Justia Civil Rights Opinion Summaries

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

Plaintiff filed suit against the City, the police department, and others, alleging claims of disability and/or racial or gender discrimination. In regard to the disability discrimination claim, the Eleventh Circuit held that plaintiff's evidence was insufficient to meet her prima facie burden of demonstrating that she was actually disabled, but was sufficient on whether she was regarded as disabled; the district court erred in holding that plaintiff failed to produce sufficient evidence that she was a qualified individual; plaintiff met her prima facie burden of demonstrating that the city discriminated against her because of her perceived disability; and plaintiff produced sufficient evidence that she was not a direct threat.In regard to the race and gender discrimination claims, the court held that the evidence of arbitrary personnel decisions surrounding plaintiff's termination, the pretextual justifications offered for the same, the differing treatment of her white male colleagues, and other evidence amounted to sufficient circumstantial evidence to create a triable issue of material fact on whether the police department's actions were discriminatory on the basis of race and/or gender. Finally, the court rejected plaintiff's municipal liability claim under 42 U.S.C. 1981 for the police chief's discriminatory actions as the final decisionmaker. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Lewis v. City of Union City" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment for the employer in an action brought by plaintiff, a former employee, under the Age Discrimination in Employment Act (ADEA). The court held that plaintiff failed to raise a genuine issue of material fact regarding the employer's reason for firing him. Although the parties agreed that plaintiff made a prima face case of employment discrimination, the court held that the employer provided a legitimate, non-discriminatory reason for firing plaintiff: a broad reduction in force. The court also held that plaintiff failed to show that the employer's reason for firing him was pretextual. In this case, no evidence showed that age was a factor in any of the employer's firing decisions. View "McMichael v. Transocean Offshore Deepwater Drilling, Inc." on Justia Law

Defendants, athletics officials at Binghampton, appealed the district court's denial in part of their motion for summary judgment based on qualified immunity. The Second Circuit held that the district court erroneously conflated the distinct Title VII and 42 U.S.C. 1983 standards for both vicarious liability and causation. The court clarified the differences between discrimination claims brought under Title VII and those brought under section 1983.The court held that section 1983 claims for discrimination in public employment require plaintiffs to establish that the defendant's discriminatory intent was a "but‐for" cause of the adverse employment action; section 1983 claims for discrimination in public employment cannot be based on a respondeat superior or "cat's paw" theory to establish a defendant's liability; and defendants were entitled to qualified immunity because, even when interpreted in the light most favorable to plaintiff, the record cannot support the conclusion that they violated her "clearly established" constitutional rights. Accordingly, the court reversed the district court's order in regard to the section 1983 claims against defendants, entered judgment for defendants, and remanded for further proceedings. View "Naumovski v. Norris" on Justia Law

The Eighth Circuit affirmed the district court's grant of Warren Unilube's motion for summary judgment in an action brought by plaintiff, alleging a race-based claim under Title VII of the Civil Rights Act. Under the McDonnell Douglass framework, the court held that plaintiff made a prima facie case of discrimination because he was a member of a protected group and was terminated. Furthermore, he was qualified for his position.However, the court held that the employer articulated a legitimate, nondiscriminatory reason for plaintiff's discharge based on plaintiff's performance related deficiencies. Finally, the court held that plaintiff failed to demonstrate that Warren's reasons for his termination were pretextual. View "Beasley v. Warren Unilube, Inc." on Justia Law

Plaintiff filed suit against the City, the police chief, and the city administrator, alleging that plaintiff was terminated without due process and in retaliation for his exercise of First Amendment free speech rights. The district court denied defendants' motion for qualified immunity.The Eighth Circuit held that, even if plaintiff were terminated in retaliation for his speech, defendants did not violate a clearly established statutory or constitutional right of which a reasonable person would have known. Furthermore, the disputed facts did not preclude summary judgment because the dispute did not affect the outcome of the suit under the governing law. In this case, defendants could reasonably conclude that plaintiff was speaking solely as an aggrieved police officer and without constitutional protection. Furthermore, plaintiff failed to establish a deprivation of a liberty interest, because he did not show that he was stigmatized by the stated reasons for his discharge and that the statements were made public. Therefore, plaintiff failed to demonstrate a constitutional violation, and the police chief and administrator were entitled to summary judgment. Finally, because plaintiff failed to demonstrate a deprivation of a property or liberty interest, his claims against the City also failed. However, this ruling did not necessarily resolve the city's liability in the retaliation claim. Accordingly, the court reversed in part, affirmed in part, and remanded. View "Mogard v. City of Milbank" on Justia Law

Lavite, a combat veteran, works in the Administration Building of Madison County, Illinois, as superintendent for the County’s Veterans Assistance Commission. In 2015, Madison County officials banned Lavite from the Administration Building indefinitely after learning that Lavite had experienced a PTSD episode during which he threatened a police officer and then kicked out the windows of a squad car. The ban lasted for nearly 20 months. Lavite kept his job but had to work remotely. Lavite had previously resisted efforts to use funds from the Commission’s budget for other county needs. Before the ban was lifted, Lavite filed suit. The district court granted summary judgment for the defendants. The Seventh Circuit affirmed. Lavite’s right to assemble on government property was not violated because the ban on his presence in the building was viewpoint-neutral and reasonably motivated by legitimate safety concerns. None of the evidence supports a reasonable inference of causation between the ban imposed on Lavite in 2015 and his 2013 objections to the proposals to divert some of his Commission’s budget to other purposes. Lavite, having no alleged liberty or property interest, did not establish any due process violation. View "Lavite v. Dunstan" on Justia Law

Plaintiffs filed suit alleging that defendant, the newly elected district attorney, fired them because they supported his political opponent. The district court denied defendant qualified immunity on the individual and official capacity claims.The Fifth Circuit held that defendant was entitled to qualified immunity as to four of the plaintiffs and reversed based on defendant's qualified immunity. However, in regard to the individual capacity claims, the court held that genuine disputes of material fact exist as to whether Cazares, Palmira Munoz, and Maldonado were policymakers or confidential employees. Accordingly, the court dismissed the district court's judgment and remanded for further proceedings. View "Maldonado v. Rodriguez" on Justia Law

Until 2013, Wozniak had tenure on the University of Illinois faculty. He waged an extended campaign against students who did not give him a teaching award. As he had done before when the University enforced school policies, Wozniak filed suit. Disagreeing with the University’s Committee on Academic Freedom and Tenure, the Board of Trustees terminated Wozniak. After the Committee had issued its report, Wozniak posted the entire document and evidence on his website, revealing the identities of the students involved. Wozniak also filed a state court civil suit seeking damages from the students, planning to get a judicial order requiring the students to sit for depositions. Wozniak sued the University alleging violations of the First Amendment. The district court granted the defendants summary judgment. The Seventh Circuit affirmed. Wozniak was fired for intentionally causing hurt to students, and refusing to follow the Dean’s instructions, not simply for publicizing the effects of his actions. Wozniak acted in his capacity as a teacher and used his position to inflict the injuries that precipitated his discharge. The First Amendment does not govern how employers respond to speech that is part of a public employee’s job. How faculty members relate to students is part of their jobs. Speech that concerns personal job-related matters is outside the scope of the First Amendment, even if that speech is not among the job’s duties. View "Wozniak v. Adesida" on Justia Law

Hubbell worked as a FedEx parcel sorter. She alleges that her manager told her she should accept a demotion because “females are better suited to administrative roles and males are better suited to leadership roles,” repeatedly disciplined her, then eventually demoted her from her position as lead parcel sorter based on her sex. She also alleges that FedEx retaliated against her for filing complaints with the Equal Employment Opportunity Commission (EEOC) and for filing a lawsuit by unfairly disciplining her, not allowing her to earn extra pay by clocking in early or clocking out late, and closely surveilling her. Eventually, she was fired. The Sixth Circuit affirmed a jury verdict finding in favor of Hubbell on her Title VII retaliation claim and the reduction of her attorney’s fees from the requested amount. A reasonable factfinder could find that several of the actions Hubbell testified about would be sufficient, on their own or in combination, to dissuade a reasonable worker from filing or pursuing an EEOC complaint. A reasonable factfinder could also find that some or all these acts were taken in retaliation for Hubbell’s EEOC complaints. A reasonable factfinder could determine that, despite its formal anti-discrimination policy, FedEx did not engage in good-faith efforts to comply with Title VII. View "Hubbell v. FedEx SmartPost, Inc." on Justia Law