Justia Civil Rights Opinion Summaries

The Eighth Circuit affirmed the district court's grant of summary judgment to UPS in an action brought by plaintiff for retaliation and discrimination under 42 U.S.C. 1981. The court held that plaintiff's retaliation claim failed because he cannot link protected conduct with his demotion. In this case, plaintiff concedes that his supervisor and his supervisor's supervisor did not know about the statements plaintiff made on two different occasions. The court also held that plaintiff's race discrimination claim failed at the third step of the McDonnell Douglas framework because UPS provided a legitimate, non-discriminatory basis for the action: plaintiff was failing to perform his duties. Furthermore, plaintiff failed to raise a genuine issue of material fact as to whether UPS's explanation for his demotion was pretext for discrimination. View "Williams v. United Parcel Service, Inc." on Justia Law

The Sheriff's Office appealed the district court's denial of qualified immunity on First Amendment wrongful-discharge claims brought by former Deputy Sheriffs Timothy Bruce and Robert Curtis. Bruce and Curtis's complaints alleged that Cole, the newly elected sheriff, discharged them for political reasons in violation of their First Amendment rights.The Eighth Circuit reversed the district court's denial of qualified immunity, holding that political loyalty is an appropriate requirement for the job of deputy sheriff under Missouri law because of the closeness and cooperation required between sheriffs and their deputies in fulfilling overlapping duties. In this case, Cole did not violate Bruce and Curtis's constitutional rights. Consequently, the county is also entitled to summary judgment on the claims against it. The court remanded for further proceedings. View "Curtis v. Christian County" on Justia Law

Purtue, a Dodge Correctional Institution officer, reported that inmate Reddick had thrown an empty box from his cell, hitting her. Reddick was taken to segregation. A video recording showed the box flying out of Reddick’s cell but the box didn’t fly toward Purtue nor strike her. Work Rule 6 prohibits correctional officers from falsifying records or knowingly giving false information to prison authorities. Reddick stated that he and Purtue had quarreled earlier and that he threw the box out of frustration but purposefully directed it away from Purtue. Purtue reiterated that the box had hit her. After watching the video, Purtue agreed that the box had not hit her but maintained that something else hit her. The investigators doubted that story because on the video Purtue did not react. The warden decided to skip progressive discipline and immediately terminate Purtue’s employment. Executive Directive #2 classifies “[l]ying or providing false information” as “Serious Acts of Misconduct” that may result in termination. Other officials agreed with that recommendation. A memorandum identified comparators for Purtue—one man and two women—all of whom were fired for lying or falsifying records.Purtue filed suit, alleging sex discrimination under Title VII and 42 U.S.C. 1983. The Seventh Circuit affirmed summary judgment for the defendants. The investigation accurately summarized Purtue’s conduct. Purtue’s expert testimony was speculative and offered nothing more than his opinion that termination was unwise but not necessarily pretextual. Although there were gender disparities in a statistical report, those disparities revealed little about Purtue's dismissal. View "Purtue v. Wisconsin Department of Corrections" on Justia Law

Three employers each fired a long-time employee for being homosexual or transgender. Each employee sued, alleging sex discrimination under Title VII of the Civil Rights Act of 1964, which makes it “unlawful . . . for an employer to fail or refuse to hire or to discharge any individual, or otherwise to discriminate against any individual . . . because of such individual’s race, color, religion, sex, or national origin,” 42 U.S.C. 2000e–2(a)(1). The Eleventh Circuit held that the suit could be dismissed. The Second and Sixth Circuits allowed the claims to proceed.The Supreme Court ruled in favor of the employees. An employer violates Title VII when it intentionally fires an individual employee based in part on sex regardless of whether other factors besides the plaintiff's sex contributed to the decision or whether the employer treated women as a group the same when compared to men as a group. Discrimination on the basis of homosexuality or transgender status requires an employer to intentionally treat individual employees differently because of their sex. It is irrelevant what an employer or others might call the discriminatory practice; that another factor, such as the plaintiff’s attraction to the same sex or presentation as a different sex from that assigned at birth, might play an important role in the employer’s decision; or that an employer could refuse to hire a gay or transgender individual without learning that person’s sex. The Court rejected arguments that homosexuality and transgender status are distinct concepts from sex and that a stricter causation test should apply because the policies at issue have the same adverse consequences for men and women. Legislative history has no bearing where no ambiguity exists about how Title VII’s terms apply to the facts. View "Bostock v. Clayton County" on Justia Law

The Supreme Court reversed the order of the circuit court granting summary judgment for Defendant and dismissing Plaintiff's age discrimination claim, holding that genuine issues of material fact remained as to whether Defendant was entitled to the benefit of a severance agreement and general release.Plaintiff, who worked for nineteen years as an area supervisor of One Stop convenience stores, lost his job after Defendant leased approximately forty-one of those stores. Plaintiff applied for a job with Defendant but was not hired. Plaintiff filed suit alleging age discrimination in violation of the West Virginia Human Rights Act. Defendant moved for summary judgment, arguing that Plaintiff had released any employment-related claims against Defendant when he executed a severance agreement and general release with his former employer and its corporate affiliates. The circuit court granted the motion. The Supreme Court reversed, holding that genuine issues of material fact existed as to the applicability of the release agreement to Plaintiff's claim against Defendant. View "Henzler v. Turnoutz, LLC" on Justia Law

The Fifth Circuit affirmed the district court's adverse grant of summary judgment entered on plaintiff's claims against her employer, the City of Houston, for discrimination and creating a hostile work environment in violation of Title VII of the Civil Rights Act of 1964.The court held that plaintiff failed to raise a genuine dispute of material fact regarding the fourth element of her discrimination claim. In this case, plaintiff failed to show that she was similarly situated to other employees who were not members of her protected class and who were treated more favorably. The court held that plaintiff's proffered evidence regarding holdover overtime failed to show that her station-level supervisors treated her less favorably than her white, male comparators. In regard to ride-up overtime, the court held that plaintiff's allegations failed because neither of her coworkers held the same job or responsibilities or shared the same supervisor as her. The court also held that plaintiff failed to show a genuine dispute of material fact regarding her hostile work environment claim because she failed to show that the harassment affected a term, condition, or privilege of employment. Furthermore, plaintiff failed to show that her colleagues' actions were severe, physically threatening, or humiliating. View "Jordan v. City of Houston" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in Trees's favor on his hostile work environment and national origin discrimination claims under Title VII of the Civil Rights Act of 1964 and the Florida Civil Rights Act (FCRA).The Eleventh Circuit affirmed the district court's grant of summary judgment for Trees on plaintiff's national origin discrimination claim, holding that the claim fails as a matter of law where the supervisor's statement, although reprehensible, was not direct evidence that plaintiff was fired because of his national origin. The court reversed the district court's grant of summary judgment for Trees on the hostile work environment claim, holding that plaintiff provided evidence sufficient to raise a material issue of fact as to whether the harassment was objectively severe or pervasive. In this case, plaintiff provided ample evidence that the harassment he faced was frequent; a reasonable jury could conclude that the harassment was sufficiently severe; the supervisor's conduct was sufficiently humiliating to support a hostile work environment claim; and, although more attenuated than typical interference-with-job-performance arguments, the court could not say on this record that plaintiff's on-the-job suicide attempt was wholly unrelated to his job performance. View "Soto Fernandez v. Trees, Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the district court's grant of summary judgment in favor of Defendant after concluding that Plaintiff failed to allege conduct sufficiently severe or pervasive to support a claim for sexual harassment, holding that the conduct alleged by Plaintiff was sufficiently severe or pervasive for a reasonable person to find the work environment to be hostile or abusive.In granting summary judgment to Defendant, the district court determined that the conduct alleged did not meet the severe-or-pervasive standard for actionable sexual harassment based on a hostile work environment. The court of appeals affirmed. The Supreme Court reversed in part, holding (1) Plaintiff has not presented the Court with a compelling reason to abandon the severe-or-pervasive standard for analyzing the objective component of a claim for sexual harassment under the Minnesota Human Rights Act, Minn. Stat. 363A.01-.44; and (2) considering the totality of the circumstances, Plaintiff presented sufficient evidence for a reasonable jury to decide that the complained of behavior was sufficiently severe or pervasive to substantially interfere with Plaintiff's employment or to create an intimidating, hostile, or offensive employment environment. View "Kenneh v. Homeward Bound, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to plaintiff's former employer, Con-E-Co, on plaintiff's sex discrimination claim, her sexual harassment claim, and her retaliation claims under Title VII of the Civil Rights Act of 1964, and the Nebraska Fair Employment Practice Act.The court held that plaintiff failed to establish a prima facie case of sex discrimination because she did not demonstrate that she met Con-E-Co's legitimate job expectations or that Con-E-Co treated her differently than similarly situated male employees; the district court did not err in granting summary judgment to Con-E-Co regarding her sexual harassment claim based on vulgar behavior directed at her by her coworkers, because plaintiff failed to demonstrate that she subjectively perceived the alleged harassment as abusive; and plaintiff failed to establish a prima facie case for retaliation in response to either her race discrimination or sex discrimination complaints. View "Gibson v. Concrete Equipment Co., Inc." on Justia Law

Plaintiff filed suit against the Attorney General of the United States in his official capacity as head of the Department of Justice (DOJ), alleging that the DOJ had denied her a promotion to a Division Director position because of her gender, in violation of 42 U.S.C. 2000e-16, and her age, in violation of 29 U.S.C. 633a. The district court granted summary judgment in favor of the DOJ.The DC Circuit held that a reasonable jury could find that the DOJ's proffered nondiscriminatory reason for denying plaintiff the promotion that she sought was pretextual and that discrimination was the real reason. In this case, a reasonable jury could find in plaintiff's favor based on her superior qualifications, the accumulated evidence of gender discrimination, and pretext. Therefore, the court reversed and remanded for further proceedings. View "Stoe v. Barr" on Justia Law