Justia Civil Rights Opinion Summaries

The case concerns Sandra Selden, an employee at the Des Moines Area Community College (DMACC), who alleged that she was a victim of illegal wage discrimination based on sex and wrongful retaliation. Selden discovered that a male colleague was receiving a higher salary for the same job. When her employer did not act on her complaint, attributing the pay gap to the male employee's greater seniority and initial higher salary because of his relevant experience, Selden filed a civil rights complaint. She also applied for a supervisory position, but her application was screened out due to her lack of required educational qualifications. The case went to trial and the jury awarded damages to Selden on both claims. DMACC appealed the decision.The Supreme Court of Iowa reversed the lower court's decision, holding that the record did not contain substantial evidence of an illegal pay practice. The court found that the pay gap was due to gender-neutral factors, specifically a neutral seniority system, and the decision to hire the male employee at a higher rate due to market conditions and his significant experience. The court also found that the retaliation claim was not supported by substantial evidence, as the employer consistently screened out all applicants who lacked the required qualifications. The court concluded that the lower court should have directed a verdict in favor of the defendants and remanded the case for that purpose. View "Selden v. Des Moines Area Community College" on Justia Law

In the case between Jennifer Harris and FedEx Corporate Services, Inc., Harris alleged race discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964. The United States Court of Appeals for the Fifth Circuit found that Harris's § 1981 claims were time-barred under her employment contract, making them fail as a matter of law. However, the court found sufficient evidence to support the jury’s verdict for Harris on her Title VII retaliation claim. In view of Title VII’s $300,000 cap on damages and the evidence presented at trial, the court remitted Harris’s compensatory damages to $248,619.57 and concluded she was not entitled to punitive damages. FedEx was not entitled to a new trial because of the court’s evidentiary ruling. View "Harris v. FedEx Corporate Services" on Justia Law

Clare Mundell worked as a licensed clinical psychologist for Acadia Hospital in Maine. She discovered that her male colleagues were paid significantly more than her for comparable work. Mundell brought a sex discrimination action against Acadia under federal and state law, specifically the Maine Equal Pay Law ("MEPL"). The district court found Acadia liable under the MEPL and awarded Mundell treble damages. On appeal, Acadia argued that the district court erred in holding that Mundell could prevail without establishing Acadia's discriminatory intent and because Acadia claimed a reasonable-factor-other-than-sex defense to explain the pay difference. The United States Court of Appeals for the First Circuit affirmed the district court's decision. The court held that the MEPL does not impose an intent requirement on a plaintiff, nor does it permit a defendant to rely on a catch-all affirmative defense such as market factors to explain pay disparity. The court also concluded that treble damages are available for MEPL violations. View "Mundell v. Acadia Hospital Corp." on Justia Law

In March 2019, the Waxahachie Police Department (WPD) SWAT Team mistakenly executed a search warrant on the wrong house, which was the home of Karen Jimerson, James Parks, and their two young children, instead of the intended target house. The error was due to Mike Lewis, the WPD SWAT Team Commander, incorrectly identifying the target house. The plaintiffs sued the officers under Section 1983 for violations of the Fourth Amendment and several state laws. The United States Court of Appeals for the Fifth Circuit reversed the district court's denial of summary judgment to Lewis on the issue of qualified immunity. The appellate court held that while Lewis's efforts to identify the correct residence were deficient, they did not violate clearly established law. The court found no genuine disputes of material fact, and it concluded that the disputed issue was one of law. The case was remanded for dismissal. View "Jimerson v. Lewis" on Justia Law

A group of current and former inmates, or their representatives, filed a class action lawsuit against Kate Brown, the Governor of Oregon, and Patrick Allen, the Director of the Oregon Health Authority, claiming that the state's COVID-19 vaccine rollout plan, which prioritized corrections officers over inmates, violated their Eighth Amendment rights. The defendants moved to dismiss the claim, asserting immunity under the Public Readiness and Emergency Preparedness (PREP) Act. The district court denied the motion, and the defendants appealed.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision, finding that the defendants were immune from liability for the vaccine prioritization claim under the PREP Act. The court held that the statutory requirements for PREP Act immunity were met because the "administration" of a covered countermeasure includes prioritization of that countermeasure when its supply is limited. The court further concluded that the PREP Act's provisions extend immunity to persons who make policy-level decisions regarding the administration or use of covered countermeasures. The court also held that the PREP Act provides immunity from suit and liability for constitutional claims brought under 42 U.S.C. § 1983, even if those claims are federal constitutional claims. View "MANEY V. BROWN" on Justia Law

The Supreme Court of Missouri reversed a lower court's dismissal of a lawsuit brought by workers against Harley-Davidson Motor Company Operations, Inc., and Syncreon.US. The workers, who are Black or People of Color, alleged that the companies created a hostile work environment and aided and abetted racial discrimination in violation of the Missouri Human Rights Act. The workers detailed numerous racially charged incidents at a manufacturing and assembly facility operated by Harley-Davidson and staffed by workers provided by Syncreon.US. The incidents included frequent racial insults, physical division of workers based on race, and multiple instances of hate symbols and threats found in the facility. The court found that the workers' allegations, if true, could establish the elements of a hostile work environment claim and aiding and abetting claims. The case was remanded back to the lower court for further proceedings. View "Matthews vs. Harley Davidson" on Justia Law

An inmate in Texas, Raul Gerardo Favela, Jr., alleged that prison officials had ignored warnings and failed to prevent him from being assaulted by another inmate. Favela sued several employees of the Texas Department of Criminal Justice (TDCJ) under 42 U.S.C. § 1983, claiming that their failure to protect him violated his constitutional rights. However, the district court granted summary judgment in favor of the defendants, stating that Favela had failed to exhaust his administrative remedies as required by the Prison Litigation Reform Act (PLRA). The United States Court of Appeals for the Fifth Circuit reversed the decision of the district court, finding that the summary judgment was inappropriate. Favela's declaration that he had filed and timely submitted grievances relating to his claims was found to be sufficient to establish a genuine issue of material fact, thereby meeting his burden to counter the defendant's prima facie case. The court concluded that the matter of the credibility of Favela's statement was a matter for trial, and not for summary judgment. The case was remanded for further proceedings. View "Favela v. Collier" on Justia Law

The case involves an appeal by a plaintiff against the dismissal of his lawsuit against the City of Buffalo and some of its police officers. The plaintiff was arrested and charged with violating a city noise ordinance after he shouted at a police officer, who was driving without headlights, to turn his lights on. The plaintiff filed a lawsuit, asserting that his arrest violated his First Amendment right to free speech and amounted to false arrest and malicious prosecution.The United States Court of Appeals for the Second Circuit found that the district court erred in ruling that the plaintiff's shout was not protected by the First Amendment, given that it was a warning about a public safety issue. The court further concluded that there were genuine issues of fact concerning whether there was probable cause to arrest the plaintiff, which should have been resolved by a jury rather than at summary judgment.The court vacated the part of the district court's judgment dismissing the plaintiff's claims of false arrest, malicious prosecution, and First Amendment retaliation, as well as his claims related to failure to intervene and respondeat superior. The court affirmed the part of the district court's dismissal of the plaintiff's claim that the noise ordinance was unconstitutional as applied to him. The case was remanded for trial on the reinstated claims. View "Rupp v. City of Buffalo" on Justia Law

This case is about a dispute between Richard Roe and St. John’s University (SJU) and Jane Doe. Roe, a male student at SJU, was accused of sexually assaulting two female students, Doe and Mary Smith, on separate occasions. SJU's disciplinary board found Roe guilty of non-consensual sexual contact with both Doe and Smith and imposed sanctions, including a suspension and eventual expulsion. Roe then sued SJU, alleging that his rights under Title IX of the Education Amendments of 1972 and state contract law had been violated. He also sued Doe for allegedly defaming him in an anonymous tweet accusing him of sexual assault. The United States District Court for the Eastern District of New York dismissed Roe's Title IX and state law claims, and declined to exercise jurisdiction over his defamation claim. On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision, holding that Roe's complaint failed to state a plausible claim of sex discrimination under Title IX. The court found that, while Roe had identified some procedural irregularities in SJU's disciplinary proceedings, these were not sufficient to support a minimal plausible inference of sex discrimination. Furthermore, the court ruled that Roe's hostile environment claim was fatally deficient, as the single anonymous tweet at the center of his claim was not, standing alone, sufficiently severe to support a claim of a hostile educational environment under Title IX. View "Roe v. St. John's University" on Justia Law

In the state of Montana, William James Rupnow Jr., a licensed bail bondsman, was accused of criminal offenses after he tried to apprehend a client, Victorianne Dahl, who had violated her bail conditions. Dahl had consistently been late with payments and had violated other conditions of her release. Rupnow resorted to using pepper spray in his attempt to detain Dahl, leading to the State charging him with felony assault with a weapon and aggravated assault. Rupnow was ultimately acquitted on the aggravated assault charge, but the jury could not reach a verdict on the assault with a weapon charge. In response, Rupnow filed a lawsuit against the Montana State Auditor and Commissioner of Insurance, Mike Winsor, Jennifer Hudson, and XYZ government subdivision, alleging malicious prosecution, abuse of process, and violation of his rights under the Montana Constitution. The defendants requested the case be dismissed based on prosecutorial immunity, a motion which the District Court granted. Rupnow appealed the decision, arguing that as a bail bondsman, he had the authority to arrest Dahl without a warrant.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision to dismiss Rupnow's case. The Court found that Montana's statutory scheme for pre-trial release, or bail, did not provide bail bondsmen with an unfettered right to remit a bail bond client to jail without an outstanding warrant. The Court reasoned that the legislature did not intend to grant bail bondsmen arrest authority that far exceeded that of law enforcement officers. Therefore, Rupnow did not have the authority to arrest Dahl without a warrant, meaning there was probable cause to charge Rupnow with the crimes he was accused of. The Court concluded that Rupnow's claims of malicious prosecution and abuse of process failed as a matter of law. View "Rupnow v. State Auditor" on Justia Law