B.S. Ex Rel. Schneider v. Board of School Trustees, Fort Wayne Community Schools

1. Under the Minnesota Human Rights Act's (MHRA) protection of transgender individuals against discrimination based on sexual orientation, Minn. Stat. § 363A.03, subd. 44 (2018), a policy that expressly prohibits transgender women from competing in the women's division of a powerlifting competition is facially discriminatory and constitutes direct evidence of discrimination based on sexual orientation under the MHRA's prohibition against business discrimination and discrimination by places of public accommodation, found at Minn. Stat. §§ 363A.11, 363A.17 (2018). 2. There is a genuine dispute of material fact as to whether seeking to ensure competitive fairness in an athletic competition satisfies the legitimate business purpose defense for sexual orientation and sex discrimination in business under Minn. Stat. § 363A.17 (2018) of the MHRA that forecloses partial summary judgment for the plaintiff as to liability on this claim. 3. In the absence of any alleged statutory exemption or defense, the district court properly granted partial summary judgment for the plaintiff on the claim of sexual orientation discrimination in public accommodations. 4. Our holding in Goins v. West Group, 635 N.W.2d 717 (Minn. 2001), is limited to claims of sexual orientation discrimination under the MHRA related to employment. Affirmed in part, reversed in part, and remanded.

This appeal concerns a police officer's termination. Kodi Gail Knight ("Knight") was a police officer for the City of Fairview, Tennessee ("Fairview"). After an August 2019 incident in which Knight struck a handcuffed woman ("the Arrestee") in the face, Fairview police chief Zack Humphreys ("Chief Humphreys") submitted a request to City Manager Scott Collins ("the City Manager") that Knight be terminated. The City Manager sent Knight a termination letter. Knight requested, and was granted, a pre-dismissal hearing before the City Manager. Following this hearing, the City Manager affirmed the decision to terminate Knight. Knight filed a petition for writ of certiorari in the Chancery Court for Williamson County ("the Trial Court"). The Trial Court affirmed Fairview's termination of Knight. Knight appeals, arguing among other things that his procedural due process rights were violated because the City Manager both drafted his termination letter and presided over his pre-dismissal hearing. We find that Knight was an at-will employee who lacked a property interest entitling him to procedural due process protection. We also find that the City Manager's decision was supported by substantial and material evidence and was neither arbitrary nor capricious. We affirm the judgment of the Trial Court.

The respondent mother appealed from the judgments of the trial court terminating her parental rights with respect to her three minor children. She claimed that the trial court deprived her of her substantive due process rights under the United States constitution because termination of her parental rights was not the least restrictive means necessary to ensure the state's compelling interest in protecting the best interests of the children, and that the record disclosed that narrower means were available to protect the children from harm and afford them statutory permanency. Held that this court declined to review the respondent's unpreserved constitutional claim because the inadequate record failed to satisfy the requirement of the first prong of State v. Golding (213 Conn. 233); the evidence at trial supported the decision of the petitioner, the Commissioner of Children and Families, to pursue termination of the respondent's parental rights, the respondent did not propose any alternative permanency plans, and, after the trial court granted the termination petitions, the respondent did not attempt to raise her claim by filing a motion to reargue or reconsider, nor did she ask the court to articulate whether it had considered other options, and the respondent's failure to pursue any of these avenues left the record devoid of evidence and findings necessary to review her constitutional claim. Argued September 9—officially released October 29, 2020

improper notice of right to appeal disciplinary action; career status employee; N.C. Gen. Stat. § 1235