Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals reversing the trial court's judgment in favor of Defendant on Plaintiff's age-discrimination claim, holding that the trial court committed reversible error by requiring the jury, rather than the court itself, to make the specific factual determination about whether Defendant, Plaintiff's former employer, replaced Plaintiff with a substantially younger person.Plaintiff sued Defendant for age discrimination in violation of the Kentucky Civil Rights Act and for retaliation, alleging that she was terminated for complaining about her former supervisor's behavior before she was replaced. During trial, Plaintiff relied on circumstantial evidence to support her age discrimination claim. The jury rendered a verdict for Defendant. The court of appeals reversed. The Supreme Court affirmed, holding that the trial court committed reversible error by instructing the jury to decide the element under the McDonnell Douglas framework that Defendant replaced Plaintiff with a substantially younger person. View "Norton Healthcare, Inc. v. Disselkamp" on Justia Law

Plaintiff filed suit against her former employer, Allina, for race and national origin discrimination as well as intentional infliction of emotional distress. The Eighth Circuit affirmed the district court's grant of summary judgment as to the discrimination claims, holding that the record demonstrates that Allina considered plaintiff's race only to ensure that any corrective action was not based on racial discrimination; without direct evidence of discrimination, the court relied on the burden shifting McDonnell Douglas analysis; and, assuming plaintiff established a prima facie case, plaintiff failed to demonstrate that Allina's stated reason for terminating her was pretext.The court explained that nothing in Allina's Violence-Free Workplace policy or other policies prohibit Allina from treating some offenses as more severe than others and selecting a corrective action that it believes is proportional to the level of severity for the violation. In this case, Allina's response to plaintiff's grievance and the deposition of an Allina human resources director make clear that Allina believed that pushing a coworker was more severe than throwing a lab coat at a co-worker and that plaintiff's behavior justified a more severe punishment. View "Findlator v. Allina Health Clinics" on Justia Law

Plaintiff filed suit pro se against Brivo, alleging discrimination based on race in violation of Title VII. In this case, within an hour of starting orientation at Brivo, Brivo's security architect approached plaintiff and confronted him about a newspaper article that he had found after running a Google search on plaintiff. The article reported plaintiff's tangential involvement in a shooting for which he faced no charges. Nonetheless, the security architect berated plaintiff about the incident, declared plaintiff unfit for employment at Brivo, and terminated him on the spot. The district court dismissed the case with prejudice, because plaintiff failed to plead sufficient facts to plausibly support a claim of discrimination.The Fourth Circuit held that it had appellate jurisdiction despite the district court's dismissal of the complaint without prejudice. Under Domino Sugar Corp. v. Sugar Workers Local Union 392, 10 F.3d 1064, 1067 (4th Cir. 1993), the order is appealable because the district court held that the circumstances surrounding plaintiff's termination did not expose Brivo to legal liability, and plaintiff has no additional facts that could be added to his complaint; under Chao v. Rivendell Woods, Inc., 415 F.3d 342, 345 (4th Cir. 2005), the order is appealable because the district court dismissed the complaint and directed that the case be closed; and the order is likewise appealable under Chao and In re GNC Corp., 789 F.3d at 511, because plaintiff has elected to stand on his complaint as filed.On the merits, the court held that the district court did not err by dismissing the Title VII claims at this point in the proceedings. The court held that plaintiff failed to plead sufficient facts to plausibly claim his termination or the Google search that lead to it was racially motivated. Accordingly, the court affirmed the judgment. View "Bing v. Brivo Systems, LLC" on Justia Law

Plaintiff filed suit against her employer and its CEO for interference and retaliation under the Family Medical Leave Act (FMLA), and for retaliation under Title VII of the Civil Rights Act and 42 U.S.C. 1981.The Eleventh Circuit affirmed the district court's grant of summary judgment to the employer on the FMLA claim, holding that plaintiff's visit to her counselor did not count as treatment by a health care provider under the statute. In regard to the Title VII claim against the employer, the court held that plaintiff failed to offer any evidence that the CEO knew she had complained about race or sex discrimination, and thus she cannot show a relationship between her firing and that protected activity. Furthermore, plaintiff failed to impeach the CEO's testimony or present circumstantial evidence of his knowledge beyond temporal proximity. Therefore, summary judgment was appropriate on this claim because a jury could find discrimination only based on speculation, rather than on evidence. Finally, plaintiff's section 1981 claims were abandoned on appeal. View "Martin v. Financial Asset Management Systems, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment for Defendants on Plaintiff's age discrimination and Older Workers Benefit Protection Act (OWBPA) claims, holding that Plaintiff's OWBPA-compliant waiver and release were knowing and voluntary under federal common law.Plaintiff, a former Winchendon police officer, decided to resign with a pension after the Defendants determined that he had made several threats against his former girlfriend. Plaintiff resigned instead of facing termination and the possibility of losing his pension and being criminally charged. Plaintiff signed a separation agreement agreeing to waive and release any claims he had against Defendants up and through signing the agreement. Plaintiff later brought a complaint alleging age discrimination, retaliation, and defamation, alleging that the waiver and release in his separation agreement violated the OWBPA and were thus invalid. The district court granted summary judgment on the age discrimination and OWBPA claims for Defendants, and a jury found for Defendants on the retaliation and defamation claims. The Supreme Court affirmed the district court's grant of summary judgment, holding (1) the waiver and release did not violate the OWBPA and were knowing and voluntary; and (2) Defendant's argument that the district court abused its discretion in withdrawing an exhibit at trial was meritless. View "Geoffroy v. Town of Winchendon" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment for Defendants on Plaintiff's claim under the Age Discrimination and Employment Act (ADEA), 29 U.S.C. 621-634, holding that Defendant put forward a legitimate, nondiscriminatory reason for its decision to terminate Plaintiff's employment.Plaintiff was let go from his position after a new, consolidated position went to another employee and because Plaintiff's performance ratings had declined over time. Plaintiff brought an age discrimination claim under the ADEA and under analogous Puerto Rico law. The district court granted Defendants' motion to dismiss the Puerto Rico law claims and granted summary judgment for Defendants on the ADEA claim. The First Circuit affirmed, holding that Plaintiff did not put forth evidence that sufficed to create a genuine issue of disputed material fact as to whether Defendant's proffered reason for selecting the other employee over him for the new, consolidated position was a pretext for age discrimination. View "Zabala-de Jesus v. Sanofi Aventis PR, Inc." on Justia Law

In this disability discrimination action, the Supreme Court reversed the award of litigation expenses but affirmed in all other respects the circuit court's judgment in favor of Plaintiff, holding that no statute allows a circuit court to award as litigation expenses the expenses incurred by counsel for the prevailing party in a Missouri Human Rights Act (MHRA) case.Plaintiff sued the City of Kansas City for disability discrimination and retaliation under the MHRA. The jury returned a verdict in Plaintiff's favor, awarding him actual and punitive damages. The circuit court entered judgment in conformity with the verdict. Upon Plaintiff's motion, the circuit court amended the judgment to award attorney fees and litigation expenses. The Supreme Court affirmed in part and reversed in part, holding (1) the City's argument that the circuit court erred in admitting evidence and argument of Plaintiff's workers' compensation permanent partial disability rating was not preserved for appellate review; and (2) the circuit court erred in awarding Plaintiff litigation expenses because no statute authorizes an award of litigation expenses in an MHRA case. View "Wilson v. City of Kansas City" on Justia Law

Plaintiff-appellant James Willis, a peace officer employed by the Carlsbad Police Department (Department), sued defendant-respondent City of Carlsbad (City) alleging in part that it engaged in whistleblower retaliation against him in violation of Labor Code section 1102.5 (b) by denying him promotions after he reported what he perceived was misconduct by another officer and complained about a Department program he believed was an unlawful quota system. Before trial, City successfully moved to strike allegations of other retaliatory acts within Willis's cause of action on grounds he had not timely presented a government tort claim within six months of the acts as required by the Government Claims Act. The trial court in limine excluded evidence of any violations by City of the Public Safety Officers Procedural Bill of Rights Act while at the same time permitting City to present evidence Department had denied Willis promotion because of a June 2012 e-mail he wrote under an assumed name lodging the officer misconduct accusations. The jury returned a verdict finding in favor of Willis that his reporting of City's violation of law was a contributing factor in City's decision to deny him the promotion. However, it also found City would have denied Willis his promotion anyway for legitimate independent reasons. Accordingly, the court entered judgment in City's favor on the whistleblower retaliation claim. On appeal, Willis argued the trial court erred as a matter of law by striking those portions of his section 1102.5 cause of action because the Government Claims Act's six-month statute of limitations was either equitably tolled or his cause of action had not accrued by reason of the continuing tort/continuing violation doctrine. Furthermore, he argued the court's evidentiary rulings were a prejudicial abuse of discretion. We conclude the trial court did not err, and accordingly affirm the judgment. Finding no reversible error, the Court of Appeal affirmed the trial court's judgment. View "Willis v. City of Carlsbad" on Justia Law

The First Circuit affirmed the judgment of the district court entering summary judgment against Plaintiff and dismissing her complaint asserting claims under the Americans with Disabilities Act (ADA) and Age Discrimination in Employment Act (ADEA) for discrimination and retaliation, holding that the district court did not err in granting summary judgment as to the ADA and ADEA claims and in dismissing the claims under analogous Puerto Rico laws.Plaintiff, a teacher at the Robinson School in Puerto Rico, sued the school and two school administrators alleging that the school had discriminated and retaliated against her because of her age and perceived disability. The district court granted summary judgment for Defendants as to the ADA and ADEA claims and dismissed without prejudice the discrimination and retaliation claims under the analogous Puerto Rico laws against the school upon declining to exercise supplemental jurisdiction. The First Circuit affirmed, holding that the district court did not err. View "Lopez-Lopez v. Robinson School" on Justia Law

After AutoZone was found liable for creating a hostile work environment and for intentional infliction of emotional distress, plaintiff was awarded both compensatory and punitive damages. The Fourth Circuit reversed the award of punitive damages for plaintiff's claim under Title VII of the Civil Rights Act of 1964 and plaintiff's state law claims. In this case, the evidence does not permit a finding that the sales manager at issue served in a managerial capacity such that liability for punitive damages could be imputed to AutoZone. Furthermore, plaintiff failed to carry his burden of presenting sufficient evidence from which a reasonable jury could conclude that the store manager and district manager at issue engaged in an intentionally discriminatory practice with malice or reckless indifference.The panel remanded with instructions for the district court to determine the final amount of plaintiff's compensatory damages award under his Title VII claim. The court rejected AutoZone's duplicative recovery, jury instruction, and evidentiary error challenges, affirming as to these claims. View "Ward v. AutoZoners, LLC" on Justia Law