Justia Civil Rights Opinion Summaries

Plaintiff sued the BBG pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., after she did not receive a promotion. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of the BBG. The court agreed with the district court's finding that no reasonable employee could believe that the objected-to conduct was unlawful under Title VII and therefore, summary judgment was appropriately granted on plaintiff's retaliation claims. Although the court had not held that bad faith was required for a party to be entitled to a spoliation inference where, as here, there was a duty of preservation, the error was harmless. Plaintiff's objections to the selection process, even applying a spoliation inference, failed to demonstrate that summary judgment was inappropriately granted on her discrimination claims. Accordingly, the court affirmed the judgment. View "Grosdidier v. Broadcasting Board of Governors" on Justia Law

Appellees sued the District, their employer, for retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The District argued on appeal, inter alia, that it was entitled to a new trial because of improper closing arguments. Appellees' counsel made four inappropriate arguments: three after the district court had sustained objections. The first three arguments were "golden rule" arguments and the fourth argument was a "send a message" argument. As the district court's efforts to cure the resulting prejudice were insufficient, the court reversed and remanded for further proceedings. View "Caudle, et al v. District of Columbia" on Justia Law

This case stemmed from the closure of the Franklin Shelter, an overnight facility for homeless men in downtown Washington D.C. On appeal, plaintiffs alleged that the closure violated federal and D.C. antidiscrimination statutes. The court affirmed the district court's dismissal on res judicata grounds because plaintiffs could have raised these claims in two prior Superior Court cases. View "Sheptock v. Fenty" on Justia Law

Plaintiff filed a complaint pursuant to Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., the District of Columbia Human Rights Act of 1977, D.C. Code 2-1404.01 et seq., and the Civil Rights Act of 1991, 42 U.S.C. 1981a, against the City, alleging that she had suffered sexual harassment during the course of her employment with the DCFEMS. The district court granted the City's motion to dismiss, dismissed plaintiff's Title VII claim with prejudice because she had not filed a timely Charge with the EEOC, and declined to exercise supplemental jurisdiction over her D.C. Human Rights Act claim. On appeal, plaintiff challenged the district court's denial of her motion for reconsideration. The court held that the district court did not err in finding that plaintiff failed to meet the requirements for equitable tolling of the statute of limitations. Plaintiff neither pursued her rights diligently nor proved that some extraordinary circumstance prevented her from satisfying the statute of limitations. Therefore, the court affirmed the judgment. View "Dyson v. District of Columbia" on Justia Law

Appellee Sue Reisinger requested access to reports made by an independent consultant to evaluate AIG's internal policies and past transactions, asserting both common law and First Amendment rights of access. The district court concluded, over the opposition of the SEC and AIG, that Reisinger had a common law right of access and ordered public disclosure of redacted copies of the reports. AIG appealed. The court held that the reports were neither judicial records nor public records. Even assuming the First Amendment right of access applied, the reports were not "aspects of court proceedings" and have no bearing on monitoring judicial conduct. Accordingly, there was no common law or First Amendment right of access to the reports and the court reversed the district court's judgment. View "SEC v. American Int'l Group" on Justia Law

Plaintiff, together with the Second Amendment Foundation, contended that 18 U.S.C. 922(g)(1) was inapplicable to common-law misdemeanants as a class and, alternatively, that application of the statute to this class of individuals violated the Second Amendment. Plaintiff was convicted some forty years ago for common-law misdemeanor assault and battery and consequently was barred for life from ever possessing a firearm under section 922(g)(1). The court held that plaintiff's statutory arguments were unpersuasive and that disarmament of common-law misdemeanants as a class was substantially related to the important governmental objective of crime prevention. Therefore, the court rejected plaintiff's statutory and constitutional challenges, affirming the district court's dismissal of the action. View "Schrader, et al v. Holder, Jr., et al" on Justia Law

Appellant alleged that the District of Columbia violated rights conferred upon him by Article 36(1)(b) of the Vienna Convention on Consular Relations, Apr. 24, 1963, 21 U.S.T. 77, 101, 596 U.N.T.S. 261. Appellant is a national of Jamaica and currently incarcerated in a federal penitentiary. Assuming without deciding that Article 36(1)(b) conferred individually enforceable rights under 42 U.S.C. 1983, the court concluded that appellant's suit was untimely. Accordingly, the court affirmed the district court's grant of summary judgment to the District of Columbia. View "Earle v. District of Columbia" on Justia Law

Appellant brought suit against officials of the Administrative Office, solely in their official capacities, alleging that they rejected her job application in violation of her constitutional rights. The district court dismissed appellant's complaint, concluding that it lacked jurisdiction because the Administrative Office had sovereign immunity from suit. The court reversed the judgment and held that appellant's claim fell within the Larson-Dugan exception to the general rule of sovereign immunity. Since the district court did not address appellees' alternative jurisdiction arguments, the court left all of these arguments for consideration on remand. Accordingly, the court reversed and remanded for further proceedings. View "Pollack v. Duff, et al" on Justia Law

Military chaplains, all non-liturgical Protestants, alleged that the Navy systematically discriminated against members of their religious denominations in the awarding of promotions. The district court denied plaintiffs' motion for a preliminary injunction, concluding that they lacked Article III standing and, alternatively, were unlikely to succeed on the merits. The court concluded that at least those plaintiffs whose promotions would likely be considered by future selection boards operating under the challenged policies have standing to pursue claims for injunctive relief. The court also concluded that the district court's resolution of plaintiffs' denominational preference theory was not based on factual findings that the court could review for clear error. Accordingly, the court reversed the district court's determination that plaintiffs lacked standing to seek injunctive relief. The court also vacated the district court's denial of a preliminary injunction and remanded for further proceedings. View "Chaplaincy of Full Gospel Church, et al v. United States Navy, et al" on Justia Law

The Family Smoking Prevention and Tobacco Control Act, Pub. L. No. 111-31, 123 Stat. 1776, directed the Secretary to issue regulations requiring all cigarette packages manufactured or sold in the United States to bear one of nine new textual warnings, as well as "color graphics depicting the negative health consequences of smoking." Companies challenged the FDA's rule through which it selected nine images that would accompany the statutorily-prescribed warnings. The court held that the FDA failed to present any data showing that enacting their proposed graphic warnings would accomplish the agency's stated objective of reducing smoking rates. Therefore, the court vacated the graphic warning requirements and remanded to the FDA. The court also vacated the permanent injunction issued by the district court.