Justia Civil Rights Opinion Summaries

The Court of Appeals held that, for cases commenced before the effective date of the 2015 amendment to the Human Rights Law, the Equal Access to Justice Act (EAJA) permits the award of reasonable attorneys’ fees and costs to a prevailing plaintiff against the State under the Human Rights Law for sex discrimination in employment by a state agency. In so holding, the Court of Appeals affirmed the judgment of the Appellate Division, concluding that the civil action in this case was eligible for an award of attorneys’ fees. Previously, Supreme Court held that attorneys’ fees and costs should not be awarded because the EAJA did not apply “where a plaintiff has recovered compensatory damages for tortious acts of the State and its employees.” View "Kimmel v. State" on Justia Law

Marshall Parker sought an award of benefits for a back injury he received during the course of his employment with Webster County Coal. An administrative law judge (ALJ) awarded benefits for the back injury. However, the ALJ found that, pursuant to Ky. Rev. Stat. 342.730(4), Webster County Coal did not have liability for payment of income benefits in addition to the two years of temporary total disability income benefits Parker had already received. The Workers’ Compensation Board and Court of Appeals affirmed. Parker appealed, arguing that section 342.730(4) is unconstitutional because, under the statute, injured older workers who qualify for normal old-age Social Security retirement benefits are treated differently from injured older workers who do not qualify. The Supreme Court reversed in part, holding that section 342.730(4) is constitutionally infirm on equal protection grounds because there is no rational basis or substantial and justifiable reason for the disparate treatment of two groups of workers. View "Parker v. Webster County Coal, LLC" on Justia Law

Shantel Jackson filed suit against former boxing champion Floyd Mayweather, Jr., alleging, inter alia, claims for invasion of privacy, defamation, and intentional and negligent infliction of emotional distress. Plaintiff's claims were based, either entirely or in part, on Mayweather's social media postings about the termination of Jackson's pregnancy and its relationship to the couple's separation and his comments during a radio interview concerning the extent to which Jackson had undergone cosmetic surgery procedures. Mayweather filed a special motion to strike under Code of Civil Procedure section 425.16, (the Anti-SLAPP statute). The trial court denied the motion. The court concluded that the challenged causes of action arose from protected activity under section 426.16, subdivision (e)(3); the statements concerned an issue of public interest; and Jackson failed to demonstrate a probability of prevailing on her cause of action for defamation and most aspects of her causes of action for invasion of privacy. Accordingly, the court reversed with respect to Jackson's causes of action for defamation and false light portrayal and her cause of action for public disclosure of private facts based on Mayweather's comments about cosmetic surgery. The court affirmed in all other respects. View "Jackson v. Mayweather, Jr." on Justia Law

Petitioner, a former researcher employed by Johns Hopkins University School of Medicine (JHU), filed suit against JHU alleging (1) he was wrongfully terminated in retaliation for his repeated protests of research misconduct in violation of 42 U.S.C. 289b and 42 C.F.R. 93; and (2) conversion because after the termination of his employment, he was denied access to stored research materials he had collected. The circuit court granted JHU’s motion to dismiss because Petitioner failed to identify a public policy exception to the at-will employment doctrine and because JHU “could not have converted what it in fact had ownership of.” The Court of Special Appeals affirmed. The Court of Appeals affirmed, holding (1) Plaintiff was not wrongfully terminated, and his at-will employment came to an end due to the expiration of his employment contract; and (2) Plaintiff’s claim of conversion must fail because JHU owned the research materials pursuant to its stated policies. View "Yuan v. Johns Hopkins University" on Justia Law

Teresa Jones filed claims against Truman Arnold Companies (TAC) for negligent supervision, retention, and hiring of a store manager, claiming that she was a victim of sexual assault and harassment while employed by TAC and that she was exposed to this harm due to TAC’s negligence. TAC moved to dismiss the complaint, arguing that Jones’s sole remedy was through the Workers’ Compensation Act and that the Arkansas Workers’ Compensation Commission had the exclusive jurisdiction to determine the applicability of the Act. The circuit court denied the motion to dismiss, ruling that the Act did not provide coverage for Jones’s claims because her alleged injuries amounted to “mental injury or illness,” which is not compensable under workers’ compensation. The TAC subsequently filed a petition for writ of prohibition. The Supreme Court granted the petition, holding that the issue of jurisdiction resided exclusively with the Workers’ Compensation Commission because the facts, as presented in the complaint, could not be determined to fall outside the Act as a matter of law. View "Truman Arnold Cos. v. Miller County Circuit Court" on Justia Law

Patricia Adams filed claims against Truman Arnold Companies (TAC) for negligent supervision, retention, and hiring of a store manager, claiming that she was a victim of sexual assault and harassment while employed by TAC and that she was exposed to this harm due to TAC’s negligence. TAC moved to dismiss the complaint, arguing that Adams’s sole remedy was through the Workers’ Compensation Act and that the Arkansas Workers’ Compensation Commission had the exclusive jurisdiction to determine the applicability of the Act. The circuit court denied TAC’s motion to dismiss, concluding that the allegations fell outside of the Commission’s jurisdiction. TAC then petitioned the Supreme Court for a writ of prohibition to preclude the circuit court from continuing to exercise jurisdiction over Adams’s claims against TAC. The Supreme Court granted the writ of prohibition, holding that the writ was warranted for the reasons stated in Truman Arnold Cos. v. Miller County Circuit Court, handed down this same date. View "Truman Arnold Cos. v. Miller County Circuit Court" on Justia Law

Plaintiff filed a complaint against her former employer (Defendant), claiming assault, sexual assault, and battery, among other causes of action. Defendant moved for summary judgment on all claims, arguing, in part, that the Texas Commission on Human Rights Act’s (TCHRA) statutory cause of action preempted Plaintiff’s common law claims. The trial court granted the motion without providing a basis for its ruling. Plaintiff appealed only the trial court’s ruling on her assault claim against Defendant. The court of appeals affirmed on the ground that the TCHRA preempted Plaintiff’s assault claim. The Supreme Court reversed, holding (1) where the gravamen of a plaintiff’s claim is not harassment, but rather, assault, the TCHRA does not preempt the plaintiff’s common law assault claim; and (2) because the gravamen of Plaintiff’s complaint in this case was assault, Defendant did not establish, as a matter of law, that Plaintiff’s claim was preempted by the TCHRA. Remanded. View "B.C. v. Steak N Shake Operations, Inc." on Justia Law

Charlene Berdahl, a court reporter, filed a sexual harassment complaint against Judge George Huss, a district judge, with the Montana Human Rights Bureau (HRB). Huss’s attorney requested that the State agree to defend and indemnify Huss regarding Berdahl's HRB claims. Berdahl and Huss subsequently entered into a stipulated judgment resulting from the State’s refusal to defend and indemnify. The State filed this action seeking declarations that the State had no duty to defend or indemnify Huss against the claims and that Huss had entered a settlement without the consent of the State, which was unenforceable against the State. Berdahl counterclaimed seeking declarations that the State was responsible for the stipulated judgment entered by Berdahl and Huss and that the State was liable under the principle of respondent superior. The district court rejected Berdahl’s request for a declaration and held that the State owed no duty to defend or indemnify Huss. The court further reasoned that Berdahl’s exclusive remedy regarding her respondent superior claim was under the Montana Human Rights Act. The Supreme Court affirmed, holding that the district court did not err in concluding that the State bore no obligation to pay the stipulated settlement between Huss and Berdahl. View "State v. Berdahl" on Justia Law

This appeal stems from an officer-involved shooting in the early morning hours of September 19, 2011. At approximately 3:50 a.m., plaintiff Matthew Carabajal was driving a vehicle containing three other individuals, including his infant son V.M.C., when he noticed that he was being followed by a police vehicle with its lights and siren activated. Plaintiff drove for several blocks. Other officers were notified and reported to the scene. Plaintiff pulled over, the officers exited their police cars, and one officer stepped in front of plaintiff’s vehicle. Soon thereafter, plaintiff’s vehicle began to move forward. The officer fired two rounds from his shotgun at plaintiff, severely injuring him. At that time, V.M.C. was still in the vehicle, secured in a car seat behind the front passenger. V.M.C., through Mathew and V.M.C.’s mother, Arianna Martinez, appealed the district court’s judgment in favor of defendants-appellees Officers Joshua Thornton and Michael Sutton, and Defendant-Appellee City of Cheyenne (“the City”). On appeal, plaintiffs challenged: (1) the district court’s grant of a motion to dismiss plaintiffs’ Fourth Amendment claim of unlawful seizure of V.M.C. by Officer Thornton when he shot into the vehicle that V.M.C. occupied; (2) the grant of summary judgment in favor of the officers based upon qualified immunity as to Carabajal’s excessive force claims; and (3) the district court’s initial dismissal of, and later grant of summary judgment in favor of the City on, Plaintiffs’ claims of negligent hiring of Officer Thornton. Finding no reversible error, the Tenth Circuit affirmed. View "Carabajal v. City of Cheyenne" on Justia Law

Plaintiff filed suit alleging, inter alia, violation of his First and Fourth Amendment rights after he was silenced and then ejected at a city council meeting. The court dismissed Councilman Roberts's appeal of the district court's denial of summary judgment based on qualified immunity because a factual dispute exists as to whether Roberts's conduct was viewpoint-based; affirmed the district court's grant of summary judgment for Roberts as to punitive damages where there is no question that Roberts's conduct did not rise to the level of reckless indifference or evil intent; affirmed the district court's grant of summary judgment for Black on the First Amendment claim because his actions as sergeant-at-arms were not objectively unreasonable in light of clearly established law; affirmed the district court's grant of summary judgment for Black on the Fourth Amendment claim based on qualified immunity; affirmed the district court's grant of summary judgment on the false arrest claim; and dismissed Black’s cross-appeal on the state tort claims for lack of jurisdiction. View "Heaney v. Roberts" on Justia Law