Justia Labor & Employment Law Opinion Summaries

Three employees at different Illinois schools declined to receive the COVID-19 vaccine, citing religious beliefs, after the Illinois Governor issued an Executive Order requiring school employees to either vaccinate or undergo weekly testing. The schools, in compliance with the Executive Order and state agency guidance, offered weekly testing as an accommodation for those claiming a religious exemption to vaccination. The employees refused the testing, asserting that submitting to it violated their moral consciences, and were either placed on unpaid leave or terminated.The employees filed suit in the United States District Court for the Central District of Illinois, alleging violations of Title VII of the Civil Rights Act, the Emergency Use Authorization Act, and the Illinois Health Care Right of Conscience Act. Each employer moved to dismiss the complaint. The district court dismissed the Title VII claim, finding that the plaintiffs failed to identify a religious belief that was violated by the testing requirement. The court also dismissed the Emergency Use Authorization Act claim, holding there was no private right of action, and declined supplemental jurisdiction over the state law claim. The employees appealed only the dismissal of their Title VII claim and, for the first time on appeal, raised a claim under the Illinois Public Health Code.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s dismissal. The court held that the plaintiffs failed to state a claim under Title VII because they did not allege a religious objection to testing; their objections were based on personal moral conscience, not religious belief. The court further held that Title VII does not require an employer to accommodate religious beliefs when doing so would cause the employer to violate the law. The court also found that any argument under the Illinois Public Health Code was waived. View "Bowlin v. Board of Directors, Judah Christian School" on Justia Law

At a psychiatric hospital, employees were exposed to violent behavior from disturbed patients. Following a tip, the Occupational Safety and Health Administration (OSHA) investigated and cited the hospital for failing to implement measures that could have protected staff from workplace violence. These measures included reconfiguring nurses’ stations, providing communication devices, fully implementing existing safety programs, maintaining adequate staffing, securing patient belongings, hiring specialized security staff, and investigating each incident of workplace violence. The hospital did not contest the necessity of some measures but challenged the citation overall.An administrative law judge with the Occupational Safety and Health Review Commission conducted a hearing, upheld the citation, and imposed a fine. The judge’s decision became the final decision of the Review Commission when it declined further review. The hospital then petitioned the United States Court of Appeals for the Tenth Circuit for judicial review, arguing that another federal agency, the Centers for Medicare and Medicaid Services, had exclusive authority over hospital safety, that the Secretary of Labor should have deferred to other regulatory bodies, and that the Secretary’s methods and notice were insufficient.The United States Court of Appeals for the Tenth Circuit held that the Secretary of Labor had the authority to enforce the Occupational Safety and Health Act’s general duty clause in this context, as the cited agency did not actually regulate employee safety regarding workplace violence. The court found that the Secretary provided fair notice, acted within statutory authority, and permissibly used adjudication rather than rulemaking. The court also concluded that the abatement measures were feasible, supported by substantial evidence, and that the imposed sanctions for failure to preserve video evidence were appropriate. The Tenth Circuit denied the hospital’s petition for review, upholding the citation and penalty. View "Cedar Springs Hospital v. Occupational Health and Safety" on Justia Law

A management company and the owner of a psychiatric hospital were both penalized after the hospital failed to implement sufficient safety measures to protect employees from workplace violence. The central issue was whether the management company could be held liable under workplace safety laws, specifically whether its relationship with the hospital owner meant it was subject to the same penalties for safety violations.Previously, the Occupational Safety and Health Review Commission evaluated whether the management company was an “employer” for relevant employees by applying a three-part factual test. This test asked whether there was a shared worksite, whether the companies’ operations (particularly regarding safety and health) were integrated, and whether the companies shared responsibility through common management, supervision, or ownership. The Commission answered all three questions affirmatively, finding the management company liable as an employer for some hospital employees.The United States Court of Appeals for the Tenth Circuit reviewed the case, examining whether substantial evidence supported the Commission’s findings. The court found that the hospital was a worksite for the management company because its employees worked there and were exposed to workplace hazards. The companies’ operations were sufficiently integrated on safety matters, evidenced by the management company’s oversight and involvement in safety training and policy enforcement. Finally, both companies were wholly owned subsidiaries of the same parent corporation, satisfying the requirement for shared ownership.The Tenth Circuit concluded that substantial evidence supported the Commission’s findings and denied the management company’s petition for review. The court’s holding was that, under the agreed-upon three-part test, the management company was properly held liable as an employer for workplace safety violations at the hospital and was subject to the associated penalties. View "UHS of Delaware v. Occupational Health and Safety Review Commission" on Justia Law

An employee of Indiana University, who began as an intern and was promoted to an online instructional designer, was terminated after sending a series of emails to senior university officials. These emails escalated an internal funding issue that had already been resolved by her supervisor and included accusations of mismanagement against her supervisors. Her conduct was considered insubordinate and a breach of professional protocol. The employee, who had taken multiple periods of leave under the Family and Medical Leave Act (FMLA) and requested accommodations for mental-health conditions, alleged that her termination was in retaliation for exercising her statutory rights.The United States District Court for the Southern District of Indiana granted summary judgment to the university and individual defendants on all claims, concluding that the evidence was insufficient for a reasonable jury to find in the employee’s favor. The plaintiff appealed but pressed only her retaliation claims under the Rehabilitation Act and the FMLA, arguing that the district court applied the wrong causation standard and that the evidence should allow her claims to proceed to trial.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and determined that, although the district court applied an incorrect “sole” causation standard rather than the proper “but-for” standard for retaliation claims, the outcome remained the same under the correct law. The appellate court held that no reasonable jury could find that the plaintiff’s protected activity caused her termination. The court found that the termination was based on unprofessional conduct, not on her FMLA leave or requests for accommodation. Accordingly, the Seventh Circuit affirmed the district court’s grant of summary judgment to the defendants. View "Shirk v. Trustees of Indiana University" on Justia Law

An employee at a construction company alleged that he faced repeated harassment at work after revealing that he was bisexual. According to his account, coworkers and a supervisor directed homophobic slurs and derogatory comments at him over several months. The employee reported the harassment to a manager on two occasions, initially without naming the harassers, and later with more details. Eventually, after a particularly hostile exchange, he formally complained to the company’s human resources department, which initiated an investigation. The HR manager interviewed the employee and nine other workers, none of whom corroborated his claims. Nonetheless, the company issued a written warning to the supervisor for inappropriate language, required all employees to review the antidiscrimination policy, and allowed the employee to transfer worksites and take medical leave.After the employee took extended medical leave, the company offered him several alternative work assignments, which he either declined or raised objections to. Ultimately, the company considered his refusals as a voluntary resignation and terminated his employment. The employee sued, alleging a hostile work environment and retaliation under Title VII and Michigan law.The United States District Court for the Eastern District of Michigan granted summary judgment to the employer on both claims. It found the company’s actions in response to the harassment allegations were prompt and appropriate, and that the employee failed to show that the termination was pretext for retaliation. On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The appellate court held that the employer was not liable for coworker harassment because it took reasonable steps to investigate and address the allegations, and that the employee did not present sufficient evidence of pretext regarding his termination. View "Hamm v. Pullman SST, Inc." on Justia Law

Donald Stephens was employed as an operator for United States Environmental Services, LLC, a position that required him to maintain a valid commercial driver's license (CDL). During a Saturday shift, Stephens refused to perform tasks typically assigned to technicians and raised several safety concerns, including inadequate equipment and staff. He also disclosed a heart condition to his supervisor. As a result, he was required to undergo a medical examination, which led to a 45-day medical hold on his CDL. Although he was medically cleared to perform non-driving work, USES denied his request for reassignment and recommended he seek short-term disability. After the hold was lifted and he was cleared to drive, Stephens resigned, claiming discomfort with his treatment by USES. Stephens filed suit in the United States District Court for the Eastern District of Arkansas, alleging disability discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Arkansas Civil Rights Act, as well as violations of the Fair Labor Standards Act (FLSA). The district court dismissed the FLSA claim and granted summary judgment to USES on the remaining claims. The court held that Stephens did not have a disability as defined by the ADA because his heart condition did not substantially limit a major life activity, and that USES did not regard him as disabled. The court also found that Stephens had not engaged in protected activity necessary to support a retaliation claim. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment ruling de novo. The appellate court affirmed the district court’s judgment, holding that Stephens did not demonstrate a substantial limitation of a major life activity and did not establish that he engaged in protected activity under the ADA. The Eighth Circuit also declined to consider an argument Stephens raised for the first time on appeal. View "Stephens v. U.S. Environmental Services LLC" on Justia Law

An airline employee, who began working in 1996 and served as a union representative, was terminated in 2023 after allegedly violating both company policy and the terms of a Last Chance Agreement (LCA) he had previously entered into. The LCA was signed following an earlier incident in which he admitted to theft, and it stipulated that any further violation of company policy during its term would result in immediate termination. In October 2023, the employee entered a restricted area in violation of company policy, leading to his discharge.Following his termination, the employee filed a lawsuit in the United States District Court for the Northern District of Texas, alleging retaliatory termination under the Railway Labor Act (RLA) and asserting that his termination was motivated by anti-union animus due to his activities as a union representative. The airline moved to dismiss the complaint, arguing that the dispute was a “minor” one under the RLA, which meant it was subject to mandatory arbitration as outlined in the collective bargaining agreement (CBA), thus depriving the federal court of subject-matter jurisdiction. The district court agreed and granted the airline’s motion to dismiss under Rule 12(b)(1), finding that the dispute was minor and did not fall within any exceptions allowing for judicial intervention.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court properly dismissed the case for lack of subject-matter jurisdiction. The Fifth Circuit affirmed the district court’s decision, holding that the dispute was a minor one under the RLA because it could be resolved by interpreting the LCA and CBA, and that none of the exceptions to exclusive arbitral jurisdiction applied. The court also found no sufficient evidence of anti-union animus to invoke an exception to arbitral exclusivity. View "Reardon v. American Airlines" on Justia Law

A franchisee brought several claims against a franchisor and related parties, including allegations of breach of contract, unjust enrichment, violations of Florida law, and Fair Labor Standards Act (“FLSA”) violations. The parties settled, with the franchisee receiving $50,000 and both sides signing a mutual release that broadly barred any future claims. The agreement was not approved by a court or the Department of Labor and contained a confidentiality provision. Subsequently, the franchisee initiated a separate action for fraudulent transfer and other non-FLSA claims, arguing these were not barred by the settlement’s release.After the settlement, the franchisee filed a supplemental complaint in the United States District Court for the Middle District of Florida, alleging fraudulent transfer and related non-FLSA claims. The franchisor responded with a motion for judgment on the pleadings, citing the settlement’s release. The franchisor also filed counterclaims, including breach of contract based on the franchisee’s new filings. The franchisee attempted to amend his complaint to add a claim for rescission, arguing fraudulent inducement, but the magistrate judge denied this motion, finding it was inadequately pleaded and untimely. The franchisee did not properly object to this denial before the district judge.The United States Court of Appeals for the Eleventh Circuit considered whether the unapproved settlement agreement barred the non-FLSA claims. The court held that, while FLSA claims cannot be waived or settled without court or Department of Labor approval, non-FLSA claims may be released according to state contract law. The court found the release enforceable under Florida law as to non-FLSA claims and affirmed the district court’s dismissal of the fraudulent transfer claims and grant of summary judgment to the franchisor on its counterclaims. The court also ruled the franchisee had waived his right to appeal the denial of his motion to amend. View "O'Neal v. American Shaman Franchise Systems, Inc." on Justia Law

A group of current and former warehouse workers employed by the defendants in Connecticut alleged that their employer failed to compensate them for time spent undergoing mandatory security screenings before leaving the workplace at the end of their shifts. The procedures required employees to pass through security—sometimes involving metal detectors, divesting tables, or X-ray machines—before being allowed to exit the premises. The length of these screenings varied, but employees were required to remain on the employer’s property during the process.After the workers filed a class action complaint in the Connecticut Superior Court, the defendants removed the case to the United States District Court for the District of Connecticut. The District Court granted summary judgment in favor of the employer, concluding that Connecticut’s wage laws were intended to align with federal law, specifically the Fair Labor Standards Act (FLSA) as amended by the Portal-to-Portal Act, and that, under federal law, such security screenings are not compensable. The workers appealed, and the United States Court of Appeals for the Second Circuit certified two questions to the Supreme Court of Connecticut regarding the interpretation of Connecticut’s wage laws.The Supreme Court of Connecticut held that, under the unambiguous language of Connecticut law, employers must compensate employees for all time required on the employer’s premises, including time spent undergoing mandatory security screenings. The Court further determined that Connecticut law does not recognize a de minimis exception that would allow employers to disregard small amounts of time as noncompensable. Thus, the Court answered the first certified question in the affirmative and the second in the negative, clarifying that Connecticut wage laws are more protective than federal law in this respect. View "Del Rio v. Amazon.com Services, Inc." on Justia Law

An employee working as a prep cook at a restaurant was injured during a physical altercation with a co-worker. The altercation arose out of a workplace argument that escalated, resulting in the co-worker striking the employee and causing significant injury. The injured employee filed a workers’ compensation claim, while the employer and its insurer denied liability, asserting the “initial physical aggressor” defense under California Labor Code section 3600(a)(7), arguing that the employee was the initial physical aggressor and thus barred from recovery.The matter was tried before a Workers’ Compensation Administrative Law Judge (WCJ), who heard testimony from all involved and found that the employee was the initial physical aggressor, based largely on the credibility of eyewitnesses. The WCJ denied the employee’s claim for compensation. The employee timely filed a petition for reconsideration with the Workers’ Compensation Appeals Board (WCAB). Although the petition was filed and transmitted within the statutory 60-day period, the WCAB did not review it until after the deadline. The WCAB ultimately granted reconsideration, rescinded the WCJ’s denial, and found that the “initial physical aggressor” defense had not been proven, thus allowing the employee’s claim.The California Court of Appeal, Sixth Appellate District, reviewed the WCAB’s order. The court held that under former section 5909 of the Labor Code, the WCAB lost jurisdiction to act on the petition for reconsideration after the 60-day statutory period elapsed, unless grounds for equitable tolling were present. The court concluded that equitable tolling was not warranted here because there was no evidence of reasonable diligence or special circumstances justifying such relief. Therefore, the court reversed the WCAB’s order and decision after reconsideration. View "Zenith Insurance Co. v. Workers' Compensation Appeals Bd." on Justia Law