Justia Civil Rights Opinion Summaries

In 1997, Campos began working as a Cook County Sheriff’s Office correctional officer. In 2011, he was arrested for driving under the influence, striking a vehicle, and leaving the scene of an accident. Campos self-reported. The sheriff suspended him without pay and referred him for termination. The Merit Board has exclusive authority to terminate Sheriff’s Office employees. While the Board proceedings were ongoing, a state court granted Campos’s motion to suppress and quashed his arrest. The Board voted to terminate Campos. The circuit court vacated that decision as too vague to allow for judicial review and remanded. In 2017, the Board again voted to terminate Campos. The circuit court again remanded based on a defect in the Board’s composition. It had been almost seven years since the sheriff suspended Campos without pay. Rather than wait for a third Board decision, Campos filed suit in federal court, arguing that the protracted proceedings have violated his substantive due process rights. The Seventh Circuit affirmed the dismissal of his claims. Campos has not met the high standard for stating a substantive due process claim. Employment rights are not fundamental rights and Campos identified no independent constitutional violation. The eight-year process is not so arbitrary or outrageous as to violate substantive due process. View "Campos v. Cook Countyx" on Justia Law

The Eighth Circuit affirmed the district court's grant of defendant's motion for summary judgment in an action challenging the decision of the Pine Bluff Arsenal (PBA) not to hire plaintiff. Under the McDonnell Douglas burden-shifting framework, the court held that plaintiff failed to show that PBA's reasons for hiring other candidates were pretextual. In this case, no reasonable factfinder could conclude that the decision to hire other candidates was motivated by race, where such a conclusion would require speculation because plaintiff has not produced sufficient evidence to raise a reasonable inference of discrimination. View "Farver v. McCarthy" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to the employer in an action brought by plaintiff, alleging claims under Title VII of the Civil Rights Act and the Iowa Civil Rights Act for retaliation, discrimination, and hostile work environment.The court held that summary judgment on the retaliation claim was proper under the McDonnell Douglas burden-shifting framework. Even assuming plaintiff established a prima facie showing of retaliation, substantial evidence in the record supported the employer's proffered reason for its termination of plaintiff: she repeatedly micromanaged and interfered with other employees. Therefore, plaintiff failed to show that the employer's reason for her termination was pretextual. The court also held that plaintiff failed to establish a prima facie case of hostile work environment based on sex, because her actions demonstrated that she did not personally experience offensive or unwelcome harassment. Furthermore, plaintiff's claim for hostile work environment based on a protected activity failed, because she failed to show that she experienced harassment so severe or pervasive as to constitute a materially adverse action. Finally, plaintiff waived her discrimination claims. View "Mahler v. First Dakota Title Limited Partnership" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Norac in an action brought by plaintiff, a Norac employee, alleging claims of employment discrimination following her termination. The court held that plaintiff failed to meet her burden of presenting evidence that created a fact question as to whether Norac's proffered reason for her termination was pretextual, and thus summary judgment was appropriate. The court also held that the district court did not abuse its discretion by denying plaintiff's motion to strike an email and its admission did not prejudice plaintiff. View "Lacey v. Norac, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Nationwide in an action brought by plaintiff, an employee of Nationwide, alleging discrimination against her on the basis of her sex and her age. The court held that plaintiff failed to show Nationwide's legitimate non-discriminatory reasons for not selecting her for vacant positions and promotions were pretexts for age or gender bias. In this case, Nationwide's treatment of a younger male employee similarly to plaintiff was the clearest example of a record reflecting a displeased manager rather than discrimination based on age or gender. View "Heisler v. Nationwide Mutual Insurance Co." on Justia Law

Plaintiff filed suit alleging that DHS engaged in discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964. The district court granted summary judgment for DHS and denied plaintiff's motion to stay proceedings to allow for discovery.The DC Circuit held that the district court erroneously concluded that the evidence sought by plaintiff could not create a dispute of material fact as to whether DHS's proffered reasons for taking adverse action were pretextual. The court also held that summary judgment was inappropriate with respect to plaintiff's claim that her reassignment to the Resource Management Branch was retaliatory. However, summary judgment was appropriate with respect to DHS's initial decision to extend her detail, because plaintiff did not create a genuine dispute of material fact. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Cruz v. McAleenan" on Justia Law

Stepp sued his former employer, Covance, alleging violations of 42 U.S.C. 2000e–3, by refusing to hire him permanently in retaliation for his earlier complaints about discrimination. Stepp received positive performance reviews in his first nine months. Two of Stepp’s temporary coworkers were made permanent around their nine-month anniversary. While a temporary worker, Stepp, an African-American male, complained that Casteel, his team leader, treated female and white employees better than male and African-American employees and confronted Casteel directly. A manager investigated Stepp’s complaints but found them baseless. Stepp filed formal charges with the EEOC Casteel complained to Ball, a supervisor, that Stepp often stared at him, shook his head, smirked, and said “uh oh.” Shortly thereafter, with Stepp still in temporary status, Covance froze new hires in his department. Stepp asked Ball if Covance did not give him permanent status before the freeze because Casteel had complained about him; she responded “yes.” Stepp’s one-year term as a temporary worker ended soon after. Grubb, a human resources partner, planned to give a 90-day extension to temporary workers whose terms ended near the December holidays but Covance advised him that a 90-day extension was too long, so he shortened the extensions. The Seventh Circuit vacated a judgment in favor of Covance. A reasonable jury could conclude that Covance refused to promote Stepp to permanent status because of his complaints. View "Stepp v. Covance Central Laboratory Services, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court granting summary judgment for the City of Scottsbluff, Nebraska and dismissing Plaintiff's claim of discrimination and retaliation under the Nebraska Fair Employment Practice Act (NFEPA), holding that the City was entitled to summary judgment on Plaintiff's claims.Plaintiff, a former police officer for the City, was terminated when he refused to undergo a fitness-for-duty examination (FFDE). Plaintiff brought this action alleging discrimination and retaliation. The district court granted the City's motion for summary judgment. The Supreme Court affirmed, holding (1) based on the undisputed evidence in the record, the City could lawfully require Plaintiff to undergo an FFDE under Neb. Rev. Stat. 48-1107.02(1)(j); and (2) because Plaintiff alleged that the City retaliated against him for expressing disapproval of his fellow employees' actions, as to his employer's actions, there was not a genuine issue of material fact as to whether Plaintiff engaged in protected activity pursuant to Neb. Rev. Stat. 48-1114(3). View "McPherson v. City of Scottsbluff" on Justia Law

Plaintiff filed suit against her employees, alleging that they unlawfully terminated her in retaliation for exercising her rights under the Family and Medical Leave Act (FMLA) and the Missouri Human Rights Act (MHRA). Plaintiff's husband filed suit for loss of consortium.The Eighth Circuit held that the district court did not err in granting defendants summary judgment on the FMLA claim, because plaintiff's use of FMLA leave some half-year prior to her termination was insufficient to show her termination was an act of discrimination. The court also held that the district court did not err in granting summary judgment in favor of defendants on the MHRA claim, because plaintiff could not have had a reasonable good faith belief that the conduct she opposed had constituted disability discrimination in violation of the MHRA. For purposes of the MHRA, accusing an employee of racism does not constitute racial discrimination. Furthermore, evidence of general temporary work restrictions, without more, was insufficient to constitute a disability. Finally, the loss of consortium claim was properly dismissed. View "Lovelace v. Washington University School of Medicine" on Justia Law

The Eleventh Circuit vacated and remanded the district court's grant of defendant's motion to dismiss the complaint alleging that defendant demoted plaintiff because of his multiple sclerosis in violation of Title I of the Americans with Disabilities Act (ADA). The court weighed the balancing factors to determine whether an entity acts as an arm of the state entitled to sovereign immunity, and held that, when defendant demoted plaintiff, it did not act as an arm of the state and was thus not entitled to sovereign immunity. In this case, the Alabama Supreme Court previously held that a communications district was not an arm of the state; there was no evidence that the State of Alabama exerts any control over the particular function at issue here; where the entity derives its funds, did not support granting sovereign immunity; and Alabama would not be financially responsible for a judgment against defendant. View "McAdams v. The Jefferson County 911 Emergency Communications District, Inc." on Justia Law