’s Office, ran against Rodebush. Vogt decided to support Rodebush privately but not publicly to maintain her friendship with Rodebush's opponent. Despite this, Vogt campaigned for Rodebush and provided advice for her campaign. Rodebush, however, was not satisfied with Vogt's level of support and eventually fired her after winning the election. Vogt then filed a lawsuit alleging that Rodebush violated her First Amendment rights of free speech and political affiliation.The United States District Court for the Eastern District of Oklahoma denied Rodebush's motion for summary judgment, where she asserted qualified immunity. Rodebush appealed this decision.The United States Court of Appeals for the Tenth Circuit affirmed the lower court's decision. The court found that a public official cannot condition a subordinate’s employment on her political beliefs, affiliation, or non-affiliation, unless the government has a vital interest in doing so. The court held that Rodebush violated Vogt's First Amendment right to political affiliation by firing her for not publicly supporting her reelection campaign. The court also found that Vogt's right was clearly established at the time of the violation, thus defeating Rodebush's claim of qualified immunity. View "Vogt v. McIntosh County Board" on Justia Law

Two campus police officers at Shepherd University, Jay Longerbeam and Donald Buracker, were terminated due to alleged "misconduct" and "unprofessionalism" during two incidents in 2018 and 2019. The officers claimed that their termination was a result of age and disability discrimination, retaliation under the West Virginia Human Rights Act (HRA), violation of the West Virginia Whistle-blower Law, and common law wrongful discharge. The Circuit Court of Jefferson County granted summary judgment against both officers on all claims.The officers appealed the decision, arguing that the lower court erred in finding no genuine issues of material fact and in its handling of the burden-shifting paradigm. They contended that their conduct during the incidents was legally proper and that the court failed to consider intervening acts of reprisal which were more temporally proximate to their protected activity than their discharge.The Supreme Court of Appeals of West Virginia found that the lower court erred in its handling of the "temporal proximity" issue and the burden-shifting paradigm. The court also found that the officers offered more than sufficient evidence upon which a rational trier of fact could find retaliatory motivation. Therefore, the court reversed the lower court's grant of summary judgment as to the officers’ whistle-blower and Harless claims and remanded for further proceedings. However, the court affirmed the lower court's grant of summary judgment as to Buracker’s HRA disability discrimination claim, finding his evidence insufficient to create an inference of disability discrimination. View "Jay Longerbeam v. Shepherd University" on Justia Law

A Black woman, Erika Buckley, filed a lawsuit against the Secretary of the Army, alleging that her former colleagues at Martin Army Hospital engaged in conduct that was racially discriminatory. Buckley, a speech pathologist, claimed her colleagues diverted white patients from her care, encouraged white male patients to complain about her, and engaged in other race-based harassing conduct. The Secretary moved for summary judgment, which the district court granted on all counts. Buckley appealed this decision.The United States Court of Appeals for the Eleventh Circuit upheld the lower court's decision regarding Buckley's retaliation claims, but vacated the lower court's decision on her race-based disparate treatment claim and her race-based hostile work environment claim. The court found that Buckley had provided enough evidence to suggest that her race played a role in the decision-making process leading to her dismissal, even if her race was not the but-for cause of the dismissal. The court also concluded that Buckley had provided sufficient evidence to establish a hostile work environment claim. The case was sent back to the district court for further proceedings consistent with the appeals court's opinion. View "Buckley v. Secretary of the Army" on Justia Law

In a case before the United States Court of Appeals for the Eleventh Circuit, Tyler Copeland, a transgender male, sued his employer, the Georgia Department of Corrections (GDOC), for workplace harassment. Copeland was a sergeant at a prison in Georgia and alleged that, after coming out as transgender at work, he endured constant and demeaning harassment from colleagues at various levels, despite repeated complaints to supervisors and HR personnel.He brought three claims under Title VII of the Civil Rights Act of 1964. The first was that his employer had created a hostile work environment. The district court granted summary judgment in favor of GDOC, concluding that the harassment Copeland experienced was not sufficiently severe or pervasive. However, the appellate court disagreed and vacated the summary judgment on this claim.The second claim was that Copeland had been denied promotion due to his transgender status. The district court also granted summary judgment on this count, as Copeland failed to provide evidence that those who decided not to promote him were aware of his protected conduct. The appellate court affirmed this decision.The third claim was that GDOC had retaliated against Copeland for engaging in a protected practice, namely opposing sex discrimination. The district court granted summary judgment on this count as well, and the appellate court affirmed the decision, citing lack of evidence of causation.In summary, the appellate court vacated the district court's grant of summary judgment on the hostile work environment claim but affirmed the summary judgments on the failure to promote and retaliation claims. The case was remanded for the district court to consider the fifth element of Copeland’s hostile work environment claim. View "Copeland v. Georgia Department of Corrections" on Justia Law

In this case, the plaintiff, Jason Schwebke, brought a lawsuit against his employer, United Wholesale Mortgage (UWM), alleging disability discrimination under state and federal law. Schwebke, who is deaf, claimed that UWM failed to provide him with necessary accommodations and retaliated against him. In response, UWM participated in extensive discovery procedures for several months without invoking its right to arbitration as per the parties' employment agreement.Seven months into the case, UWM moved to compel arbitration. The district court denied this motion, reasoning that UWM had implicitly waived its right to compel arbitration through its conduct. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court's decision.The appellate court applied the principle from the Supreme Court's decision in Morgan v. Sundance, Inc., which held that a party may waive its contractual right to arbitrate by participating in litigation. In applying this rule, the court found that UWM's actions—participating in extensive discovery, failing to raise arbitration in its defense, and not moving to compel arbitration until seven months into the case—were completely inconsistent with reliance on the arbitration agreement. The court therefore concluded that UWM had implicitly waived its right to arbitration. View "Schwebke v. United Wholesale Mortgage LLC" on Justia Law

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