Justia Labor & Employment Law Opinion Summaries

The case involves Leika Joanna García-Gesualdo, who filed an employment discrimination lawsuit against Honeywell Aerospace of Puerto Rico, Inc., and Honeywell International, Inc. García-Gesualdo alleged that Honeywell discriminated against her in violation of Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA). The EEOC investigated her claims but decided not to proceed further, issuing a right-to-sue letter on March 29, 2022. García-Gesualdo filed her lawsuit on July 7, 2022, 100 days after the EEOC's decision.The United States District Court for the District of Puerto Rico dismissed García-Gesualdo's claims as time-barred, agreeing with Honeywell that the complaint was filed more than ninety days after the EEOC issued the right-to-sue letter. The court noted that García-Gesualdo's attorney received emails from the EEOC on March 29 and April 6, indicating that a new document was available on the EEOC's portal. The district court concluded that the ninety-day period began on either March 29 or April 6, making the July 7 filing untimely.The United States Court of Appeals for the First Circuit reviewed the case and reversed the district court's dismissal. The appellate court held that neither the March 29 email nor the April 6 email provided sufficient notice of García-Gesualdo's right to sue. The court emphasized that the emails did not unambiguously indicate that the EEOC had terminated its processes or that the ninety-day period to file a lawsuit had begun. Therefore, the appellate court concluded that the facts establishing untimeliness were not clear on the face of the pleadings, and the case was remanded for further proceedings. View "Garcia-Gesualdo v. Honeywell Aerospace of Puerto Rico, Inc." on Justia Law

Christina DeBenedetti and Morgan Ensburg were involved in a marital dissolution case where the trial court assigned four of Morgan’s ERISA-governed retirement accounts to Christina through Qualified Domestic Relations Orders (QDROs). This assignment was to satisfy an award made against Morgan after the court found he breached his fiduciary duty to Christina, resulting in a loss of community property. The total amount ordered for reimbursement and attorney fees exceeded $2 million.The Superior Court of San Diego County initially issued QDROs dividing the community property interests in Morgan’s retirement accounts. After a trial on reserved financial disputes, the court found Morgan had mismanaged community property and awarded Christina $1,831,250 for her share of the lost assets and $230,000 in attorney fees. Christina later sought to enforce this award through new QDROs, which the trial court granted, assigning her 100% of Morgan’s remaining interests in the retirement plans.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. Morgan argued that the QDROs did not relate to “marital property rights” and violated ERISA’s purpose of protecting retirement income. He also claimed the QDROs were invalid under California law and that the trial court did not value the retirement accounts. The appellate court rejected Morgan’s contentions, holding that the QDROs related to marital property rights, complied with ERISA, and that California laws cited by Morgan were either preempted by ERISA or did not invalidate the orders. The court also found that Morgan’s argument regarding the valuation of the retirement accounts was not raised in the trial court and could not be considered on appeal. The appellate court affirmed the trial court’s orders. View "In re Marriage of DeBenedetti" on Justia Law

Event Media Inc. and Pack Expo Services, LLC, were contributing employers to the Central States, Southeast and Southwest Areas Pension Fund. Both companies withdrew from the Fund and incurred withdrawal liability obligations. The dispute centers on how to calculate these obligations, specifically whether post-2014 contribution rate increases should be included in the calculation.The United States District Court for the Northern District of Illinois, Eastern Division, held that the employers' post-2014 contribution rate increases should be excluded from the calculation of their withdrawal liability payments. The court reasoned that these increases were required by a rehabilitation plan and thus should be disregarded under 29 U.S.C. § 1085(g)(3).The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the post-2014 contribution rate increases were indeed required by the rehabilitation plan and should be excluded from the calculation of the employers' withdrawal liability payments. The court concluded that neither of the exceptions outlined in 29 U.S.C. § 1085(g)(3)(B) applied in this case, as the increases were not due to increased levels of work, employment, or periods for which compensation is provided, nor were they used to provide an increase in benefits permitted by subsection (f)(1)(B). Therefore, the Fund must use the 2014 contribution rate, not the higher 2019 rate, in calculating the employers' withdrawal liability payments. View "Central States, Southeast and Southwest Areas Pension Fund v. Event Media Inc." on Justia Law

Several hair stylists filed a lawsuit against their employer, Lady Jane’s Haircuts for Men, alleging that they were underpaid due to being misclassified as independent contractors instead of employees. This misclassification, they argued, allowed the employer to avoid the Fair Labor Standards Act’s minimum-wage and overtime-pay requirements. The employer moved to dismiss the lawsuit, citing an arbitration agreement in the Independent Contractor Agreement, which required disputes to be resolved through the American Arbitration Association (AAA) under its Commercial Arbitration Rules.The United States District Court for the Eastern District of Michigan reviewed the case and found the arbitration agreement enforceable but severed the cost-shifting provision, which required the stylists to pay arbitration costs exceeding their yearly income. The court ruled that the arbitration would proceed under the less costly AAA employment rules and dismissed the lawsuit in favor of arbitration.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the severability clause in the contract allowed the court to remove the cost-shifting provision while enforcing the rest of the arbitration agreement. The court found that the term “provision” in the severability clause referred to individual clauses within the contract, not entire sections. The court also rejected the stylists’ arguments that the district court had impermissibly reformed the contract and that the arbitration agreement should be unenforceable for equitable reasons. The court concluded that the district court correctly severed the cost-shifting provision and enforced the arbitration agreement under the AAA’s employment rules. View "Gavin v. Lady Jane's Haircuts for Men" on Justia Law

A landlord operated a business renting homes and had a tenant who performed repair, maintenance, and improvement work in exchange for reduced rent and payment. The tenant fell while working on the roof of one of the rental units and filed a workers' compensation claim. The landlord denied an employment relationship and disputed the work-related injury.The Director of the Department of Labor and Industrial Relations ruled in favor of the tenant, finding an employer-employee relationship. The landlord appealed, and the Labor and Industrial Relations Appeals Board (LIRAB) reversed the Director's decision, concluding there was no employment relationship under the control and relative nature of work tests. The tenant appealed to the Intermediate Court of Appeals (ICA), which vacated parts of LIRAB's decision, instructing LIRAB to apply the substantial evidence standard instead of the preponderance of the evidence standard.The Supreme Court of the State of Hawai'i reviewed the case. The court held that the landlord did not present substantial evidence to rebut the presumption of an employment relationship under the relative nature of the work test. The tenant's work was integral to the landlord's rental business, and the tenant did not have a business of his own. Therefore, the court concluded that an employer-employee relationship existed, and the tenant's injury was covered under Hawai'i's workers' compensation laws. The court vacated LIRAB's decision and the ICA's judgment, remanding the case to LIRAB to compute compensation. The court also held that the landlord was not responsible for the tenant's attorney fees and costs. View "Borrson v. Weeks" on Justia Law

A former employee, Corbin Williams, worked as an insurance adjuster for Alacrity Solutions Group, LLC, from 2014 until January 2022. Williams typically worked 84-hour weeks but was not paid overtime, violating the Labor Code. In March 2023, over a year after his employment ended, Williams notified the California Labor & Workforce Development Agency of his intent to pursue a PAGA action for these violations. He then filed a lawsuit seeking civil penalties on behalf of other current and former employees but not on his own behalf.The Superior Court of Los Angeles County sustained a demurrer to Williams's complaint without leave to amend, finding the action time-barred. The court noted that Williams had not suffered any Labor Code violations within the one-year statute of limitations period before notifying the Agency, as his employment ended in January 2022. Consequently, the court did not address the defendant's alternative argument regarding Williams's standing.The California Court of Appeal, Second Appellate District, Division Five, affirmed the lower court's decision. The court held that to be a PAGA plaintiff, an individual must have a timely individual claim for at least one Labor Code violation. Since Williams's individual claims were time-barred, he could not satisfy this requirement. The court rejected Williams's arguments that other aggrieved employees' timely claims could substitute for his own untimely claims and that the continuous accrual doctrine applied. The court also found no abuse of discretion in denying leave to amend, as Williams's proposed amendments would not cure the timeliness defect. View "Williams v. Alacrity Solutions Grp." on Justia Law

A dispute arose regarding the National Labor Relations Board’s (NLRB) rule on when one entity is considered a joint employer of another entity’s employees. The NLRB determined that Google was a joint employer of Cognizant employees working on Google’s YouTube Music platform and ordered both companies to bargain with the employees’ union, the Alphabet Workers Union-Communication Workers of America, Local 9009 (AWU). Google and Cognizant refused to bargain, leading the NLRB to conclude that this refusal violated the National Labor Relations Act (NLRA). The employers petitioned for review, arguing they were not joint employers, but the contract under which the employees provided services to Google expired, rendering the petitions and the Board’s cross-applications for enforcement moot. The Union also petitioned for review, contending that the NLRB’s remedies were insufficient.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the expiry of the Google-Cognizant contract meant there was no longer any relationship to support the joint-employer finding, making the case moot. The court dismissed Google’s and Cognizant’s petitions and the Board’s cross-applications as moot and vacated the order below. The court also dismissed as jurisdictionally barred the part of AWU’s petition seeking review of the NLRB’s decision to sever the issue of a make-whole remedy for employees and dismissed as moot those parts of AWU’s petition seeking prospective remedies.The court denied the remainder of AWU’s petition, concluding that the NLRB did not abuse its discretion by ordering only the customary remedies. The court emphasized that the Board’s choice of remedies is primarily within its province and subject to very limited judicial review. View "Alphabet Workers Union-Communication Workers v. NLRB" on Justia Law

Plaintiffs, former employees of Vicar Operating, Inc., filed a class action lawsuit alleging that Vicar failed to provide the required meal periods as mandated by California Labor Code section 512 and IWC Wage Orders Nos. 4-2001 and 5-2001. Vicar contended that the plaintiffs had signed valid written agreements prospectively waiving their meal periods for shifts between five and six hours, which could be revoked at any time. The plaintiffs argued that such prospective waivers allowed employers to circumvent statutory meal break requirements and denied employees a meaningful opportunity to exercise their right to meal breaks.The Superior Court of Los Angeles County granted summary adjudication in favor of Vicar, determining that the prospective waivers were valid under section 512 and the wage orders. The court found that the plain language of the statute and wage orders permitted such waivers and distinguished the case from Brinker Restaurant Corp. v. Superior Court, which did not address the timing of meal break waivers. The court also concluded that a DLSE opinion letter cited by the plaintiffs was not applicable as it interpreted different wage order regulations.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case and affirmed the lower court's decision. The appellate court held that the revocable, prospective waivers signed by the plaintiffs were enforceable in the absence of any evidence that the waivers were unconscionable or unduly coercive. The court concluded that the prospective written waiver of a 30-minute meal period for shifts between five and six hours was consistent with the text and purpose of section 512 and Wage Order Nos. 4 and 5. The court also determined that the legislative and administrative history confirmed that such waivers were consistent with the welfare of employees and that Brinker did not require a contrary result. View "Bradsbery v. Vicar Operating, Inc." on Justia Law

Dawn Simonson was employed by Douglas County as a histologist and suffered a lower back injury in 1996 while performing her job duties. The injury left her permanently and totally disabled, and she received workers' compensation benefits. When Simonson turned 67 in 2023, her employer stopped paying her permanent total disability (PTD) benefits based on a statutory retirement presumption. Simonson claimed she would have worked past age 67 and sought to rebut the presumption.A compensation judge initially found that Simonson had not rebutted the retirement presumption, applying factors from a previous case, Davidson v. Thermo King. The judge concluded that Simonson's intent to retire weighed in favor of the employer, while her financial need weighed in her favor, and other factors were neutral or irrelevant. The Workers’ Compensation Court of Appeals (WCCA) reversed this decision, concluding that the proper standard of proof to rebut the presumption was a preponderance of the evidence and that Simonson had met this burden based on her financial need.The Minnesota Supreme Court reviewed the case and affirmed the WCCA's determination that the preponderance-of-the-evidence standard applies when an employee seeks to rebut the retirement presumption. However, the Supreme Court found that the WCCA erred in emphasizing financial need as the primary factor. Instead, the court held that the relevant question is whether the employee would have retired anyway, even if not disabled, considering various factors such as the availability of work, retirement arrangements, age, work history, and willingness to forgo social security benefits. The case was remanded to the compensation judge for further findings consistent with this opinion. View "Simonson v. Douglas County" on Justia Law

Kassandra Memmer sued her former employer, United Wholesale Mortgage (UWM), alleging discrimination and sexual harassment during her employment. UWM moved to dismiss the lawsuit and compel arbitration based on the employment agreement. Memmer argued that the arbitration agreement was invalid and that she had the right to go to court under the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA).The United States District Court for the Eastern District of Michigan granted UWM's motion to dismiss and compel arbitration, concluding that the parties had a valid arbitration agreement. The court did not address Memmer's argument regarding the applicability of EFAA. Memmer appealed the decision, asserting that EFAA should apply to her case.The United States Court of Appeals for the Sixth Circuit reviewed the case and concluded that EFAA applies to claims that accrue after its enactment date and to disputes that arise after that date. The court determined that the district court had not applied the correct interpretation of EFAA. The Sixth Circuit reversed the district court's decision and remanded the case for further proceedings to determine when the dispute between Memmer and UWM arose and whether EFAA applies to her claims. View "Memmer v. United Wholesale Mortgage, LLC" on Justia Law