Justia Civil Rights Opinion Summaries

Appellant was terminated for cause from his employment with Northwest Airlines shortly after he was arrested for possession of marijuana. At the same time, appellant had pending with Northwest a request for disability retirement benefits. Northwest later granted appellant's request, but he was ineligible for certain retirement benefits as a result of the termination. Appellant sued Northwest, claiming that the termination violated section 510 of the Employment Retirement Income Security Act (ERISA), 29 U.S.C. 1140. The district court denied Northwest's motion to dismiss for lack of subject-matter jurisdiction, but granted its motion for summary judgment. The court held that the district court properly exercised jurisdiction over the case where appellant's claim did not require an interpretation of a collectively bargained agreement. The court also held that appellant failed to show a causal connection between his termination and his application for disability retirement benefits. The court rejected appellant's remaining arguments. Accordingly, the court affirmed the judgment of the district court.

Plaintiff filed suit against St. Louis police officers for violating his Fourth Amendment rights by unlawfully entering his home, using excessive force, and unlawfully arresting him, and for violating Missouri common law by maliciously prosecuting him. A jury rendered a verdict for plaintiff on the unlawful entry claim and for the officers on the excessive force, unlawful arrest, and malicious prosecution claims. At issue was whether the district court abused its discretion by failing to order a jury to award nominal damages following the entry of the verdict and by denying plaintiff's Rule 59(e) motion to alter or amend the judgment to award nominal damages. The court affirmed the judgment of the district court and held that the district court did not plainly err in denying either plaintiff's post-verdict request to direct the jury to award nominal damages, or his Rule 59(e) motion to alter or amend the judgment to award nominal damages. The court also declined to adopt an exception to Rule 51 that would permit plaintiffs to request nominal damages after the verdict was rendered.

Plaintiff, a member of the Westboro Baptist Church (WBC), believed that God was punishing America for tolerating homosexuality and the WBC expressed its views by protesting at funerals, including those of American soldiers. Plaintiff brought a First Amendment challenge to a Manchester, Missouri ordinance that regulated protests near funerals. The district court ruled in favor of plaintiff, awarding nominal damages and enjoining enforcement of the ordinance. The court agreed that plaintiff had standing to challenge the ordinance where the ordinance specifically targeted plaintiff's conduct, but challenges to two earlier versions of the ordinance were moot. The court held that the district court erred in concluding that the ordinance was a content based regulation. The court affirmed, however, the district court's alternative conclusion, relying on Phelps-Roper v. Nixon, that the ordinance could not survive because it was not narrowly tailored to serve a significant government interest where Manchester had no significant interest "in protecting funeral attendees from unwanted communication." Accordingly, the judgment of the district court was affirmed.

Plaintiffs, six current and former African-American employees, brought suit against Nucor alleging racial discrimination in violation of 42 U.S.C. 1981 and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2000e-17. The district court denied plaintiffs' requests for class certification, granted summary judgment in favor of Nucor on several claims and the case proceeded to trial. A jury returned verdicts against Nucor and awarded each plaintiff monetary damages. The parties appealed and cross-appealed, contesting various rulings by the district court. The court held that the district court did not abuse its discretion in believing that evidence of a previous enforcement action alleging race discrimination at the Blytheville plant was relevant to the credibility of plaintiffs' allegations. The court also held that the district court properly admitted certain statements at issue. The court further held that because Nucor failed to renew its motion under Rule 50(b), the court was without power to disturb the district court's entry of judgment on the jury's punitive damages award. The court finally held that the district court did not abuse its discretion by concluding that plaintiffs had not met their burden of demonstrating the commonality of their claims and that summary judgment was warranted on plaintiffs' disparate impact claims, failure-to-train disparate treatment claims, and failure-to-promote disparate treatment claims. Accordingly, the judgment of the district court was affirmed.

Plaintiff sued defendant, asserting racial discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e to 2000e-17, and the Arkansas Civil Rights Act, Ark. Code Ann. 16-123-101 to -108. The district court granted defendant's motion for summary judgment. The court held that defendant offered nondiscriminatory, legitimate grounds for its decisions not to promote plaintiff and to terminate him. The court also held that, considering both plaintiff's individual claims and the cumulative effects of those claims, no reasonable jury could find pretext or discrimination. Therefore, the court affirmed the grant of summary judgment to defendant on plaintiff's claim that he was not promoted because of racial discrimination. The court also held that plaintiff's retaliation claim was properly dismissed.

This case arose out of a dispute between plaintiff and her ex-husband over the education and custody of their three minor children. Plaintiff sued City Defendants, alleging that they unlawfully impeded her access to the children. Plaintiff sued the School District Defendants, asserting that they unlawfully denied her access to the children and their education records. The district court dismissed plaintiff's claims against the City Defendants for failure to state a claim and granted summary judgment for the School District Defendants. The court held that the fact that plaintiff lived in a different state did not suffice to convert the loss of a single three-hour visit into a deprivation of a fundamental right for purposes of substantive due process and, even if plaintiff could show a deprivation, the City Defendants' alleged conduct would not shock the conscience. The court also held that plaintiff failed to state a procedural due process claim against the City Defendants, given the relatively minimal deprivation alleged in this case, where the post-deprivation procedures were adequate to protect her rights to be heard at a meaningful time and in a meaningful manner. The court further held that plaintiff had no fundamental liberty interest in contacting her children at their schools and the court agreed with the district court that an attendance clerk's one-time refusal to tell plaintiff why one of the children had been absent from school, a coach's referral of plaintiff to her ex-husband for information about the children's swimming activities, and the school's refusal to send plaintiff all of the school's projects she requested did not amount to a deprivation of a fundamental liberty interest. Given the limited nature of any infringement of plaintiff's protected liberty interest, the procedures at issue were sufficient to protect plaintiff's right to procedural due process. The court finally held that plaintiff's right, as a non-custodial parent, under state law and her role in the children's lives vary significantly from the rights and role afforded to the ex-husband or to a typical married parent. Therefore, the court affirmed the grant of summary judgment to defendants with respect to her equal protection claims. Accordingly, the judgment of the district court was affirmed.

Plaintiffs, parents of deaf and hearing impaired children, brought suit against defendants, claiming that the closure of the South Dakota School for the Deaf and the discontinuation of its programs at the school's campus violated state and federal law. The complaint sought, among other things, class certification and an order enjoining the closure of the school and outsourcing of its programs to other school districts. Plaintiffs subsequently appealed from the district court's order granting summary judgment in favor of defendants. The court held that the district court did not err in converting defendants' motion to dismiss to a motion for summary judgment. The court also held that plaintiffs have failed to allege facts to support their claim that the school's discontinuation of education programs at the Sioux Falls campus violated the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., and therefore, the district court properly granted summary judgment in favor of defendants on that cause of action. The court further held that plaintiffs have failed to point out any facts supporting their claim that their constitutional rights were violated and therefore, their 42 U.S.C. 1983 cause of action against defendants in their individual capacities failed. The court finally held that plaintiffs did not have standing to sue on behalf of students in the auditory-oral program because they could not show an injury in fact. Therefore, the court concluded that it was within the South Dakota Board of Regents' power to discontinue offering education programs at the school's campus, in favor of contracting with other school districts to offer those programs and maintaining funds in its budgets for students to attend residential programs.

Two administrative hearing panels (Panels) concluded that the school district failed to provide plaintiffs' twin sons with a free appropriate public education (FAPE) in 2005, pursuant to the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq., but did provide one in 2006. The district court upheld these decisions and later awarded attorney's fees to plaintiffs. Plaintiffs and the school district cross appealed. The court held that the school district offered the twins a FAPE in 2005 and therefore, reversed the award of a reduced attorney's fee. The court affirmed, however, the district court's ruling that plaintiffs waived or abandoned their appeal of the Panels' 2006 FAPE decision.

Plaintiff appealed the dismissal of her action against a former employer alleging race, sex, and age discrimination and retaliation in violation of Title VII. The district court concluded that plaintiff had not filed a charge of discrimination with the EEOC within 300 days of her termination, as required to exhaust her claim, and therefore dismissed the case for failure to state a claim. The court held that because the district court rested its factual conclusions on matters outside the pleadings, it erred by failing to convert the employer's motion into one for summary judgment under Federal Rule of Civil Procedure 56. This error did not prejudice plaintiff with regard to her claims of age discrimination and retaliation, so the court affirmed the district court's dismissal in this respect. The court held that because the error was prejudicial with respect to the remaining claims of race and sex discrimination, however, the court reversed the district court's dismissal and remanded for further proceedings.

Plaintiff sued her employer under the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-43, and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601-54, and asserted other state common law claims including breach of employment contract. Plaintiff subsequently appealed the dismissal of her breach of contract claim with prejudice, the denials of her motions for leave to amend her complaint, the denial of her motion for consideration, and the adverse grant of her MHRA and FMLA claims by the district court. The court did not reach the merits of plaintiff's arguments because any error with respect to the dismissal of the breach of employment contract claim was harmless where plaintiff resigned from her employment with the county and failed to generate a genuine issue of fact as to constructive discharge in the context of her MHRA reprisal claim. The court also held that because plaintiff failed to generate an issue of fact as to whether she suffered a materially adverse employment action, summary judgment was appropriate as to her MHRA retaliation claim. The court further held that summary judgment was properly granted on plaintiff's FMLA interference claim where plaintiff did not contest the district court's finding that she received the full twelve weeks of FMLA leave to which she was entitled each year she requested it. The court finally held that summary judgment was properly granted on plaintiff's FMLA retaliation claim where she failed to generate an issue of fact as to whether she suffered an adverse employment action.