Justia Labor & Employment Law Opinion Summaries

A former employee of a company signed a document as a condition of her employment that purported to shorten the period in which she could sue her employer for workplace disputes, including discrimination claims, to 180 days. This agreement included a tolling provision for the period when a charge was pending before an administrative agency. The employee was terminated and, after filing timely administrative charges with the EEOC and the Maryland Commission on Civil Rights, she received a right-to-sue letter. She then filed suit in federal court, alleging violations of Title VII, the ADEA, and the Maryland Fair Employment Practice Act (MFEPA).After the employer moved to dismiss on the grounds that the lawsuit was untimely under the agreement, the United States District Court for the District of Maryland, treating the motion as one for summary judgment, ruled in favor of the employer. The district court concluded the parties had validly agreed to shorten the limitations period, making the employee’s claims untimely.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. The court held that, as to the Title VII and ADEA claims, private parties may not, by advance agreement, prospectively shorten the statutory time periods for filing suit provided by Congress. The court reasoned that judicial enforcement of such agreements would undermine the comprehensive and uniform remedial schemes established by those statutes. Therefore, the court vacated the district court’s grant of summary judgment on the Title VII and ADEA claims and remanded for further proceedings. However, the court affirmed the dismissal of the MFEPA claims, finding that Maryland law permits reasonable contractual modifications of limitations periods and that the employee had not demonstrated the provision was unreasonably short or otherwise invalid under state law. View "Thomas v. EOTech, LLC" on Justia Law

Two companies that operate app-based delivery platforms challenged a Seattle ordinance enacted in 2023, which aims to protect gig economy workers from unwarranted account deactivations. The law requires “network companies” to provide workers with written deactivation policies and mandates that these policies be “reasonably related” to the companies’ safe and efficient operations. The ordinance also delineates examples of impermissible deactivation grounds, such as those based solely on customer ratings or certain background checks. The companies did not contest the general bar on unwarranted deactivations but argued that the notice and deactivation policy requirements violate the First Amendment and that the ordinance is unconstitutionally vague.In the United States District Court for the Western District of Washington, the companies sought a preliminary injunction to prevent the ordinance from taking effect. The district court denied their motion. It found that the ordinance regulates conduct (the act of deactivating accounts) rather than speech, and that any impact on expression is incidental. The court also concluded that the use of “reasonable” in the ordinance was not unconstitutionally vague, pointing to statutory context and specific examples for guidance.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of injunctive relief. The court held that the ordinance regulates nonexpressive conduct, not speech, and thus does not trigger First Amendment scrutiny. Alternatively, if the ordinance were seen as regulating speech, that speech would be commercial in nature, and the law would satisfy the lower level of scrutiny applicable to compelled factual commercial disclosures. The court further held that the ordinance is not unconstitutionally vague, as it provides adequate notice of what is prohibited. The disposition by the Ninth Circuit was to affirm the district court’s denial of injunctive relief. View "MAPLEBEAR INC. V. CITY OF SEATTLE" on Justia Law

Elizabeth Chitwood worked as a human resources specialist for Ascension and was granted intermittent Family and Medical Leave Act (FMLA) leave for migraines in 2021, which she was required to report on the same day to a third-party administrator, Sedgwick, and to notify her supervisor as soon as practicable. She also received approval for continuous FMLA leave to care for her son from August 31 to November 3, 2021. After her continuous leave ended, Chitwood did not return to work despite explicit instructions and warnings from Ascension. She instead applied for a personal leave, which was denied, and ultimately left a voicemail on November 15, 2021, implying she believed she had been terminated. Ascension terminated her that day for failure to return to work. The following day, Chitwood attempted to retroactively report intermittent FMLA leave for absences on November 11, 12, and 15, but Ascension rejected these requests since she was already terminated.Chitwood filed suit against Ascension in the United States District Court for the Southern District of Indiana, alleging interference with her FMLA rights and retaliation for using FMLA leave. The district court granted summary judgment for Ascension, finding no reasonable jury could rule in Chitwood’s favor. The court concluded she was not entitled to FMLA benefits at the time of her post-termination requests and had failed to provide timely notice for her absences.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The appellate court held that Chitwood could not prevail on either her FMLA interference or retaliation claims because she was not denied FMLA benefits to which she was entitled and there was no evidence that her termination was retaliatory. The court found that her noncompliance with notice requirements and her failure to return to work justified her termination. View "Chitwood v. Ascension Health Alliance" on Justia Law

A former employee brought suit against his prior employer, alleging that the employer’s compensation plan for commissions violated several provisions of the California Labor Code. The employee claimed that the employer’s use of a “windfall” provision, which limited commission payments when revenue goals were substantially exceeded, resulted in retroactive reductions to earned commissions. The employer invoked this provision after the employee and others exceeded their sales goals, causing the employee’s final commission payment to be lower than anticipated. The employee resigned and later sought civil penalties under the Private Attorneys General Act (PAGA), as well as damages for alleged unpaid wages and other Labor Code violations.The Superior Court of Alameda County compelled arbitration of the employee’s individual claims but allowed the PAGA claims to proceed in court. During arbitration, the arbitrator found in favor of the employer on all individual claims, concluding that the compensation plan’s “windfall” provision did not violate the Labor Code sections at issue. The arbitrator determined that the commissions in question were not subject to the statutory requirements argued by the employee, and that the plan did not involve unlawful wage recapture or secret underpayment. The trial court confirmed the arbitration award, denied the employee’s motion for summary adjudication on the PAGA claim, and subsequently granted the employer’s motion for judgment on the pleadings, finding that the arbitration resolved the issue of whether the employee was an “aggrieved employee” with standing under PAGA.The California Court of Appeal, First Appellate District, Division Four, affirmed the lower court’s judgment. The court held that the arbitration agreement was not illusory, that the arbitrator’s findings precluded the employee from maintaining PAGA standing, and that the employer’s commission plan did not violate the cited Labor Code provisions. The judgment in favor of the employer was affirmed. View "Sorokunov v. NetApp, Inc." on Justia Law

An employee of MITRE Corporation, serving as a Principal Business Process Engineer, contracted COVID-19 twice. After experiencing long-COVID symptoms that prevented her from returning to her occupation, she applied for long-term disability (LTD) benefits under her employer’s ERISA-governed plan, administered by Reliance Standard Life Insurance Company. Reliance denied her claim, asserting she was not “Totally Disabled.” She submitted further medical documentation and filed an internal appeal. The plan and ERISA regulations required Reliance to respond within 45 days, extendable by another 45 days only for “special circumstances,” with written notice specifying the reason and expected decision date.Reliance took more than 45 days to issue a decision, did not specify a date for resolution, and cited only routine medical review as justification for delay. The employee sued in the United States District Court for the Eastern District of Virginia after Reliance failed to timely decide her appeal. The district court found that Reliance had not complied with ERISA’s timing and notice requirements, held that de novo review (rather than deferential review) was appropriate, and ruled in favor of the employee, awarding LTD benefits and interest.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed whether Reliance’s delay deprived it of deferential review of its benefit determination. The court held that, because Reliance failed to decide the internal appeal within the required time and had not justified its delay with a special circumstance, it forfeited any entitlement to deference. The Fourth Circuit affirmed that de novo review applied, found no error in the district court’s factual findings or legal conclusions, and upheld the award of benefits to the employee. View "Cogdell v. Reliance Standard Life Insurance Company" on Justia Law

Two Certified Registered Nurse Anesthetists (CRNAs) were employed by American Anesthesiology of Virginia, a subsidiary of North American Partners in Anesthesia (NAPA), and worked exclusively at medical facilities operated by a health care system. In 2022, the health care system denied their requests for exemptions from its Covid-19 vaccination policy, resulting in the suspension of their clinical privileges. Approximately two months later, NAPA terminated their employment. The CRNAs each filed lawsuits: one sued the health care system for discrimination under Title VII and the Virginia Human Rights Act (VHRA), and the other sued both the health care system and NAPA under Title VII, the Americans with Disabilities Act (ADA), and the VHRA. Both plaintiffs alleged that the health care system was their joint employer with NAPA.The United States District Court for the Eastern District of Virginia dismissed both complaints. It found that neither plaintiff plausibly alleged the health care system was their employer, as necessary for liability under the statutes invoked. Additionally, it dismissed the claims against NAPA for failure to exhaust administrative remedies because the plaintiff did not name NAPA in her Equal Employment Opportunity Commission (EEOC) charge. The district court allowed the plaintiffs to amend their complaints as to the health care system, but upon amendment, again dismissed with prejudice, concluding that the new allegations still did not support a joint employer relationship.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the dismissals de novo. The court held that the plaintiffs failed to plausibly allege that the health care system was their employer under the “joint employment” doctrine, applying a nine-factor control test from Butler v. Drive Automotive Industries of America, Inc. The court further held that the plaintiff’s claims against NAPA were properly dismissed for failure to exhaust administrative remedies. The Fourth Circuit affirmed the district court’s dismissal of both complaints in full. View "Hoffman v. INOVA Health Care Services" on Justia Law

The plaintiff, a former Federal Air Marshal, worked for over seven years within the Transportation Security Administration (TSA). She began her employment after disclosing several vision-related medical conditions, and over time developed additional health problems, including cardiac and nerve issues. As her conditions worsened, TSA placed her on temporary “light duty” and reassigned her to a ground-based Regional Coordinator role with limited flight requirements. Eventually, TSA determined she could not meet the essential medical standards of her position and advised her to seek reassignment. The plaintiff requested reassignment due to her inability to perform the essential duties of her current role and was ultimately transferred to a position at the Federal Law Enforcement Training Centers (FLETC), a separate division within the Department of Homeland Security.Following her reassignment, the plaintiff experienced difficulties in her new role and unsuccessfully sought reconsideration of her reassignment. She subsequently filed a complaint in the United States District Court for the Eastern District of Virginia, alleging that TSA failed to accommodate her disability under the Rehabilitation Act. The district court dismissed her claim, finding that she had not plausibly alleged that she was a “qualified individual” capable of performing the essential functions of her desired position. The court emphasized her own admission that she could not perform those duties and concluded that TSA had provided reasonable accommodations.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s dismissal de novo. The Fourth Circuit affirmed the district court’s decision, holding that the plaintiff was not a “qualified individual” for her desired position because she conceded her inability to perform its essential functions, even with accommodations. The court further held that TSA met its obligation by providing reasonable accommodations, including reassignment, and was not required to offer a permanent “light duty” position. The judgment of the district court was affirmed. View "Redding v. Noem" on Justia Law

The case involves a multi-employer pension fund seeking to collect withdrawal liability under the Multiemployer Pension Plan Amendments Act of 1980 from two corporate entities, which the fund alleged were successors to a defunct contributing employer. The companies denied any liability, contending they had never agreed to make contributions to the fund, were not under common control with the original employer, and were not otherwise subject to the fund’s claims. After the fund notified the companies of the alleged liability several years after the original employer ceased operations, the companies sought a declaratory judgment in federal court to clarify that they were not liable. The fund counterclaimed for withdrawal liability, as well as damages and interest.The United States District Court for the District of New Jersey found genuine disputes of material fact regarding whether the companies could be treated as employers under the applicable law, thus precluding summary judgment on that issue. Nevertheless, the District Court granted judgment in favor of the companies on a separate basis: it concluded that the fund’s eight-year delay in providing notice and demanding payment of withdrawal liability failed to meet the statutory requirement under 29 U.S.C. § 1399(b)(1) that such notice be given “as soon as practicable.” The court reasoned that this requirement is an independent statutory element—not an affirmative defense subject to waiver or arbitration—and that the fund’s failure to comply with it barred any recovery.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that timely notice and demand is a necessary element for a withdrawal liability claim to accrue under the MPPAA; if the fund fails to act “as soon as practicable,” its claim cannot proceed, regardless of whether the issue is raised in arbitration or by the parties. Arbitration was not required in this circumstance, and the District Court properly resolved the question. View "RTI Restoration Technologies Inc v. International Painters and Allied Trades Industry Pension Fund" on Justia Law

A former participant in a Zen Buddhist center’s residential training programs asserted wage-and-hour claims against the center and two of its leaders, arguing he was owed various wages and penalties for work performed during his time in the center’s programs. The center operates multiple facilities, offers residential programs, and generates income from guest activities and commercial events. The plaintiff undertook tasks such as guesthouse cleaning, kitchen work, gardening, and guest cooking, receiving modest stipends and room and board. After leaving the center, he filed his claims, alleging unpaid minimum and overtime wages and other statutory violations.The Labor Commissioner held in favor of the plaintiff and found the center, as well as the two individual leaders, liable for significant amounts. The center and the individuals appealed to the Superior Court of California, County of San Francisco. The trial court denied the plaintiff’s motion to dismiss the individual appeals on the ground that only the center, not the individuals, was required to post an appeal bond. The trial court subsequently granted summary judgment for the defendants, holding that the “ministerial exception” of the First Amendment barred the plaintiff’s wage-and-hour claims due to the religious nature of the organization and the plaintiff’s role as a minister.On appeal, the California Court of Appeal, First Appellate District, Division Two, reversed the summary judgment. The court held that the ministerial exception does not categorically bar wage-and-hour claims by ministers against religious organizations in the absence of evidence that adjudicating the claims would require resolving ecclesiastical questions or interfere with religious autonomy. The court affirmed the trial court’s denial of the motion to dismiss the individual appeals, holding that only the employer (the center) was required to post the statutory undertaking, not the individual leaders. The judgment was thus reversed in part and affirmed in part. View "Ehrenkranz v. S.F. Zen Center" on Justia Law

The plaintiff, who was in his mid-fifties and had decades of restaurant industry experience, was employed by the defendant as a field leader, overseeing several restaurants. He was recognized as a top performer in 2021, with high scores on cleanliness and safety audits. In early 2022, a severe cockroach infestation was reported at one of his assigned restaurants. The infestation was not previously known to him, and he took steps to address it once notified. However, his supervisor observed persistent pest and cleanliness problems at this and other locations within his responsibility. Additionally, site audits found that several of his restaurants failed to meet cleanliness standards within a single week.After these incidents, the plaintiff was terminated for failing to maintain company food safety standards and for not reporting critical breaches promptly. He received termination documentation and final warnings simultaneously. The plaintiff later sued under the New Mexico Human Rights Act, alleging that his termination was due to age discrimination. The defendant removed the case to the United States District Court for the District of New Mexico, which granted summary judgment for the employer, holding that the plaintiff had not shown sufficient evidence that the stated reasons for his firing were a pretext for age discrimination.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court held that the plaintiff did not present enough evidence that the employer’s justification was pretextual. The evidence failed to show that younger employees with comparable problems were treated more favorably or that the employer’s stated reasons were false or inconsistent. The court emphasized that it would not second-guess business decisions absent evidence of discrimination. The Tenth Circuit affirmed the district court’s grant of summary judgment in favor of the employer. View "Sousa v. Chipotle Services" on Justia Law