Eighth Circuit -- Tabby Butler v. Crittenden County, Arkansas

Tabby Butler v. Crittenden County, Arkansas U.S. Court of Appeals Case No: 12-1993 U.S. District Court for the Eastern District of Arkansas - Jonesboro [PUBLISHED] [Murphy, Author, with Loken and Colloton, Circuit Judges]
Civil case - civil rights. Since plaintiff's race and gender discrimination claims under Section 1983 are based on alleged constitutional violations, she was not required to comply with Title VII's procedural requirements, such as filing her action within 90 days of receiving a right to sue letter, in order to maintain them; while plaintiff suffered tangible job detriments in the form of a suspension and termination, she failed to show that her rejection of her supervisor's advances caused the detriments; plaintiff's allegations of different treatment were insufficient to establish a prima facie case of discrimination on the basis of her sex and race; retaliation claim under Section 1981 rejected; First Amendment claim under Section 1983 rejected as the comments in question were made as part of her official duties and were not immunized under the First Amendment.