[Download] "Washington v. County of Rockland" by 2003 United States Court of Appeals for the Second Circuit August Term " eBook PDF Kindle ePub Free
eBook details
- Title: Washington v. County of Rockland
- Author : 2003 United States Court of Appeals for the Second Circuit August Term
- Release Date : January 25, 2004
- Genre: Law,Books,Professional & Technical,
- Pages : * pages
- Size : 70 KB
Description
Plaintiffs-appellants Evan Washington, Howard Pierson IV and Secunda Crump (collectively, "plaintiffs"), African-American correction officers employed by the Rockland County Sheriffs Department ("RCSD" or "the Department") brought suit, pursuant to 42 U.S.C. §Â§ 1981 and 1983, against the County of Rockland ("the County") and Rockland County Sheriff James F. Kralik, in his individual capacity (collectively, "defendants"). Plaintiffs claimed that defendants engaged in malicious prosecution by bringing meritless disciplinary charges against plaintiffs because of plaintiffs race and in retaliation for plaintiffs decision to speak out against defendants allegedly discriminatory policies and practices. Plaintiffs further allege that defendants selectively maintained meritless disciplinary proceedings against them because of their race and prior opposition to defendants allegedly discriminatory practices. The district court (Conner, J.) granted summary judgment in favor of defendants on all of plaintiffs claims. On appeal, we hold that: (1) plaintiffs malicious prosecution claims fail because a § 1983 malicious prosecution claim may not be premised on a civil administrative proceeding of the type at issue here; (2) plaintiffs discrimination claims accrued at the time the disciplinary charges were filed, and thus, plaintiffs filing of the claims more than three years after they accrued rendered them untimely; and (3) although plaintiffs suffered an adverse employment action, their retaliation claim fails nonetheless because they did not demonstrate a causal connection between the adverse employment action and the protected speech.
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