Justia Labor & Employment Law Opinion Summaries

The plaintiff, who worked as a truck driver for the defendants for approximately nine months in 2018, brought claims alleging that the defendants failed to provide required meal and rest breaks, failed to reimburse necessary work-related expenses, and violated California’s unfair competition law. The plaintiff also filed a representative claim for civil penalties under the Labor Code Private Attorneys General Act of 2004 (PAGA), all arising from his employment as a driver.The Superior Court of Sutter County denied the plaintiff’s motion for class certification on the meal break, rest break, expense reimbursement, and unfair competition claims. In particular, the court found that the plaintiff failed to present substantial evidence of a common policy of discouraging breaks or of a community of interest among the proposed class members. The court relied on declarations from other drivers indicating they were not discouraged from taking breaks and noting variability in their experiences. The court also granted the defendants’ motion to strike the PAGA claim on manageability grounds, reasoning that adjudicating the claim would require individual testimony from 75 drivers and would be unmanageable.The California Court of Appeal, Third Appellate District, affirmed in part and reversed in part. It affirmed the denial of class certification for the rest break and expense reimbursement claims, finding insufficient evidence of commonality. However, it reversed the denial of class certification for the meal break and derivative unfair competition claims, holding that the trial court failed to apply the burden-shifting framework required by Donohue v. AMN Services, LLC when time records show missed or unrecorded meal breaks. Additionally, the appellate court reversed the order striking the PAGA claim, holding that trial courts lack inherent authority to strike PAGA claims solely based on manageability concerns, as clarified in Estrada v. Royalty Carpet Mills, Inc. The case was remanded for further proceedings, including consideration of whether the PAGA claim is preempted by federal law. View "Dieves v. Butte Sand Trucking Co." on Justia Law

A female senior administrator at a Mississippi public university, who had served as Vice President and Chief of Staff since 2017, alleged that she was not hired for the position of university president on two occasions, in 2020 and 2023, despite her extensive qualifications and expressed interest. In 2020, following the resignation of the then-president, the university’s governing board appointed a less-experienced male interim president without conducting a search or soliciting applications, even though the plaintiff had managed university affairs in the president’s absence. After the interim president was placed on administrative leave in 2023, the board began a new search. The plaintiff applied but was denied an interview; instead, the board selected another male candidate with less experience, who had not applied for the position.The plaintiff filed suit against the board members in their individual capacities, alleging sex discrimination under the Equal Protection Clause via 42 U.S.C. § 1983, as well as Title VII claims. The United States District Court for the Southern District of Mississippi dismissed all claims against the individual board members except for the § 1983 equal protection claim regarding the 2023 hiring decision. The district court found that the plaintiff stated a prima facie case of sex discrimination and that the right to be free from such discrimination was clearly established, thus denying the defendants’ motion to dismiss based on qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo. The court held that the plaintiff adequately pleaded a violation of clearly established equal protection rights, including allegations that each defendant took individual actions causing the asserted harm. The Fifth Circuit therefore affirmed the district court’s denial of the motion to dismiss as to the § 1983 equal protection claim arising from the 2023 hiring decision. View "Jackson v. Duff" on Justia Law

A group of retired law enforcement officers who had worked for a Connecticut town sought a court declaration that they were entitled to receive contributions to their health savings accounts (HSAs) from the town in the same manner as currently employed police officers. The retirees based their claim on a pension agreement negotiated by the town and their union, which provided that retirees would receive health insurance coverage, including deductibles, “in effect for active Police Officers.” After these retirees left their positions, a new collective bargaining agreement was executed that changed the town’s insurance plan to a high deductible health plan and required the town to contribute 50% of the deductible amount to the HSAs of active police officers. The retirees, now participating in the same insurance plan, did not receive these contributions.The Superior Court for the judicial district of New London found in favor of the retirees, concluding that the pension agreement entitled them to the same HSA contributions as active officers. The court awarded damages accordingly. The Appellate Court affirmed, reasoning that the effect of the HSA contributions was to lower the deductible for active officers, and that the retirees were entitled to equal treatment under the pension agreement.On appeal, the Connecticut Supreme Court reviewed whether these HSA contributions constituted “coverage” or “deductibles” under the relevant pension agreement. The court held that the ordinary meaning of “coverage” and “deductible” did not include HSA contributions, which are distinct from the insurance policy’s terms and can be used for a variety of purposes. The court further noted that extrinsic evidence, including subsequent collective bargaining agreements, confirmed that the contracting parties did not intend HSA contributions for retirees. The Supreme Court reversed the Appellate Court’s judgment and directed that judgment be entered for the town. View "Duso v. Groton" on Justia Law

A former hourly employee brought a class action lawsuit against his former employer, a large wood products company, alleging various wage and hour violations under California law. The proposed classes included both employees who had signed arbitration agreements and those who had not. While some nonexempt employees had signed arbitration agreements requiring individual arbitration and waiving class actions, the named plaintiffs had not. The employer did not initially assert arbitration as a defense and, when ordered by the court to produce copies of signed arbitration agreements for putative class members, failed to do so for several years.During the course of discovery in the Superior Court of Shasta County, the employer repeatedly resisted requests to identify or produce arbitration agreements for employees who had signed them, leading to multiple discovery sanctions. The employer participated in extensive discovery and mediation involving employees who had signed arbitration agreements, without distinguishing them from other putative class members. Only after class certification did the employer finally produce thousands of signed arbitration agreements and immediately moved to compel arbitration for those employees. Plaintiffs opposed, arguing the employer had waived its right to arbitrate by years of litigation conduct inconsistent with an intent to arbitrate, and sought evidentiary and issue sanctions for delayed production.The California Court of Appeal, Third Appellate District, reviewed the case. Applying the California Supreme Court’s standard from Quach v. California Commerce Club, Inc., the appellate court held that the employer waived its right to compel arbitration by clear and convincing evidence. The employer’s prolonged failure to produce arbitration agreements and its conduct throughout litigation was inconsistent with an intention to enforce arbitration. The order denying the motion to compel arbitration was affirmed, and the appeal from the order granting evidentiary and issue sanctions was dismissed as nonappealable. View "Sierra Pacific Industries Wage and Hour Cases" on Justia Law

After divorcing in 2010, a former employee and his ex-spouse entered into a court-approved domestic relations order in North Carolina that divided his employer-sponsored retirement plan benefits. The order stipulated that the ex-spouse would be treated as a surviving spouse, entitling her to survivor benefits under the plan, and stated that her portion of the benefit "may be reduced as necessary" to cover the cost of the survivor annuity. Years later, when the employee retired and began receiving benefits, he argued that the plan administrator improperly reduced his monthly payment by factoring the cost of the survivor annuity into his share, rather than allocating the cost solely to his ex-spouse’s portion. He also claimed that the plan administrator failed to timely provide all requested plan documents, warranting statutory penalties.The United States District Court for the Western District of North Carolina granted summary judgment for the employer and plan administrator. The court found that the plan administrator correctly interpreted the qualified domestic relations order (QDRO) to permit, but not require, allocating the cost of the survivor annuity to the ex-spouse’s share, and that the benefit calculation was consistent with the plan terms and not an abuse of discretion. Additionally, the court held that the plaintiff was not prejudiced by any delay in receiving plan documents and denied statutory penalties.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed. The Fourth Circuit concluded that de novo review was appropriate for interpreting the QDRO, while the plan administrator’s benefit calculations were reviewed for abuse of discretion. The court held that the QDRO’s language was unambiguous and permissive, not mandatory, regarding who should bear the cost of the survivor annuity. The court also upheld the denial of statutory penalties, finding no prejudice or bad faith. The district court’s summary judgment for the defendants was affirmed. View "Gasper v. EIDP, Inc." on Justia Law

An employer engaged in the cybersecurity industry hired an employee for a marketing and sales position after recruiting him away from a competitor. The parties signed a written employment agreement that described a specific role and compensation structure. The employee alleged that the promised position did not actually exist and that he was instead given an entry-level sales role. Although the employee changed employers, he remained at his existing residence in Las Vegas throughout his employment.The employee sued the employer, claiming a violation of Nevada's employment-luring statute, NRS 613.010, which prohibits employers from inducing workers to change locations under false pretenses regarding employment terms. The employer moved for summary judgment in the Eighth Judicial District Court, arguing that the statute did not apply because the employee had not physically relocated his residence. The employee countered that the statute applies when an employee changes their place of employment, not necessarily their residence. The district court denied the employer’s motion for summary judgment, finding that the statute’s civil cause of action provision supports the employee’s interpretation. The court also denied the employer’s later motion to strike the employee’s jury demand, ruling the employer had waived the argument by waiting too long to raise it.The Supreme Court of the State of Nevada reviewed the case and held that NRS 613.010 authorizes a civil cause of action when an employee changes their place of employment in response to false or deceptive representations by an employer, even if the employee does not change their place of residence. The court further found that the district court did not abuse its discretion in denying the motion to strike the jury demand. Accordingly, the Supreme Court denied the employer’s petition for a writ of mandamus. View "Field Effect Security, Inc. v. District Court" on Justia Law

These consolidated cases concern the constitutionality of statutory limits on the President’s authority to remove members of the National Labor Relations Board (NLRB) and the Merit Systems Protection Board (MSPB). Both agencies are composed of members appointed by the President with Senate confirmation, and statutes prohibit the President from removing members except for cause. The NLRB oversees labor relations and union elections, with powers including rulemaking, adjudication, and the issuance of affirmative remedies. The MSPB administers federal employment disputes and can issue final orders, award a range of remedies, and promulgate certain regulations.After the President removed Gwynne Wilcox from the NLRB and Cathy Harris from the MSPB—without alleging the statutory grounds for removal—Wilcox and Harris challenged their removals in the United States District Court for the District of Columbia. The District Court held that the statutory protections against removal were constitutional under the precedent of Humphrey’s Executor v. United States, declared Wilcox and Harris remained in office, and enjoined the government from interfering with their roles. The government appealed, and the Supreme Court stayed the district court’s orders pending appeal, signaling skepticism about the constitutionality of the removal restrictions.The United States Court of Appeals for the District of Columbia Circuit reversed the district courts’ judgments. The court held that, under Seila Law LLC v. Consumer Financial Protection Bureau, Congress may not restrict the President’s ability to remove principal officers who wield substantial executive power. The court found that both the NLRB and MSPB exercise powers that are executive in nature and go beyond the quasi-legislative or quasi-judicial functions contemplated in Humphrey’s Executor. Consequently, statutory restrictions on the President’s removal authority for members of these boards are unconstitutional. The court ordered that the removal protections for NLRB and MSPB members be disregarded. View "Harris v. Bessent" on Justia Law

A company that provides temporary labor to various industries offers daily work opportunities to individuals at its labor halls. Workers can choose whether to accept job assignments, and once they do, they are responsible for arriving at the jobsite on time. The company offers several transportation options—including vans, carpools, and public transit—with a nominal fee deducted from paychecks for those who use company-arranged transportation. Workers can also bring their own tools or use company-provided equipment, with deductions only made for unreturned items.A group of workers filed a class action in the United States District Court for the Southern District of Florida, alleging violations of the Fair Labor Standards Act (FLSA) and the Florida Minimum Wage Act. They claimed that transportation deductions reduced their pay below the minimum wage and that the company failed to pay for travel time, time spent collecting tools, and waiting time. The plaintiffs also raised a claim under the Florida Labor Pool Act regarding excessive transportation charges. The district court granted summary judgment to the company on the FLSA and minimum wage claims, denied the plaintiffs’ summary judgment motion, and declined to certify the subclass related to excessive transportation charges.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the transportation deductions were lawful because the transportation was optional and for the benefit of employees, not the employer. The court further held that time spent traveling, collecting tools, and waiting was not integral and indispensable to the workers’ principal activities and was thus noncompensable under the FLSA. Finally, the court affirmed the district court’s denial of class certification for the excessive-transportation-charge subclass, finding that individual inquiries would predominate. The judgment of the district court was affirmed. View "Villarino v. Pacesetter Personnel Service, Inc." on Justia Law

A deputy sheriff of Arabic descent, employed by the Richmond County Sheriff’s Office, was assigned to an off-duty security position at a local business. During his assignment, he alleged that his supervisor subjected him to repeated racial harassment, including derogatory remarks about his ethnicity. Witnesses at the business supported these allegations, noting that the supervisor frequently made such comments. The deputy was also interested in joining the SWAT team, which the supervisor led, but after failing the SWAT entrance exam, the deputy filed a formal internal complaint about the harassment.Shortly thereafter, the deputy was investigated and ultimately terminated for allegedly violating departmental policy by making personal use of his patrol vehicle, specifically for visiting another county’s sheriff’s office to inquire about job opportunities. The deputy provided evidence that other officers regularly made similar personal use of patrol vehicles without being disciplined, and argued that his termination was in retaliation for his internal complaint. He filed suit under 42 U.S.C. § 1981, claiming retaliatory discharge.The United States District Court for the Southern District of Georgia granted summary judgment for the defendants, finding that the deputy had not shown that the employer’s stated reason for termination was a pretext for retaliation.On appeal, the United States Court of Appeals for the Eleventh Circuit concluded that the District Court erred by conflating the McDonnell Douglas pretext analysis with the “convincing mosaic” standard. The Eleventh Circuit held that a plaintiff may survive summary judgment by presenting circumstantial evidence that creates a triable issue regarding retaliatory intent, even if pretext is not conclusively shown. The court reversed and remanded for the District Court to apply the correct summary judgment standard. View "Ismael v. Roundtree" on Justia Law

In 2015, a firefighter suffered a compensable back injury while working part-time for a fire company. He settled his workers’ compensation claim related to that incident in 2018 by accepting a lump sum and releasing the insurer from future liability. Years later, in 2023, while working for a different fire department, he experienced another back injury while carrying heavy equipment up stairs during a call. Medical evaluations indicated the new injury involved the same area of his spine as the 2015 incident. The firefighter sought workers’ compensation from his current employer, but the claim was denied.The Industrial Accident Board (IAB) held an evidentiary hearing, receiving testimony from the claimant, his treating physician, and an orthopedic surgeon retained by the employer. The Board concluded that the 2023 incident was a recurrence of the 2015 injury—not an aggravation or a new injury—based primarily on the orthopedic surgeon’s opinion and a comparison of medical imaging. Under Delaware law, liability for a recurrence rests with the insurer on the risk for the original injury, while an aggravation caused by a new workplace incident would be covered by the current employer’s insurer. Because the firefighter had already settled and released all claims relating to the 2015 injury, no compensation was available for the 2023 event. The Superior Court of the State of Delaware affirmed the Board’s decision, finding that the correct legal standard had been applied and that the decision was supported by substantial evidence.On appeal, the Supreme Court of the State of Delaware affirmed the Superior Court’s judgment. The Supreme Court held that the IAB and the Superior Court properly applied the standard from Standard Distributing Co. v. Nally for distinguishing between recurrence and aggravation in successive injury cases, and that substantial evidence supported the Board’s finding that the 2023 incident was a recurrence rather than an aggravation or a new injury. View "Corey Ferrell v. City of Wilmington IAB" on Justia Law