In Gera v. County of Schuylkill, the U. S. District Court of Pennsylvania rejected a pro se former corrections officer’s ADA disability and retaliation claims, granting summary judgment to Schuylkill County because the officer failed to show that he was a qualified individual within the meaning of the ADA, failed to show retaliation, and his disability benefits claim precluded his ADA claim.
In Carothers v. County of Cook, the Seventh Circuit found that a black employee at a juvenile detention center could not move forward with her Title VII race discrimination claim, despite evidence that her supervisor had told a group of employees he would “take them to the woodshed” and made a problematic comment about Malcom X. In her complaint, the employee alleged not only race discrimination, but also disability discrimination, gender discrimination, and retaliation. The Court found that because the statements were not made by the ultimate decision maker, the woodshed statement did not hold racial connotations, and the Malcom X comment was made three years prior, the County’s motion for summary judgment was appropriate.
In Bonenberger v. St. Louis Metro. Police Dept., a white police officer applied for and was denied the position of Assistant Academy Director of the St. Louis, Missouri Police Academy, an African American woman was chosen instead. The police officer sued department officials alleging race discrimination and conspiracy to discriminate. A jury found in the officer’s favor on claims against three of his superiors regarding both claims. The department appealed the district court’s denial of their motion for a judgment as a matter of law.
In Jennings v. Wayne County, a Michigan police officer was able to establish a claim for retaliation after she complained about sexual harassment. The district court found that being frozen out of meetings, not receiving backup, and being stripped of her Blackberry could constitute an adverse action. The district court also found the officer had established a First Amendment claim because her complaints about the harassment involved a matter of public concern.
In Reeder v. County of Wayne, the U.S. District Court for the Eastern District of Michigan held that a Wayne County police officer diagnosed with depression and anxiety could proceed with a claim against the county alleging that it wrongfully discharged him—in violation of the Americans with Disabilities Act—for refusing to work mandatory overtime.
In Craft v. Fairfax County Government, the U.S. District Court for the Eastern District of Virginia held that a Fairfax County firefighter could not bring a disability discrimination claim of either wrongful termination or failure to accommodate because he was unable to show he was a “qualified individual” under the Americans with Disabilities Act.
In McWilliams v. Cmty. Educ. Ctrs., Inc., an African American correctional officer was terminated for violating a fraternization policy after he helped an inmate deposit money into his prison account. The officer alleged the termination was racially discriminatory and that the prison had allowed a hostile work environment. The U.S. District Court in Pennsylvania found that the officer had established a disparate treatment claim by alleging his punishment was not comparable to white officers who had broken the same rule and the office had established a hostile work environment claim by alleging black officers were subjected to pictures of nooses.
In McMillion v. Mollenhauer, a former jailer brought a claim against an Indiana Sheriff’s Office alleging race discrimination because she was demoted from corporal, was not paid for her FMLA leave and was wrongfully terminated. The district court granted the Sheriff’s Office summary judgment because the jailer never returned to work after her FMLA leave expiredThe court also rejected the demotion claim because no pay was attached to that position and all other officers had had the title of corporal removed.
In Federal Bureau of Prisons, an arbitrator ruled that a corrections officer could not sustain his claim that the Federal Bureau of Prisons discriminated against him for being Hispanic. This finding was largely because none of his co-workers corroborated his story and thus there was no evidence to substantiate his claim.
In Williams v. Alabama Dep’t. of Corrections, the U.S.Court of Appeals for the 11th Circuit determined that a Corrections Officer’s resignation could not be considered an adverse employment action on the part of his employer if he was provided with reasonable alternatives to resignation. The Court found the employer’s offer to hold a formal hearing at which the Officer could tell his side of the story to be a sufficient alternative to immediate resignation.
