Justia Civil Rights Opinion Summaries

The Supreme Court reversed the judgment of the district court holding that Montana law precluded a jury trial on Plaintiff's federal discrimination claims even though federal law allows a jury trial for federal claims, holding that the district court erred when it concluded that Montana procedural law applied under the Montana Human Rights Act (MHRA) and denied Plaintiff a jury trial on his federal claims.Plaintiff, who has a visual disability, brought claims alleging that the Montana Department of Public Health and Human Services engaged in intentional employment discrimination on the basis of his sex and/or disability, in violation of state and federal anti discrimination statutes. The district court concluded that state law precluded a jury trial on Plaintiff's federal discrimination claims because Montana's antidiscrimination statutes do not provide for a trial by jury and because state procedural rules govern procedures in state courts. The Supreme Court reversed, holding that Plaintiff's claims were separate and distinct from his state law claims and that Plaintiff had a right to a jury trial on his federal claims in state district court. View "Spillers v. Third Judicial District Court" on Justia Law

Plaintiff, an assistant professor at Macalester College, filed suit against the college after she was terminated for violating the college's policies on student-teacher relationships.The Eighth Circuit affirmed the district court's dismissal of plaintiff's claims for discriminatory discharge based on disability under section 504 of the Rehabilitation Act of 1973, the Americans with Disabilities Act, and the Minnesota Human Rights Act (MHRA). The court held that plaintiff's claim regarding the departing provost was raised for the first time on appeal and therefore could not be considered by the court; the district court did not abuse its discretion in ruling that plaintiff's motion to amend her complaint to add claims under the Family Medical Leave Act was untimely and futile; and, even if plaintiff made a prima face case of discrimination, the court concluded on de novo review that the college articulated a legitimate, non-discriminatory reason for terminating plaintiff based on her sexual relationship with a former student. Finally, the court held that plaintiff's claim for failure to accommodate her disability under section 504 failed as a matter of law. View "Naca v. Macalester College" on Justia Law

The Fifth Circuit affirmed the district court's grant of Champion's motion for summary judgment on workplace-discrimination claims brought by plaintiff, an employee, who alleged that he was fired because of a diabetes-related condition. Champion claimed that plaintiff was sleeping at his desk during work hours, an immediately terminable offense.The court held that the district court did not err in finding no direct evidence of discrimination on the basis of disability. The court also agreed with the district court that the evidence suggested that plaintiff could not perform the essential functions of the job with or without an accommodation.The court also held that plaintiff's disability-based claim failed because any harassment plaintiff alleged was not severe or pervasive and did not create an abusive working environment. Furthermore, plaintiff failed to show that the harassment was based on his disability. The court held that the district court did not err in finding no failure to accommodate plaintiff's disability and no failure to engage in an interactive process. Even if plaintiff was a qualified individual, his failure-to-accommodate claim failed because he failed to carry his burden to show that he requested reasonable accommodations. The court further held that plaintiff failed to show a prima facie case of retaliation. Finally, the district court did not err by denying plaintiff's claims for damages. View "Clark v. Champion National Security, Inc." on Justia Law

In this suit alleging retaliation pursuant to section 213.070 of the Missouri Human Rights Act (MHRA) the Supreme Court reversed the judgment of the circuit court denying Washington University judgment notwithstanding the verdict (JNOV), holding that Plaintiff failed to submit a cognizable claim under the MRHA.Plaintiff filed a complaint against the University claiming that her request for a reasonable accommodation of her herniated discs was a protected activity. A jury returned a verdict in Plaintiff's favor against the University. The Supreme Court reversed, holding that the circuit court erred in overruling the University's JNOV motion because merely requesting an accommodation is insufficient to support a claim of retaliation under the plain language of the MHRA. View "Lin v. Ellis" on Justia Law

Plaintiff filed suit against the fire chief and the city after he was terminated from his position as a driver/pump operator at the fire department because he objected to having TDAP vaccinations based on religious grounds. Plaintiff was given a choice between two accommodations: transfer to a code enforcement job that did not require a vaccination, or wear a respirator mask during his shifts, keep a log of his temperature, and submit to additional medical testing. When plaintiff did not accept either accommodation, he was fired by the fire chief for insubordination.The Fifth Circuit affirmed the district court's grant of summary judgment to defendants on all of plaintiff's claims. In regard to plaintiff's claim of retaliation in violation of Title VII and the Texas Commission on Human Rights Act (TCHRA), the court held that the city provided a reasonable accommodation by offering to transfer plaintiff to the code enforcement position in the department. In regard to plaintiff's Title VII and TCHRA retaliation claims, the court held that the city had a legitimate, non-discriminatory reason for plaintiff's termination: plaintiff's defiance of a direct order by failing to select an accommodation to the TDAP vaccine policy. In regard to plaintiff's 42 U.S.C. 1983 claims that defendants violated his First Amendment Free Exercise rights, the court held that plaintiff's right to freely exercise his religious beliefs was not burdened by the respirator requirement. View "Horvath v. City of Leander" on Justia Law

In 1982, Miles began working with SCHRA, a Tennessee public nonprofit organization that provides services to low-income individuals. After promotions and reassignments, Miles became Community Services Director in 2012, reporting directly to the Executive Director and responsible for overseeing six programs. Each of these programs, except for DUI school, has its own Director. In 2011, the Tennessee Comptroller, Tennessee Bureau of Investigation, and U.S. Department of Energy’s Office of Inspector General investigated SCHRA and discovered several deficiencies, including some within programs directly supervised by Miles. The Executive Director resigned. Two employees admitted to wrongdoing and were terminated. The new Executive Director, Rosson, subsequently terminated Miles, “at-will,” “without notice and without reason.” Miles sent emails to Rosson and other SCHRA employees saying that she believed SCHRA fired her because of the nefarious efforts of her subordinates and that she intended vindictively to sue SCHRA to impose legal defense costs on the agency and the individuals. Miles filed a charge of age discrimination with the EEOC. SCHRA then provided Miles with reasons for her termination: her implication in misconduct by the Comptroller’s report and her toxic relationship with her subordinates. Miles sued. During discovery, SCHRA reaffirmed those reasons. The Sixth Circuit affirmed summary judgment in favor of the defendants. The Age Discrimination in Employment Act only prevents employers from terminating an employee because of such individual’s age, 29 U.S.C. 623(a)(1). Miles failed to establish a genuine dispute as to pretext. View "Miles v. South Central Human Resource Agency, Inc." on Justia Law

Lett worked as an investigator for Chicago’s Civilian Office of Police Accountability. In 2016, Lett was investigating police involvement in a particular civilian shooting. The Chief Administrator, Fairley, directed Lett to include in the report a finding that police officers had planted a gun on the shooting victim. Lett refused because he did not believe that the evidence supported that finding. Lett raised his concerns with Fairley’s deputy, who spoke with Fairley. Soon after, Lett was removed from his investigative team, then removed from investigative work, and ultimately assigned to janitorial duties. Fairley opened an internal investigation that concluded that Lett had violated the office’s confidentiality policy. Fairley ordered that Lett be fired. Lett initiated a grievance through his union. The arbitrator ordered the office to reinstate Lett with back pay and to expunge his record. Fairley immediately placed Lett on administrative leave with pay. Lett was assigned on paper to the Police Department’s FOIA office but was not allowed to return to work. Lett sued under 42 U.S.C. 1983, alleging First Amendment retaliation for his refusal to write a false report and Monell liability for the city and Fairley in her official capacity. The Seventh Circuit affirmed the dismissal of the claims. Lett spoke pursuant to his official duties and not as a private citizen when he refused to alter the report; the First Amendment does not apply. View "Lett v. City of Chicago" on Justia Law

The Chicago Police Department (CPD) periodically administered an examination for sergeants seeking promotion to lieutenant. While the CPD retained discretion over whom to promote, those who scored highest on the exam were generally first in line. Word has served with the CPD since 2001. When he took the exam in 2006, he was ranked 150th. The sergeants ranked 1-149 received promotions; Word was the highest-scoring sergeant who did not. In 2015, when Word next took the exam, his ranking fell to 280th. He was passed over. Word alleges that three senior CPD leaders each had “wives or paramours” who were sergeants who took the 2015 exam and then received promotions. Word alleges that one defendant had early access to the exam and provided test content to the wives and paramours. The Seventh Circuit affirmed the dismissal of his suit, which alleged violations of equal protection and due process under 42 U.S.C. 1983 and breach of contract. While Illinois law prohibits “wilfully or corruptly furnish[ing] to any person any special or secret information,” there is no property interest in any municipal promotional process. Class-of-one equal protection claims are barred in the public employment context. Word’s s theory does not amount to gender discrimination. There was no contract and Word has not plausibly alleged that the city and exam administrator intended to confer legally enforceable rights on the test takers. View "Word v. City of Chicago" on Justia Law

Plaintiff filed suit alleging that CFS and two of its employees fired him from his position as a social services practitioner in retaliation for his whistleblowing activities, in violation of California Labor Code section 1102.5 and 42 U.S.C. 1983. The County's Civil Service Commission upheld the termination and denied plaintiff's appeal, and the district court dismissed the action.The Ninth Circuit held that the Commission's order did not preclude plaintiff's section 1102.5 claim for retaliation in light of Taswell v. Regents of Univ. of Cal., 232 Cal. Rptr. 3d 628, 643 (Ct. App. 2018). In Taswell, the California Court of Appeal applied a legislative-intent exception and held that administrative findings by a state agency do not preclude claims for retaliation brought under section 1102.5. However, the panel's conclusion regarding legislative intent did not extend to plaintiff's claim under section 1983, which was precluded by the Commission's order. In this case, plaintiff had a full opportunity to litigate the propriety of his termination before the administrative agency, as evidenced by the comprehensive evidentiary record and the availability of judicial review. Accordingly, the panel affirmed in part, reversed in part, and remanded. View "Bahra v. County of San Bernardino" on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered in favor of Defendant by the superior court on Plaintiff's claims of a hostile work environment and gender discrimination prohibited by the Maine Human Rights Act and unlawful retaliation in violation of the Maine Whistleblower's Protection Act, holding that the superior court did not err by granting a summary judgment in favor of Defendant on all of Plaintiff's claims of discrimination in the workplace.Specifically, the Supreme Judicial Court held that the superior court did not err when it concluded that Plaintiff failed to present evidence that he had been subjected to a hostile work environment arising from sexual harassment, that he was terminated from his employment in retaliation for complaints he had made about other employees, and that he was the victim of gender-based discrimination. View "Johnson v. York Hospital" on Justia Law