Justia Civil Rights Opinion Summaries

After plaintiff was injured while performing work in the Adult Offender Work Program (AOWP), he filed suit against the county for its failure to accommodate his preexisting physical disability and failure to engage in the interactive process under the Fair Employment and Housing Act (FEHA).The Court of Appeal affirmed the trial court's grant of summary judgment in favor of the county. The court held that an individual sentenced to perform work activities in lieu of incarceration in the absence of any financial remuneration, is precluded, as a matter of law, from being an "employee" within the meaning of the FEHA. The court explained that, while remuneration alone is not a sufficient condition to establish an individual is an employee under the statute, it is an essential one. Because plaintiff earned no sufficient financial remuneration as a result of participation in the AOWP, he could not be deemed an employee under the FEHA. The court did not reach plaintiff's remaining arguments. View "Talley v. County of Fresno" on Justia Law

Two teachers at Roman Catholic elementary schools were employed under agreements that set out the schools’ mission to develop and promote a Catholic School faith community; imposed commitments regarding religious instruction, worship, and personal modeling of the faith; and explained that teachers’ performance would be reviewed on those bases. Each taught religion and worshipped with her students, prayed with her students. Each teacher sued after her employment was terminated. One claimed violation of the Age Discrimination in Employment Act; the other claimed she was discharged because she requested a leave of absence to obtain breast cancer treatment. The Ninth Circuit declined to apply the Supreme Court's 2012 Hosanna-Tabor “ministerial exception” to laws governing the employment relationship between a religious institution and certain key employees.The Supreme Court reversed. The First Amendment’s Religion Clauses foreclose the adjudication of employment disputes involving those holding certain important positions with churches and other religious institutions. Several factors may be important in determining whether a particular position falls within the ministerial exception. What matters is what an employee does. Educating young people in their faith, inculcating its teachings, and training them to live their faith lie are the core of a private religious school’s mission. The plaintiff-teachers qualify for the exception; both performed vital religious duties, educating their students in the Catholic faith, and guiding their students to live their lives in accordance with that faith. Their titles did not include the term “minister” but their schools expressly saw them as playing a vital role in carrying out the church’s mission. A religious institution’s explanation of the role of its employees in the life of the religion is important. The Ninth Circuit mistakenly treated the Hosanna-Tabor decision as a checklist; that court invested undue significance in the facts that these teachers did not have clerical titles and that they had less formal religious schooling than the Hosanna-Tabor teacher. The Court rejected a suggestion that an employee can never come within the Hosanna-Tabor exception unless the employee is a “practicing” member of the religion with which the employer is associated. View "Our Lady of Guadalupe School v. Morrissey-Berru" on Justia Law

After Costco terminated plaintiff, who has been deaf since birth, she filed suit in Florida state court for violations of the Florida Civil Rights Act of 1992 (FCRA). After Costco removed the case to federal court, the case went to trial, and the jury returned a verdict in favor of Costco on one count of wrongful termination, but against the company on plaintiff's failure-to-accommodate claim. The district court subsequently granted summary judgment to Costco for judgment as a matter of law on the failure-to-accommodate claim.The Eleventh Circuit affirmed, holding that there was insufficient evidence to support plaintiff's failure-to-accommodate claim. In this case, plaintiff failed to point to a specific instance in which she needed an accommodation and was denied one. The court stated that it cannot hold that an employer fails to reasonably accommodate a deaf employee when it provide her with on-demand access to live sign-language interpreters at two, convenient locations within her place of work; when it goes further to provide on-site person interpreters for larger, group meetings; when it arranges a thorough training session on deaf culture, pursuant to the plaintiff's request; and when the plaintiff's general manager—the supervisor who was the sole subject of her sole complaint—resolves to improve his relationship with the plaintiff by attending multiple, one-on-one training sessions. View "D'Onofrio v. Costco Wholesale Corp." on Justia Law

Plaintiff filed suit under Title VII against Midwest after it allegedly withdrew his job offer after learning that he was gay. The Eighth Circuit reversed the district court's dismissal based on Williamson v. A.G. Edwards & Sons, Inc., 876 F.2d 69, 70 (8th Cir. 1989), and remanded for further proceedings in light of the Supreme Court's decision in Bostock v. Clayton Cty., 590 U.S. ___, Nos. 17-1618, 17-1623, 18-107, slip op. at 4 (June 15, 2020), which held that it "defies" Title VII for "an employer to discriminate against employees for being homosexual or transgender," because to do so, it "must intentionally discriminate against individual men and women in part because of sex." View "Horton v. Midwest Geriatric Management" on Justia Law

After plaintiff was denied tenure as an assistant professor of Legal Studies at the University of Mississippi, he filed suit against several university officials in their individual capacities, alleging that they violated his substantive due process rights when they evaluated his eligibility for tenure in an arbitrary and capricious manner. A jury subsequently awarded plaintiff over $200,000 in damages for lost wages and past and future pain and suffering.The Fifth Circuit reversed and rendered judgment in favor of defendants, holding that the district court erred when it denied defendants' motions for qualified immunity and concluded that plaintiff had a clearly established property interest. In this case, plaintiff failed to demonstrate that the language in his contract that allegedly guaranteed him a "fair process of tenure review" gave rise to a clearly-established property right. View "Wigginton v. Jones" on Justia Law

The Fourth Circuit affirmed the district court's judgment entered in favor of Rand in an action brought by plaintiff, a former employee, alleging that Rand unlawfully fired her for taking leave under the Family Medical Leave Act (FMLA).The court affirmed and agreed with the district court that plaintiff failed to present sufficient evidence for a reasonable jury to find that Rand's justification for the termination was false and merely a pretext for retaliation. In this case, Rand presented a lawful explanation for firing plaintiff: performance problems. The court also held that the district court did not abuse its discretion by excluding a former employee's testimony under Federal Rule of Evidence 403. View "Fry v. Rand Construction Corp." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Koss in an action brought by plaintiff, a former employee, alleging that Koss terminated her employment in retaliation for her complaints about pay discrimination based on sex in violation of the Equal Pay Act (EPA).The court held that plaintiff failed to present sufficient evidence to create a genuine issue of material fact as to pretext. In this case, plaintiff failed to present sufficient evidence as to the question of whether there was no basis in fact for Koss's proffered reason for her termination: there was lack of work at the project. The court also held that plaintiff failed to present sufficient evidence to create a genuine issue of material fact on the question of whether a retaliatory reason more likely motivated the manager's decision to terminate her. View "Yearns v. Koss Construction Co." on Justia Law

The DC Circuit vacated the district court's dismissal of plaintiff's claims of employment discrimination against Cushman & Wakefield's Chief Executive Officer of the Americas for lack of personal jurisdiction based on the fiduciary shield doctrine.The court held that the fiduciary shield doctrine lacks any basis in either the Due Process Clause or the transacting-business prong of the District of Columbia's long-arm statute, D.C.CODE 13-423(a)(1). The court also held that the district court's dismissal erroneously denied plaintiff's request in the alternative for limited jurisdictional discovery. Accordingly, on remand, the district court may either (i) determine on the current record that defendant's suit-related contacts (made in his capacity as CEO of the Americas and otherwise) satisfy the minimum-contacts standard, or (ii) grant jurisdictional discovery to permit development of the record on defendant's contacts with the District of Columbia. View "Urquhart-Bradley v. Mobley" on Justia Law

Plaintiff filed suit against the railroad under the Missouri Human Rights Act (MHRA) and the Family and Medical Leave Act (FMLA), alleging that the railroad discriminated against her on the basis of her gender and her use of FMLA leave when it terminated her. The railroad maintains that plaintiff was terminated as part of a reduction in force (RIF) without discriminatory intent.The Eighth Circuit affirmed the district court's grant of summary judgment to the railroad, holding that the affidavits that the district court relied on were not sham affidavits; plaintiff failed to present any evidence to create a genuine dispute of material fact that her gender was a contributing factor in her termination; the RIF was legitimate and plaintiff failed to demonstrate evidence showing that her gender was a contributing factor in her termination; and thus the district court properly granted the railroad summary judgment on plaintiff's MHRA gender-discrimination claim. Because plaintiff does not offer any direct evidence that the railroad terminated her in the RIF for exercising her FMLA rights, the court analyzed her claim under the McDonnell Douglas burden-shifting framework. In this case, the railroad proffered a legitimate, nondiscriminatory reason for terminating plaintiff and she failed to show that the stated reason was a pretext for FMLA discrimination. View "Button v. Dakota, Minnesota & Eastern Railroad Corp." on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment in favor of the school district in an action brought by plaintiff, alleging claims under the Americans With Disabilities Act (ADA) for discrimination and retaliation.Regardless of whether the "transitory and minor" nature of the impairment was part of plaintiff's prima facie case or an affirmative defense to her claim of "regarded as" disability discrimination, the court held that the school district is entitled to judgment as a matter of law on plaintiff's "regarded as" disability-based discrimination claim. In this case, there are no facts in dispute regarding the transitory and minor nature of the perceived impairment from plaintiff's lap band surgery. Although the court held that the district court erred in its determination that plaintiffs failed to establish a prima facie case of retaliation because she failed to present sufficient evidence of a causal connection, the court affirmed the district court's grant of summary judgment to the school district on the retaliation claim because plaintiff failed to meet her summary judgment burden of pointing to evidence demonstrating that the legitimate, non-discriminatory reasons proffered by the school district for its actions were pretextual. The school district proffered that plaintiff was removed from coaching basketball because it was the school district's understanding that she did not like coaching basketball and did not want to do so. View "Lyons v. Katy Independent School District" on Justia Law