Justia Civil Rights Opinion Summaries

Plaintiff, a union employee, filed suit alleging that his employer discriminated against him on the basis of his race and/or national origin, and retaliated against him. At issue on appeal is whether the collective bargaining agreement (CBA), which requires arbitration of disputes over discrimination, requires arbitration of statutory claims. The court concluded that the CBA’s arbitration requirement does not encompass statutory discrimination or retaliation claims with wording that is “clear and unmistakable.” Therefore, the court vacated the district court's grant of defendants' motion to compel arbitration and dismissed the complaint, remanding for further proceedings. View "Lawrence v. Sol G. Atlas Realty Co., Inc." on Justia Law

Plaintiffs filed suit alleging 42 U.S.C. 1983 claims for false arrest, malicious prosecution, abuse of process, and excessive force. Plaintiffs were arrested at a party after officers suspected that plaintiffs were trespassing, loitering for the purpose of using narcotics, and endangering the welfare of a child because there was a 12 year-old child present. Charges against plaintiffs were later dropped. The court held that there is a genuine dispute of material fact as to whether the defendant police officers had probable cause to arrest plaintiffs for trespass. Therefore, the court vacated the judgment. The court remanded the false arrest claim and defendants' claim of qualified immunity related to the false arrest. Finally, the court affirmed the dismissal of the malicious prosecution, abuse of process, and municipal liability claims. View "Mitchell v. The City of New York" on Justia Law

Plaintiff and Undercover Officer C0039’s (UC 39) appeal from the district court's judgment finding UC 39 liable for denying plaintiff his right to a fair trial by fabricating evidence in connection with criminal charges against plaintiff, and awarding plaintiff $1 in nominal damages and $20,000 in punitive damages. The district court held that UC 39’s allegedly fabricated account of his own observations could provide the basis for a claim of denial of the right to a fair trial due to an officer’s provision of false information to a prosecutor following Ricciuti v. N.Y.C. Transit Authority. The court held that the district court did not err in denying UC 39’s motion for judgment as a matter of law or in denying plaintiff's motion for a new trial.The court held that Ricciuti, along with the limiting standard therein, applies to false information contained in an officer’s own account of his or her observations of alleged criminal activity giving rise to an arrest which he or she then conveys to prosecutors. Accordingly, the court affirmed the judgment. View "Garnett v. Undercover Officer C0039" on Justia Law

Plaintiffs, individually and on behalf of their respective daughters J.C. and T.H., filed suit against District Defendants and NYSED Defendants. Plaintiffs claim that the district court erred in concluding that plaintiffs did not make a prima facie showing of discrimination against District Defendants pursuant to the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and Section 504 of the Rehabilitation Act (Section 504), 29 U.S.C. 794 et seq. In this case, plaintiffs' disparate impact claim relies exclusively on data concerning students with disabilities under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. 1400 et seq. The court concluded that, aside from their receipt of special education services, the record is devoid of any evidence as to whether the students included in the data qualify as disabled under the ADA or Section 504. Because, as a matter of law, an IDEA disability does not necessarily constitute a disability under the ADA or Section 504, the court concluded that plaintiffs’ data does not establish “a significantly adverse or disproportionate impact on persons of a particular type produced by the defendant’s facially neutral acts or practices.” Therefore, the court concluded that plaintiffs failed to make their prima facie showing that District Defendants’ academic intervention services (AIS) policy adversely impacted individuals protected by the ADA and Section 504. The court concluded that the district court properly entered summary judgment in favor of District Defendants as to the ADA and Section 504 claims. Likewise, the district court properly entered summary judgment on their derivative Section 1983 claim against the District Defendants. The court affirmed the judgment. View "B.C. v. Mount Vernon Sch. Dist." on Justia Law

Plaintiffs, students who are currently enrolled in the District's public school system, filed suit alleging that a majority of the School Board are of the Orthodox/Hasidic Jewish faith or are sympathetic to the interests of the Orthodox/Hasidic Jewish community. Plaintiffs claim that the Board Defendants have promoted the Hasidic Jewish faith in violation of the First Amendment. Plaintiffs argue that defendants' unconstitutional actions contributed to the defunding of the public school system, which in turn injured plaintiffs by depriving them of educational opportunities and by damaging their psychological and mental well‐being.The court held that plaintiffs lack standing to assert an Establishment Clause claim against defendants because they are only indirectly affected by the conduct alleged to violate the Establishment Clause. Therefore, it is unnecessary to decide whether defendants are entitled to absolute or qualified immunity. View "Montesa v. Schwartz" on Justia Law

Plaintiff filed suit under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and the New Your State Human Rights Law, N.Y. Exec. Law 290 et seq., alleging that she was wrongfully terminated in retaliation for complaining of sexual harassment. The district court dismissed the claims, holding that plaintiff's employer could not have engaged in retaliation because it could not be held responsible for the retaliatory animus of plaintiff's co-worker, a low-level employee with no decisionmaking authority. The court held, however, that an employee’s retaliatory intent may be imputed to an employer where, as alleged here, the employer’s own negligence gives effect to the employee’s retaliatory animus and causes the victim to suffer an adverse employment decision. Accordingly, the court vacated and remanded for further proceedings. View "Vasquez v. Empress Ambulance Serv." on Justia Law

Plaintiff, a New York City taxi driver, filed suit under 42 U.S.C. 1983 against the United States alleging that the New York City Taxi and Limousine Commission (TLC) deprived him of his Fourth Amendment rights in various ways. As relevant to this appeal, plaintiff argued that the TLC’s mandate that all New York City taxicabs install technology systems equipped with Global Positioning System (GPS) tracking abilities amounted to a property‐based search pursuant to United States v. Jones, and that this search violated his Fourth Amendment rights. The district court granted summary judgment to defendants. The court affirmed the judgment, concluding that the record is devoid of evidence as to whether plaintiff had any interest in a taxi at the time of an alleged trespass or physical intrusion, plaintiff failed to make a sufficient showing on an essential element of his property‐based Fourth Amendment claim, and thus defendants are entitled to summary judgment. View "El-Nahal v. Yassky" on Justia Law

Plaintiff filed suit against defendants alleging that she was terminated for exercising her First Amendment right to free speech when she spoke to local leaders about what she saw as a "scam" occurring in the police department. The district court held that the officials had not shown entitlement to summary judgment of qualified immunity because, accepting plaintiff's facts as true and drawing all permissible factual inferences in her favor, she had shown that they had violated her clearly established constitutional rights. The court concluded that, under plaintiff's version of the facts, there was no doubt that under the prevailing decisions, plaintiff's speech was not made "pursuant to" her official duties as a patrol officer. Therefore, defendants failed to show entitlement to fire plaintiff or entitlement to qualified immunity under her version of the facts. Accordingly, the court affirmed the judgment. View "Ricciuti v. Gyzenis" on Justia Law

Plaintiff appealed the district court's partial grant of summary judgment to his former employer, Rockbestos, on his claims of hostile work environment and discriminatory discharge. The court held that it lacked appellate jurisdiction to review so much of the district court's judgment as involves plaintiff's claim under the Connecticut Fair Employment Practices Act, Conn. Gen. Stat. 46a‐60. In regard to plaintiff's discriminatory-discharge claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., the Age Discrimination in Employment Act, 29 U.S.C. 621 et seq., the court concluded that, although the district court's explanation of why plaintiff was judicially estopped from asserting that he was qualified for his position was erroneous, the decision was nevertheless correct because plaintiff failed to proffer a sufficient explanation in light of the record why his assertion that he was qualified for his position was consistent with his earlier sworn statement to the SSA that he was “unable to work.” Therefore, the court agreed with the district court that plaintiff failed to establish a prima facie case of discriminatory discharge on summary judgment under the ADA, Title VII, and the ADEA. Finally, the court held that to the extent plaintiff pleaded hostile-work-environment claims in his amended complaint, he has subsequently abandoned these claims. Accordingly, the court affirmed the judgment and dismissed for want of appellate jurisdiction in regard to the CFEPA claim. View "Kovaco v. Rockbestos-Surprenant Cable Corp." on Justia Law

Plaintiff, a Columbia University student, appealed the dismissal of his amended complaint for failure to state a claim. Plaintiff alleged that the University violated Title IX of the Education Amendments of 1972, 20 U.S.C. 1681 et seq., and state law, by acting with sex bias in investigating him and suspending him for an alleged sexual assault. The court concluded that the complaint meets the low standard described in Littlejohn v. City of New York, by alleging facts giving rise to a plausible minimal inference of bias sufficient to survive a motion to dismiss, which the court held applies to Title IX cases. In this case, the complaint alleged that both the investigator and the panel declined to seek out potential witnesses plaintiff had identified as sources of information favorable to him; the investigator and the panel failed to act in accordance with University procedures designed to protect accused students; and the investigator, the panel, and the reviewing Dean reached conclusions that were incorrect and contrary to the weight of the evidence. Accordingly, the court vacated and remanded. View "Doe v. Columbia University" on Justia Law