Justia Civil Rights Opinion Summaries

The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendant on Plaintiff's Age Discrimination in Employment Act (ADEA) claim regarding the termination of Plaintiff's employment, holding that the totality of the circumstances showed a lack of foundation for Plaintiff's pretextual argument.In granting Defendant's motion for summary judgment, the district court determined that the evidence did not support Plaintiff's argument that Defendant's articulated reason for terminating Plaintiff's employment was pretextual, let alone a pretext for age discrimination. The First Circuit affirmed, holding the district court did not misapply the summary judgment standard or err in holding that no reasonable fact-finder could determine that Defendant's reasons for terminating Plaintiff were pretextual. View "Rodriguez-Cardi v. MMM Holdings, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Union Pacific in an action brought by plaintiff, alleging claims of discrimination and retaliation in violation of the Americans with Disabilities Act (ADA), Title VII of the Civil Rights Act, the Family Medical Leave Act (FMLA), and the Nebraska Fair Employment Practice Act (NFEPA).In regard to plaintiff's discrimination claim, the court held that plaintiff was not qualified for a dispatcher position as a matter of law because she was unable to work mandatory overtime and Union Pacific's earlier willingness to accommodate a two-month restriction did not create a genuine issue of fact about whether availability for overtime was an essential function of the position. In regard to the sex and pregnancy discrimination claims, the court held that plaintiff suffered no adverse action when her supervisor denied her requested training or commented on the length of her breast pumping breaks, and the evidence did not give rise to an inference of discrimination in any event. In regard to the race discrimination claim, the court held that plaintiff's proffered comparators were not similarly situated because they were able to work overtime. View "McNeil v. Union Pacific Railroad Co." on Justia Law

The First Circuit vacated the district court's dismissal of Appellant's sexual harassment claims based on a hostile work environment, holding that the district court erred in concluding that alleged incidents of harassment that occurred earlier than 2014 were time-barred and that the error contributed to other flaws in the court's analysis.Appellant brought this action claiming sexual harassment and retaliation under both Title VII of the Civil Rights Act and Puerto Rico Commonwealth law. Defendant asserted that he was sexually harassed for more than a decade and thus subjected to a hostile work environment and that managers at his workplace retaliated against him for complaining about this treatment. The district court granted summary judgment for Defendant on all claims. The First Circuit remanded the case, holding (1) the district court did not err in dismissing the retaliation claims; but (2) a jury could reasonably find that incidents that allegedly occurred in 2014 were instances within the limitations period of a claimed pattern of sexually charged interactions, and the court's statute-of-limitations error necessarily impacted its assessment of the hostile work environment claim. View "Nieves-Borges v. El Conquistador Partnership, L.P." on Justia Law

During his probationary employment period, Smith challenged and failed to follow directions, was confrontational, engaged in unsafe conduct, and received unsatisfactory evaluations. He filed internal and union complaints, alleging abusive language, docking his hours, and racial discrimination. The Illinois Department of Transportation discharged Smith. Smith sued the Department under Title VII, arguing that it had subjected him to a hostile work environment and fired him in retaliation for his complaints about racial discrimination. The district court granted the Department summary judgment. The Seventh Circuit affirmed. The district court was within its discretion in concluding that Smith’s expert witness testimony was inadmissible as not based on “sufficient facts or data” under Federal Rule of Evidence 702(b). An affidavit sworn by one of Smith’s supervisors was inadmissible because it lacked a proper foundation and was “replete with generalized assertions." Given the extensive evidence that Smith was not meeting his employer’s legitimate expectations, a reasonable jury could not find that the Department fired him because of his protected activity rather than for his poor performance nor could a reasonable jury have resolved the hostile work environment claim in Smith’s favor. View "Smith v. Illinois Department of Transportation" on Justia Law

The Ninth Circuit affirmed the district court's judgment for the Mayo Clinic in an action alleging employment discrimination under Title I of the Americans with Disabilities Act.In light of Supreme Court precedent, the panel held that its decision in Head v. Glacier Northwest, Inc., 413 F.3d 1053 (9th Cir. 2005), holding ADA discrimination claims are evaluated under a motivating factor causation standard, is no longer good law. The panel held that Head was irreconcilable with the Supreme Court's decisions in Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (2009), and Univ. of Texas Southwestern Med. Ctr. v. Nassar, 570 U.S. 338 (2013). The panel agreed with its sister circuits and held that an ADA discrimination plaintiff bringing a claim under 42 U.S.C. 2112 must show that the adverse employment action would not have occurred but for the disability. Therefore, the district court correctly instructed the jury to apply a but for causation standard, rather than a motivating factor standard. View "Murray v. Mayo Clinic" on Justia Law

The Ninth Circuit affirmed the district court's grant of summary judgment for Medtronic in an employment discrimination action brought by plaintiff under the Americans with Disabilities Act (ADA). Plaintiff alleged that he was terminated based on his morbid obesity, but the district court held that morbid obesity was not a physical impairment under the relevant EEOC regulations and interpretive guidance.The panel held that it need not determine whether morbid obesity itself is an impairment under the ADA, and affirmed the district court's judgment for Medtronic on alternative grounds. The panel held that, even assuming that morbid obesity were an impairment, or plaintiff suffered from a disabling knee condition that the district court could have considered, he would have to show some causal relationship between these impairments and his termination. In this case, there was no basis for concluding that he was terminated for any reason other than Medtronic's stated ground that he falsified records to show he had completed work assignments. View "Valtierra v. Medtronic Inc." on Justia Law

The Second Circuit affirmed the district court's award of summary judgment to defendants on plaintiff's state law claims of sex discrimination, retaliation, and hostile work environment. The court held that summary judgment was correctly entered in favor of AutoZone on plaintiff's Connecticut claims of discriminatory discharge based on sex, retaliatory discharge for reporting sexual harassment, and a sex hostile work environment because plaintiff failed to adduce sufficient evidence from which a reasonable jury could resolve any of these claims in her favor; the district court correctly concluded that plaintiff's own deposition testimony could not raise a genuine issue of fact as to AutoZone's having notice of plaintiff's sexual harassment by a co‐worker before August 2014 because that testimony was unequivocally contradicted by her own earlier sworn and written statements, and she failed plausibly to explain the numerous contradictions; and the district court correctly concluded that plaintiff failed to raise a genuine issue of fact as to the harassing co‐worker being a supervisor, which was required for AutoZone to be strictly vicariously liable for any ensuing hostile work environment. View "Bentley v. AutoZoners, LLC" on Justia Law

Plaintiff, a former special agent with the Virginia State Police, filed suit under the Americans with Disabilities Act (ADA) and Title VII of the Civil Rights Act against the Commonwealth, seeking relief that includes compensatory damages, reinstatement, and back pay.The Fourth Circuit affirmed the district court's dismissal of the ADA claim, because the Commonwealth has not waived its sovereign immunity from that claim. However, the court reversed the district court's decision that claim preclusion barred the Title VII claims, because the initial forum did not have the power to award the full measure of relief sought in this litigation. Accordingly, the court remanded for further proceedings. View "Passaro v. Commonwealth of Virginia" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment on plaintiff's race discrimination and retaliation claims under Title VII and 42 U.S.C. 1981. In this case, plaintiff was terminated from her position as deputy clerk with the City of Houston, Mississippi as part of a group of layoffs designed to offset the City's budget shortfall. The court held that plaintiff failed to present a genuine issue of material fact that her race was a motivating factor in her termination or that there was a causal connection between her EEOC complaint and that termination. View "Harville v. City of Houston" on Justia Law

Boxill worked at Franklin County Municipal Court. Boxill alleges that the defendants, judges and an administrator, formulated a concealed policy that female employees asserting complaints about abusive and discriminatory treatment by judges would be discouraged and intimidated. She claimed that in 2011 O’Grady began making sexist and racist comments and that Brandt was “hostile and intimidating." Boxill reported this to administrators and judges in 2011-2013; “[n]o administrator or Judge acted ... each discouraged [her] from action.” They began removing her responsibilities. A week after others reported O’Grady’s behavior Boxill was demoted. She claims that O’Grady then recruited other judges to monitor her and her staff. The Defendants began bypassing her and going directly to the Caucasian male subordinate. She resigned and later filed suit, alleging that each Defendant retaliated against her in violation of the First Amendment, 42 U.S.C. 1983, 1981 and contributed to a hostile work environment. The district court dismissed her claims. The Sixth Circuit affirmed in part. Boxill offered no plausible, non-conclusory facts to show that O’Grady was aware of her complaints and cannot demonstrate that O’Grady’s adverse actions were motivated by her protected speech. Reversing as to the hostile work environment claim, the court stated Boxill’s complaint plausibly alleged that O’Grady made sexist and racist comments to her and others for years, she reported that behavior, and the harassment was sufficiently severe and/or pervasive that others found it necessary to memorialize their concerns in writing. View "Boxill v. O'Grady" on Justia Law