Justia Labor & Employment Law Opinion Summaries

A group of current and former battalion chiefs employed by the City of Alexandria Fire Department alleged that the City failed to pay them overtime wages as required by the Fair Labor Standards Act (FLSA). The battalion chiefs’ compensation was based on a complex pay structure. Chiefs worked either operational or administrative schedules. Operational chiefs rotated through 24-hour shifts within a nine-day cycle, and administrative chiefs worked a standard 40-hour week. The City paid the chiefs a predetermined amount per pay period, corresponding to either 80 administrative hours or 106 operational hours, regardless of the exact number of hours worked, with additional compensation for hours worked beyond their scheduled shifts.The United States District Court for the Eastern District of Virginia granted summary judgment for the City. The district court found that the chiefs were exempt from the FLSA’s overtime requirements under the “highly compensated employee” exemption. Specifically, the court held that the chiefs were paid on an hourly basis and applied the salary basis test found in 29 C.F.R. § 541.604(b). The court concluded the chiefs received guaranteed pay that satisfied the regulatory requirements and that the pay had a reasonable relationship to their usual earnings.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment but for different reasons. The appellate court held that the district court applied the wrong salary basis test, finding that the appropriate test was under 29 C.F.R. § 541.602(a), which applies to employees paid on a weekly or less frequent salary basis. The court concluded that, despite the complexity of the pay system, the chiefs received a predetermined salary not subject to improper deductions and, therefore, were compensated on a salary basis. As a result, the chiefs were correctly deemed exempt from overtime requirements, and the district court’s decision was affirmed. View "Kelly v. City of Alexandria" on Justia Law

A former lieutenant in a county sheriff’s office was accused of using excessive force during two arrests. After an internal investigation was initiated, he was suspended and scheduled for a public hearing before a merit board, which is required under Indiana law for disciplinary actions. The lieutenant alleged that the sheriff manipulated both the investigation and the merit board to ensure an unfavorable outcome for him. Faced with the possibility of an unfair hearing and negative publicity, the lieutenant negotiated a severance agreement with the sheriff: he would resign and waive his hearing in exchange for withdrawal of the charges and a promise of a neutral reference.Despite the agreement, on the day the resignation became effective, two county prosecutors and the sheriff broadly disclosed the excessive-force allegations to local legal professionals and the lieutenant’s current and prospective employers, including through Brady/Giglio disclosures. The disclosures described the alleged misconduct and claimed issues with the lieutenant’s credibility, leading to his suspension from his part-time job and the loss of other employment opportunities. The lieutenant claimed these actions were part of a premeditated scheme to render him unemployable in law enforcement.In the United States District Court for the Northern District of Indiana, the complaint was dismissed. The district court found that absolute and qualified immunity protected the prosecutors and that the sheriff could not be liable because the lieutenant had voluntarily resigned, waiving his due process rights. On appeal, the United States Court of Appeals for the Seventh Circuit held that the prosecutors were entitled to absolute immunity only for Brady/Giglio disclosures made in pending criminal cases. For disclosures to the bar association and employers, neither absolute nor qualified immunity applied at this stage because the alleged coercion through misrepresentation could constitute a procedural due process violation. The appellate court reversed in part, affirmed in part, and remanded for further proceedings. View "Martin v. Goldsmith" on Justia Law

An employee of a car rental company was involved in a motor vehicle collision while working as a transporter, driving a van on company property. The employee was at a complete stop when another vehicle reversed into the van. She reported that her nose struck the steering wheel during the collision, and subsequently experienced pain and symptoms affecting the right side of her face and nose. Medical records from the days following the accident documented her complaints of facial pain, sinus pain, and nasal congestion, and x-ray imaging taken one week after the incident revealed a nondisplaced right-sided nasal fracture. The employer accepted liability for injuries to her neck, back, and right shoulder, but denied that the nasal injury was caused by the collision.The Director of the Department of Labor and Industrial Relations found the nasal injury to be compensable under Hawaii’s workers’ compensation law. The Labor and Industrial Relations Appeals Board (LIRAB) reviewed the case and, based largely on the opinions of two medical examiners selected by the employer, reversed the Director’s decision regarding the nasal fracture. LIRAB concluded that the employer had presented substantial evidence that the nasal injury was not caused by the collision. The Intermediate Court of Appeals affirmed LIRAB’s decision, agreeing that credible medical testimony supported the employer’s position.The Supreme Court of the State of Hawaii reviewed the case and held that the employer failed to meet its initial burden of producing substantial evidence to rebut the statutory presumption that the employee’s nasal injury was work-related. The Supreme Court found that the biomechanics opinions relied on by LIRAB lacked proper foundation and did not constitute substantial evidence. The Court vacated the Intermediate Court of Appeals’ judgment and the relevant portions of LIRAB’s decision and affirmed the Director’s finding that the nasal injury was compensable, remanding for further proceedings consistent with its opinion. View "Lane v. Avis Budget Group, Inc." on Justia Law

A member of the United States Army National Guard, Stacy Gonzales, worked as a local disease intervention specialist at the Finney County Health Department in Kansas. Her position was funded primarily through Aid-to-Local grants distributed by the Kansas Department of Health and Environment (KDHE), which set substantive job expectations and supervised both state and local disease intervention specialists. Gonzales’s salary and benefits were determined and paid by Finney County, but her day-to-day work, training, and performance evaluations involved significant oversight from KDHE. When KDHE decided not to renew the Aid-to-Local grant in 2010 due to perceived performance deficiencies, Finney County was forced to terminate Gonzales’s position, resulting in her unemployment.The United States filed suit in the United States District Court for the District of Kansas, alleging that KDHE had violated the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) by discriminating against Gonzales based on her military service obligations. Both sides moved for summary judgment on the threshold issue of whether Kansas, through KDHE, was Gonzales’s “employer” under USERRA. The district court granted summary judgment to Kansas, concluding that KDHE was not Gonzales’s employer because it did not have direct authority to hire, fire, supervise, or determine her salary or benefits.The United States Court of Appeals for the Tenth Circuit reviewed the district court’s decision de novo. The appellate court held that the definition of “employer” under USERRA includes entities that exercise control over employment opportunities, not limited to direct authority over hiring, firing, or pay. The court found sufficient evidence that KDHE retained significant control over Gonzales’s employment opportunities to preclude summary judgment. The Tenth Circuit reversed the district court’s order and remanded the case for further proceedings. View "United States v. Department of Health & Environment" on Justia Law

Five former employees of a construction company alleged that their employer failed to pay commissions they had earned after leaving the company. Four of the plaintiffs were paid solely by commission, while one received commissions and other compensation. The employer initially lacked a written commission policy but later required employees to sign agreements stating that commissions would be paid only up to 14 days after their departure, with no further commissions paid thereafter. The plaintiffs claimed they were owed significant sums in unpaid commissions after leaving, and three argued that the agreement violated statutory prohibitions against forfeiting wages for time worked as a condition of employment.The employer responded to the complaint by filing a demurrer in the Circuit Court, arguing that Virginia’s wage theft statute, Code § 40.1-29, did not apply to commissions. The Circuit Court agreed, holding that commissions were not covered by the statute. The plaintiffs appealed, and the Court of Appeals of Virginia reversed the lower court’s decision, concluding that the term “wages” in Code § 40.1-29 encompassed commissions. The Court of Appeals relied on the statute’s remedial purpose, previous decisions interpreting “wages” broadly, and an administrative agency’s interpretation.The Supreme Court of Virginia reviewed the case and held that Code § 40.1-29 does not cover commissions, either expressly or by implication. The Court determined that the statute’s language and context indicate the General Assembly did not intend for commissions to be included, noting that the legislature has elsewhere specifically distinguished wages, salaries, and commissions. The Supreme Court reversed the judgment of the Court of Appeals of Virginia and entered final judgment for the employer. View "Groundworks Operations, LLC v. Campbell" on Justia Law

Amazon was accused of unfair labor practices under the National Labor Relations Act for refusing to recognize and bargain with the Teamsters Amazon National Negotiating Committee, which represented a group of former Amazon delivery drivers. After Amazon terminated its contract with a delivery service whose drivers were represented by the union, the Teamsters alleged that Amazon and the contractor were joint employers and demanded bargaining rights. Amazon declined, prompting the Teamsters to file unfair labor practice charges with the National Labor Relations Board (NLRB). The NLRB’s General Counsel filed a complaint against Amazon, alleging threats, retaliation, and refusal to bargain.Following the initiation of the NLRB administrative proceedings, Amazon sued in the United States District Court for the Central District of California, seeking to enjoin the Board from continuing those proceedings. Amazon argued that the Board’s structure and adjudicative procedures were unconstitutional and requested a preliminary injunction. The Teamsters intervened in the case to represent the interests of the drivers. The district court denied Amazon’s motion, holding that it lacked jurisdiction under the Norris-LaGuardia Act, which prohibits federal courts from issuing injunctions in cases involving or growing out of labor disputes.On appeal, the United States Court of Appeals for the Ninth Circuit addressed whether Amazon’s constitutional challenge “involved or grew out of” a labor dispute, as defined by the Norris-LaGuardia Act. The Ninth Circuit held that both the parties and the underlying dispute satisfied the requirements of the Act, as Amazon’s claims were directly connected to a labor dispute between an employer and a union. The court affirmed the district court’s denial of the preliminary injunction, concluding that federal courts lack jurisdiction to issue such relief in this context. View "AMAZON.COM SERVICES, LLC V. NATIONAL LABOR RELATIONS BOARD" on Justia Law

A former employee worked for a retail company and, during his employment, signed an arbitration agreement that included a waiver of class, collective, and Private Attorneys General Act (PAGA) representative actions. This agreement stated that any dispute must be brought in arbitration on an individual basis and not as a representative action. The agreement also included a severability clause, specifying that if any part of the waiver was found invalid, a private attorney general claim would have to be litigated in court.After his employment ended, the employee filed a lawsuit against the company under PAGA, alleging wage-and-hour violations on behalf of himself, other employees, and the State of California. The claims and requested relief were pleaded in the aggregate, and the complaint did not separately seek penalties for violations suffered by the plaintiff alone.The employer moved to compel arbitration, arguing that the Supreme Court’s decision in Viking River Cruises, Inc. v. Moriana allowed for arbitration of the “individual” component of a PAGA claim even if representative claims could not be arbitrated. The Alameda County Superior Court denied the motion, reasoning that there is no such thing as an “individual PAGA claim” under California law.On appeal, the Court of Appeal of the State of California, First Appellate District, Division Four, affirmed the trial court’s decision. The appellate court held that, based on the language of the arbitration agreement, the parties did not agree to arbitrate individual PAGA claims. The court reasoned that as of the time the agreement was drafted, there was no clear distinction in California law between “individual” and “non-individual” PAGA claims. Therefore, the court declined to compel arbitration of the PAGA claim and affirmed the lower court’s order. Costs on appeal were awarded to the employee. View "LaCour v. Marshalls of California" on Justia Law

A former employee brought a single-count action under the Private Attorneys General Act of 2004 (PAGA) against his previous employer, alleging violations of various wage-and-hour provisions of the California Labor Code. The employee had previously signed an arbitration agreement that included waivers of class action, collective action, and representative PAGA claims, with a severability clause stating that any invalidation of the PAGA waiver would require such claims to be litigated in court, not arbitrated. The complaint sought civil penalties on behalf of the employee, other current and former employees, and the State of California, but did not separately seek penalties for violations suffered by the employee personally.The employer moved to compel arbitration, arguing that recent federal and state precedent required arbitration of the "individual component" of the PAGA claim, relying on Viking River Cruises, Inc. v. Moriana and subsequent California cases. The Superior Court of Alameda County denied the motion, reasoning that under California law there was no such thing as an "individual PAGA claim" and, therefore, the claim could not be compelled to arbitration.Reviewing the denial, the Court of Appeal of the State of California, First Appellate District, Division Four, considered the parties’ arguments regarding the interpretation of the arbitration agreement and relevant case law. The court held that, based on the language of the agreement and the intent of the parties at the time it was signed, there was no clear agreement to arbitrate individual PAGA claims if the PAGA waiver was invalidated. The court reasoned that, although recent decisions allow splitting PAGA actions into individual and non-individual claims, the agreement in this case did not provide for such arbitration. Accordingly, the court affirmed the order denying the motion to compel arbitration. View "LaCour v. Marshalls of California" on Justia Law

The plaintiff performed maintenance and handyman work for a property owned by a corporation, with the arrangement that he would receive free rent in exchange for keeping the water system operational and doing various tasks. He worked for the corporation between 2009 and 2016, receiving instructions and approvals from the company’s officer who managed the property. After the arrangement ended, it was undisputed that the plaintiff had not been paid wages apart from free rent. He filed a wage claim with the Division of Labor Standards Enforcement, seeking unpaid wages, liquidated damages, waiting time penalties, and other remedies.After a favorable administrative decision by the Labor Commissioner, finding the plaintiff to be an employee entitled to recover unpaid wages and imposing personal liability on the company officer, the defendants appealed to the Superior Court of Humboldt County. Following a bench trial, the court awarded the plaintiff some unpaid wages and penalties, but calculated the statute of limitations from a later date, declined to impose personal liability on the officer, denied liquidated damages and administrative penalties, and rejected claims under the Unfair Competition Law.The California Court of Appeal, First Appellate District, Division One, reviewing the case after remand from the California Supreme Court, held that the trial court erred in several respects. The appellate court found the statute of limitations should have been calculated from the date the initial wage claim form was filed, not a later complaint. It held that the officer could be held personally liable under Labor Code section 558.1, and that the trial court lacked discretion to deny individual liability when the statutory criteria were met. The court also concluded liquidated damages under section 1194.2 and administrative penalties under section 248.5 should have been awarded, and waiting time penalties should have incorporated the rental value provided as compensation. The judgment was reversed in these respects and remanded for recalculation, while affirmed in other areas. View "Iloff v. LaPaille" on Justia Law

Stericycle, Inc. reorganized its sales department in 2021, creating a new position called Key Account Director (KAD) in both its national and hospital divisions. Cheryl Lane and Adrienne Hause, both female employees, were promoted to the National KAD role. Prior to being promoted, Lane and Hause were National Account Managers with base salaries of $92,784 and $95,026. After expressing concerns about salary disparities between themselves and male Hospital KADs, they received raises increasing their salaries to $98,000. The male Hospital KADs, some promoted and some transferred, generally received higher salaries, with promoted males receiving immediate raises and transferred males retaining their previous, often higher, salaries.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment to Stericycle, finding that Lane and Hause had established a prima facie case under the Equal Pay Act but that Stericycle’s pay practices were justified by a sex-neutral factor: prior salary history. The court found Stericycle had satisfied its affirmative defense for all comparators, concluding that salary disparities were not based on sex. The court also granted summary judgment on the Title VII claim, holding that Lane and Hause had failed to show intentional discrimination.On appeal, the United States Court of Appeals for the Seventh Circuit found genuine disputes of material fact regarding whether Lane and Hause received raises at the time of promotion, as their male counterparts did. The court held that summary judgment was improper in relation to the two promoted male Hospital KADs, as Stericycle failed to prove its affirmative defense as a matter of law, and there was a material factual dispute as to pretext under Title VII. The Seventh Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Lane v Stericycle, Inc." on Justia Law