Brazil v. Arkansas Department of Human Services, No. 17-2229 (8th Cir. 2018)
Annotate this CaseBrazil spent over three decades working for the Arkansas Department of Human Services. A 2010 disagreement with her supervisor eventually led her to seek a transfer to another division. When she did not receive a transfer, she sued the Department and several officials for alleged civil rights violations. None of her claims survived summary judgment. Brazil’s work environment did not improve. Brazil believes that she received lower performance evaluations in retaliation for the lawsuit. Brazil’s supervisors reassigned her from performing traditional administrative-assistant tasks to working in a document-scanning room, which required heavy lifting, long periods of sitting, and repetitious activities. Though her official title remained the same, Brazil regarded the assignment as a demotion because it required manual labor and diminished her opportunities for promotion. Brazil filed suit alleging retaliation and racial discrimination. A year into the litigation, Brazil changed positions. In her current job, Brazil reports to different supervisors and performs only administrative-assistant duties. The district court dismissed all of Brazil’s claims, except those against her former supervisors, which it rejected on summary judgment. The Eighth Circuit concluded that her claims were moot, vacated, and instructed the district court to dismiss the claims.
Court Description: Stras, Author, with Colloton and Shepherd, Circuit Judges] Civil case - Employment discrimination. In action alleging defendant had retaliated against plaintiff for filing a civil-rights suit, the issue remaining for appeal was whether plaintiff was entitled to injunctive relief requiring defendant to transfer her to a suitable position under the direction of different supervisors; however, plaintiff has already received such a transfer and, as a result, there is no longer a live case or controversy under Article III; remanded with directions to dismiss plaintiff's retaliation claim for lack of subject-matter jurisdiction.
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