Justia Civil Rights Opinion Summaries

Plaintiff appealed the district court's dismissal of his 42 U.S.C. 1983 claims against the county and the sheriff. At issue was whether plaintiff's due process rights were violated when the sheriff induced plaintiff to plead guilty to a pending felony charge of terroristic threatening in December 1989. The court concluded that the alleged coercion did not render plaintiff's plea involuntary; there was no imposition of section 1983 liability on a state actor for coercing or inducing a guilty plea that was later determined not to be knowing and involuntary; an official holding a criminal defendant in pretrial custody could reasonably assume that the trial court would properly determine whether the defendant was competent to stand trial or plead guilty; and plaintiff failed to present evidence from which a reasonable jury could conclude that the sheriff's statements were the proximate cause of the violation of plaintiff's constitutional rights. The court held that because plaintiff failed to establish a violation of his constitutional rights by the sheriff, the district court properly dismissed plaintiff's official capacity claims against the sheriff and the county.

Plaintiff, a hearing-impaired employee of the USDA, brought this action under the Rehabilitation Act of 1973, 29 U.S.C. 701 et seq., for workplace discrimination and retaliation. Defendant appealed an adverse bench trial verdict. The court held that plaintiff's failure to apply for a loan specialist position advertised in a job announcement was not excused for futility where the court found no clear error in the district court's finding that the death of plaintiff's father caused her failure to apply for the position; as plaintiff did not make every reasonable attempt to convey her interest in an accretion-of-duties promotion, her claim failed; the court found no clear error in the district court's finding that the reclassifications of certain positions to higher grade levels were not made with discriminatory or retaliatory intent; the district court was correct in refusing to consider incidents in 2009 where these incidents were not included in her complaint or amended complaint; and the district court's determination that plaintiff's allegations considered cumulatively did not amount to discrimination or retaliation was a permissible view of the evidence and was not clearly erroneous. Accordingly, the judgment was affirmed.

Plaintiff sued ATI alleging that it violated his rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601, et seq., and under the Arkansas Civil Rights Act (ACRA), Ark. Code Ann. 16-123-101 et seq. The district court dismissed, finding that plaintiff's claims were subject to a mandatory arbitration provision contained in a collective bargaining agreement between plaintiff's union and ATI. Plaintiff argued that the arbitration provision was invalid because it was joined with an illegal and non-severable waiver of his FMLA claims. The court concluded that the waiver referenced in the last sentence of the arbitration clause was the waiver of judicial forum, not the waiver of plaintiff's claims. The court also concluded that employment-related civil rights claims, like plaintiff's claims, could be subject to a mandatory arbitration provision. Accordingly, the district court was correct in determining that plaintiff's claims must be arbitrated.

In consolidated appeals regarding continuing school desegregation efforts in the Little Rock, Arkansas area, NLRSD and PCSSD each appealed the district court's denial of their petitions for a declaration of unitary status. In addition, NLRSD and PCSSD joined with LRSD, several local teachers' unions, and a union member in appealing the district court's decision to terminate certain funding obligations of the State arising from a previous settlement agreement in this case. The court reversed the denial of unitary status for NLRSD in the area of staff recruitment where NLRSD had maintained levels of black teacher employment that exceeded the percentages in the relevant labor market, when viewed in light of NLRSD's good-faith efforts, which suggested that the vestiges of past discrimination have been eliminated to the extent practicable in the area of recruitment. The court affirmed, however, the denial of unitary status for PCSSD in the area of student assignment, advanced placement, discipline, school facilities, scholarships, special education, staff, student achievement, and monitoring. The court vacated the portion of the district court's order terminating the State's funding obligations under the 1989 Settlement Agreement.

Plaintiff brought suit against defendant, claiming workplace gender discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e, et seq., and the Arkansas Civil Rights Act of 1993, Ark. Code Ann. 16-123-101 et seq. The jury returned a verdict in plaintiff's favor and the district entered judgment against defendant. The court held that improperly admitted compromise evidence, a separation agreement and related testimony, materially prejudiced the jury's verdict and therefore, the court reversed and remanded for a new trial.

Plaintiff appealed the district court's grant of summary judgment dismissing her 42 U.S.C. 1983 suit against the Dean of the University of Iowa's College of Law. Plaintiff alleged that the Dean discriminated against her in violation of her First Amendment rights of political belief and association when plaintiff was not hired to be a full-time instructor or part-time adjunct instructor. The court held that plaintiff had presented sufficient evidence for a fact finder to infer that the Dean's repeated decisions not to hire her were in part motivated by her constitutionally protected First Amendment rights of political belief and association; the facts viewed in the light most favorable to plaintiff were sufficient to establish a violation of her First Amendment rights where it was apparent that a dispute existed regarding a material issue of fact, namely whether the Dean would have made the same hiring decisions in the absence of plaintiff's political affiliations and beliefs; the Dean had not shown that a reasonable university dean in her position would have believed that failing to hire plaintiff was lawful in light of clearly established law; and the district court erred in finding that qualified immunity protected the Dean from liability in her individual capacity. Accordingly, the court reversed the grant of summary judgment and remanded for further proceedings.

Plaintiff brought this action against his former employer alleging wage discrimination and termination on the basis of race and national origin in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., the Minnesota Human Rights Act (MHRA), Minn. Stat. 363.01 et seq., and 42 U.S.C. 1981, as well as breach of his employment contract. The court affirmed the district court's holding that plaintiff failed to establish that the employer's proffered legitimate, nondiscriminatory reason for his termination was pretextual. Plaintiff also had not shown pretext through evidence that similarly situated non Hispanic or non Cuban born employees received more favorable treatment. Accordingly, the district court did not err in granting summary judgment on the Title VII and MHRA claims that plaintiff's termination was a result of unlawful discrimination. The district court also properly granted summary judgment on plaintiff's discriminatory wage claims. Finally, in the absence of evidence of an employment contract or any exception to at will employment, plaintiff's breach of contract claim failed and consequently, plaintiff's section 1981 claim also failed.

Plaintiff sued defendant under 42 U.S.C. 1983 for violations of her constitutional rights when defendant, a building commissioner and Auxiliary Reserve Police Officer, stopped plaintiff's vehicle, arrested her, and searched her car. Defendant then directed her to follow him to an empty parking lot and sexually assaulted her. The district court concluded that defendant was not entitled to qualified immunity and denied his motion for summary judgment. Defendant appealed. The court held that defendant was not entitled to qualified immunity on plaintiff's claim that defendant violated her right to be free from unreasonable seizures by detaining her without reasonable suspicion; the district court should have dismissed plaintiff's claim for unlawful arrest where plaintiff could not show that defendant violated her constitutional right to be free from arrest without probable cause where plaintiff had an outstanding warrant; defendant was not entitled to qualified immunity on plaintiff's claim that defendant searched her car without probable cause; and defendant was not entitled to qualified immunity on plaintiff's claim that defendant violated her substantive due process right to bodily integrity.

Plaintiffs, four women employed by NSP, brought this action alleging discriminatory pay practices under the Equal Pay Act (EPA), 29 U.S.C. 206 et seq., the Minnesota Human Rights Act (MHRA), Minn. Stat. 363.01 et seq., and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The district court granted summary judgment in favor of NSP after concluding that plaintiffs had not established a prima facie case of wage discrimination. Plaintiffs appealed. The court concluded that the district court did not err in holding that the evidence showed that some employers did better than others in given years, but did not establish that NSP was liable for a violation of the EPA. The court also held that the district court did not err in finding that one plaintiff, Helen Goebel, could not make a prima facie case because the St. Cloud Service Center was a different establishment from the Chestnut Service Center and Goebel was the highest paid woman at that facility. Accordingly, the judgment was affirmed.

Plaintiff sued defendants, inter alia, after the local newspaper stopped publishing his letters criticizing the Tripp County Commission. Plaintiff alleged deprivation of his First Amendment rights, deprivation of his Fourteenth Amendment rights, and civil conspiracy under 42 U.S.C. 1985. The district court granted summary judgment in favor of defendants and dismissed all claims. The court affirmed and held that plaintiff failed to establish a violation of his First Amendment rights; plaintiff failed to present sufficient evidence to support a prima facie substantive due process claim or an equal protection claim; and consequently, plaintiff's civil conspiracy claim also failed.