Justia Civil Rights Opinion Summaries

Plaintiff appealed the dismissal of his disability discrimination and constructive discharge claims against SNS. The court concluded that, viewing the facts in the light most favorable to plaintiff, a reasonable person would not have found his work environment intolerable. Therefore, the district court did not err by granting summary judgment to SNS on plaintiff's claim under the Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213. The court concluded that the fact that an employee is disciplined in accordance with an employment policy is not enough to prove a constructive discharge claim under the MHRA. In this case, while one of plaintiff's supervisors laughed when asked about plaintiff's future at SNS and another supervisor told plaintiff that "this" would continue if he did not resign, the evidence was insufficient to create a material factual dispute about whether plaintiff's work environment was intolerable. The court also concluded that plaintiff did not give SNS a reasonable opportunity to resolve any problems with supervisors and plaintiff admits that he never complained about his supervisors during his employment. Therefore, the district court properly granted SNS summary judgment on plaintiff's constructive discharge claim. The court affirmed the judgment. View "Cosby v. Steak N Shake" on Justia Law

The Army hired URS to destroy munitions at a facility in Arkansas. Smith, a black male, was hired by URS as a full-time temporary instructor/trainer for employees on the Arkansas project. Within months URS hired another black male and a white male (Griffin) for training positions; there were already four individual with various credentials in training positions. Smith alleges that the white man was paid more for essentially the same work and was given a favorable ranking in deciding which trainers should be terminated first, notwithstanding the fact that Griffin had a disciplinary report in his personnel files, for distributing purportedly obscene material in a class. Smith and testified that Griffin had openly conducted a side-business of selling health drinks from his office space at URS on company time without being disciplined. After being terminated during a reduction in forces, Smith sued, alleging race discrimination and retaliation in violation of 42 U.S.C. 1981. The Eighth Circuit reversed summary judgment in favor of URS, noting “evidence of dissembling” that a jury could rely upon to discount URS's claimed rationales for its actions. View "Smith v. URS Corp." on Justia Law

Plaintiffs sell technology that permits computers to identify license-plate numbers in digital photographs taken by cameras mounted on vehicles. The cameras automatically photograph everything the vehicles encounter, with GPS coordinates; software provides notice if a photographed vehicle is subject to repossession. The information is sold to clients, including automobile finance and insurance companies and law enforcement. Arkansas’s Automatic License Plate Reader System Act prohibits use of automatic license plate reader systems and permits any person claiming harm from a violation to seek damages from the violator. Vigilant and its affiliates sued, arguing that “use of [automatic license plate reader] systems to collect and create information” and dissemination of the information constitutes speech and that the Act impermissibly restricts this speech based on content—license-plate data—and on the identity of the speaker, because it exempts some entities, such as law enforcement agencies. The district court dismissed, ruling that state officials were immune from suit under the Eleventh Amendment. The Eighth Circuit affirmed on the ground that the plaintiffs lack standing, so there is no Article III case or controversy. State officials do not have authority to enforce the Act, so they do not cause injury; the Act provides for enforcement only through private actions for damages. View "Digital Recognition Network, Inc. v. Hutchinson" on Justia Law