Justia Civil Rights Opinion Summaries

Appellant Jessica Adams worked for C3 Pipeline Construction, Inc. (“C3”) on a pipeline construction crew. C3 subcontracted with Alpha Crude Connector, LLC (“Alpha Crude” or “ACC”) on an ACC pipeline system in New Mexico and Texas. Adams alleged that three C3 workers sexually harassed her while they were working on this project in New Mexico. She sued C3 and Plains Defendants, Alpha Crude’s corporate successors, under federal and New Mexico law. When Plains Defendants answered the complaint, they moved for summary judgment, attaching their Master Service Agreement (“MSA”) with C3 and affidavits from managers stating that Plains Defendants did not “employ” C3’s workers. Adams opposed the motion, moved under Federal Rule of Civil Procedure 56(d) to take discovery on her alleged “employment” relationship with Plains Defendants, and argued for the first time that Plains Defendants should have been liable for breaching their duty to keep her safe on their premises. The district court granted summary judgment to Plains Defendants, denied Adams’s Rule 56(d) motion, and construed her premises liability argument as a motion to amend her complaint and denied it as futile. That same day, the district court ordered Adams to serve a summons and the complaint on C3, which she did. When C3 did not answer the complaint, the court entered a default judgment against C3 and ordered it to pay Adams $20,050,000. Within 30 days of that order, Adams appealed the district court’s grant of summary judgment to Plains Defendants. After its review, the Tenth Circuit: (1) denied Plains Defendants’ motion to dismiss this appeal as untimely; (2) affirmed the district court’s summary judgment and Rule 56(d) rulings; and (3) vacated its denial of Adams’s motion to amend and remanded for further proceedings. View "Adams v. C3 Pipeline Construction, et al." on Justia Law

This case arose from the fatal shooting of Logan Simpson by Jon Little, a patrol officer for the City of Bixby, Oklahoma. Tiffany Simpson, Logan Simpson’s mother and personal representative of his estate, sued Officer Little in his individual capacity under 42 U.S.C. 1983 for excessive force in violation of Simpson’s Fourth and Fourteenth Amendment rights. Officer Little moved for summary judgment on qualified immunity grounds. The district court denied the motion. Officer Little appealed. After review, the Tenth Circuit affirmed, finding: (1) the Court lacked interlocutory appellate jurisdiction to review the district court’s conclusion that a jury could find a constitutional violation because Officer Little challenged the factual basis for the court’s determination; (2) the Court also lacked jurisdiction to consider some of Officer Little’s arguments regarding clearly established law; and (3) the Court found his remaining arguments lack merit. View "Simpson v. Little, et al." on Justia Law

This case arose from the tragic death of Dillon Taylor, who was shot and killed by Salt Lake City Police Officer Bron Cruz. Officer Cruz and two fellow officers were following up on a 9-1-1 call reporting that a man had flashed a gun. The caller described the man and noted that he was accompanied by another male whom the caller also described. The officers attempted to stop Taylor and two male companions because two of the three men matched the caller’s descriptions. While Taylor’s companions immediately complied with the responding officers’ commands to stop and show their hands, Taylor did not. Instead, he made a 180-turn and walked away. Firearms in hand, but not pointed at Taylor, Officer Cruz and another responding officer followed Taylor. At some point, Taylor turned to face Officer Cruz, continuing to walk backwards with his hands in his waistband, "appeared to be digging there, as if Mr. Taylor was manipulating something." Then, without any verbal warning, Taylor quickly lifted his shirt with his left hand - exposing his lower torso -and virtually simultaneously withdrew his right hand from his waistband. The motion took less than one second and was consistent with the drawing of a gun. Reacting to Taylor’s rapid movement, Officer Cruz shot Taylor twice—firing in quick succession. Taylor died at the scene. When he was searched, Taylor was unarmed; in particular, he did not have a gun. Taylor’s estate and family members (collectively, “Plaintiffs”) filed this lawsuit under 42 U.S.C. 1983, asserting claims against Salt Lake City and Officer Cruz (and others). The question this appeal presented for the Tenth Circuit's review was whether Officer Cruz’s decision to shoot Taylor was reasonable based on the totality of the circumstances. Concluding that it was, the Tenth Circuit affirmed the district court's judgment. View "Estate of Dillon Taylor, et al. v. Salt Lake City, et al." on Justia Law

Plaintiff Nicholas Roberts appealed the district court’s grant of summary judgment in favor of Defendants James Winder, Rosie Rivera (solely in her official capacity as Salt Lake County Sheriff), and the Unified Police Department of Greater Salt Lake (“UPD”) (collectively, “Defendants”) on Roberts’ 42 U.S.C. 1983 and the Age Discrimination in Employment Act (“ADEA”) claims. All of his claims arose from his removal as Range Master-Firearms Instructor (“Range Master”). On March 1, 2017, at Winder’s request, Undersheriff Scott Carver and Chief Deputy Shane Hudson met with Roberts and informed him that the Range Master position was being eliminated. Hudson told Roberts he would be reassigned to patrol duties and his pay would be reduced. On March 9, Roberts, through counsel, sent a letter to Winder objecting to his removal, reassignment, and pay reduction. Winder treated Roberts’ letter as a grievance and rejected the grievance, explaining that the Range Master was subject to transfer under Merit Commission Policy 3140, Range Master was a specialist position, and Roberts’ merit rank was “sergeant.” The UPD Board later ratified Winder’s decision to remove Roberts as Range Master and reassign him to patrol duties as a sergeant. Winder later assigned Todd Griffiths, a merit rank Lieutenant four years younger than Roberts, to oversee the shooting range. Roberts did not appeal his grievance, and instead filed this complaint in the district court. In June 2017, after Roberts initiated this lawsuit, the UPD conducted two investigations of Roberts’ management of the Range. Both investigations described failures in Roberts’ performance as Range Master. The district court granted partial summary judgment to Defendants on Roberts’ declaratory judgment and due process claims, finding that Roberts did not have a property interest in his position as Range Master, and thus his reassignment did not violate due process. Alternatively, the district court held that Roberts waived his due process claims by failing to appeal Winder’s decision to the Merit Commission. After review, the Tenth Circuit found no reversible error and affirmed the grant of summary judgment in favor of defendants. View "Roberts v. Winder, et al." on Justia Law

The estate of a mentally ill and intellectually disabled prisoner who committed suicide while in Utah Department of Corrections (“UDC”) custody appealed the dismissal of its lawsuit against the UDC. Brock Tucker was seventeen when he was imprisoned at the Central Utah Correctional Facility (“CUCF”). At CUCF, Tucker endured long periods of punitive isolation. CUCF officials rarely let him out of his cell, and he was often denied recreation, exercise equipment, media, commissary, visitation, and library privileges. Tucker hanged himself approximately two years after his arrival at CUCF. Plaintiff-appellant Janet Crane was Tucker’s grandmother and the administrator of his estate. She sued on his estate’s behalf: (1) making Eighth Amendment claims against four prison officials (the “CUCF Defendants”); (2) making statutory claims for violations of the Americans with Disabilities Act (“ADA”) and the Rehabilitation Act against UDC; and (3) making a claim under the Unnecessary Rigor Clause of the Utah Constitution against both the CUCF Defendants and UDC. The defendants moved for judgment on the pleadings. The district court granted the motion, holding the CUCF Defendants were entitled to qualified immunity on the federal constitutional claims and the federal statutory claims did not survive Tucker’s death. As a result, the district court declined to exercise supplemental jurisdiction over the state constitutional claim. Finding no reversible error in the district court's dismissal, the Tenth Circuit affirmed. View "Crane v. Utah Department of Corrections, et al." on Justia Law

Defendant-Appellee Southwest Airlines graded its new hires based on two overarching categories of criteria: Attitude and Aptitude. By all accounts, Plaintiff-appellant Krista Edmonds-Radford had the necessary Attitude for her position as a Southwest Customer Service Agent. Unfortunately, she failed to exhibit the necessary Aptitude, and Southwest terminated her for failing to meet expectations. That termination led to this disability-based lawsuit, in which Edmonds-Radford sued Southwest for disparate treatment, failure to accommodate, and retaliation under the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The district court granted summary judgment in favor of Southwest on all claims, and Edmonds-Radford appealed. After review, the Tenth Circuit determined: (1) Edmonds-Radford failed to establish her prima facie case or that Southwest’s proffered reason for her termination was pretextual; (2) Edmonds-Radford failed to present evidence she requested any accommodations in connection with her disability (in any event, Southwest provided all requested accommodations); and (3) because there was no proof she made any disability-based accommodation requests, Edmonds-Radford's retaliation claim based on such requests was doomed. "But even if Edmonds-Radford had made disability-based accommodation requests, her retaliation claim would still fail in light of our conclusions that Edmonds-Radford failed to establish that her disability was a determining factor in her termination, or that Southwest’s legitimate, nondiscriminatory reason for the termination was pretextual. Accordingly, the Court affirmed the district court's grant of summary judgment in favor of Southwest on all claims. View "Edmonds-Radford v. Southwest Airlines" on Justia Law

After Albuquerque Police Officers Demsich and Melvin entered plaintiff-appellant Bradley Soza’s front porch with guns drawn, handcuffed him, and patted him down as part of a burglary investigation, Soza sued the Officers under 42 U.S.C. 1983, alleging the Officers violated his clearly established Fourth Amendment rights when they seized him without probable cause and entered the curtilage of his home without a warrant. The Officers moved for summary judgment, asserting qualified immunity, which the district court granted. Because the law regarding the constitutionality of the Officers’ actions was not clearly established, the Tenth Circuit agreed with the district court that the Officers were entitled to qualified immunity. View "Soza v. Demsich, et al." on Justia Law

This appeal stemmed from Alfred Brown’s lawsuit under the Rehabilitation Act, 29 U.S.C. secs. 701–796l, against his former employer, the Defense Health Agency. In April 2010, the Agency hired Brown as a healthcare fraud specialist (HCFS) assigned to the Program Integrity Office (PIO) in Aurora, Colorado. Shortly after joining the Agency, Brown told his supervisors that he had been diagnosed with posttraumatic stress disorder and other panic and anxiety disorders related to his military service. When Brown’s symptoms worsened in September 2011, he was hospitalized and received in-patient treatment for one week. The Agency approved Brown’s request for leave under the Family and Medical Leave Act (FMLA). The district court granted summary judgment for the Agency, determining that there were no triable issues on Brown’s claims that the Agency failed to accommodate his mental-health disabilities and discriminated against him based on those disabilities. Brown appealed, challenging the district court’s rulings that: (1) his requests for telework, weekend work, and a supervisor reassignment were not reasonable accommodations; and (2) he failed to establish material elements of his various discrimination claims. The Tenth Circuit found no reversible error: (1) granting Brown’s telework and weekend-work requests would have eliminated essential functions of his job, making those requests unreasonable as a matter of law; (2) Brown did not allege the limited circumstances in which the Agency would need to consider reassigning him despite the fact that he performed the essential functions of his position with other accommodations; (3) the Court declined Brown’s invitation to expand those limited circumstances to include reassignments that allow an employee to live a “normal life;” and (4) Brown did not allege a prima facie case of retaliation, disparate treatment, or constructive discharge. Summary judgment for the Agency was affirmed. View "Brown v. Austin, et al." on Justia Law

Dr. Rachel Tudor sued her former employer, Southeastern Oklahoma State University, under Title VII, claiming discrimination on the basis of sex, retaliation, and a hostile work environment after Southeastern denied her tenure, denied her the opportunity to reapply for tenure, and ultimately terminated her from the university. A jury found in favor of Dr. Tudor on her discrimination and retaliation claims and awarded her damages. The district court then applied the Title VII statutory cap to reduce the jury’s award, denied Dr. Tudor reinstatement, and awarded front pay. Both Dr. Tudor and the University appealed: Southeastern challenged certain evidentiary rulings and the jury verdict; Dr. Tudor challenged several of the court’s post-verdict rulings, the district court’s denial of reinstatement, the calculation of front pay, and the application of the statutory damages cap. After review, the Tenth Circuit rejected Southeastern’s challenges. Regarding Dr. Tudor’s appeal however, the Court held that there was error both in denying reinstatement and in calculating front pay, although there was no error in applying the Title VII damages cap. Affirming in part and reversing in part, the Court remanded the case back to the district court for further proceedings. View "Tudor, et al. v. Southeastern OK St. University, et al." on Justia Law

Plaintiff John Hayes prosecuted his employment discrimination case to a favorable verdict and judgment. During trial, two instances of misconduct prompted Defendant SkyWest Airlines, Inc. to request a mistrial. But it was Defendant’s own misconduct. Thus, the district court tried to remedy the misconduct and preserve the integrity of the proceedings, but did not grant Defendant’s request. After the trial, exercising its equitable powers, the district court granted Plaintiff’s request for a front pay award. Following final judgment, Defendant moved for a new trial based, in part, on the district court’s handling of the misconduct incidents and on newly discovered evidence. The district court denied that motion. Defendant appealed, asking the Tenth Circuit Court of Appeals to reverse and remand for a new trial or, at the very least, to vacate (or reduce) the front pay award. Finding the district court did not abuse its discretion or authority in this case, the Tenth Circuit affirmed the front pay award. View "Hayes v. Skywest Airlines" on Justia Law