Justia Labor & Employment Law Opinion Summaries

Three former deputies of the Los Angeles County Sheriff’s Department were discharged for alleged misconduct and subsequently appealed their terminations to the Los Angeles County Civil Service Commission. While their appeals were pending, each entered into a settlement agreement with department chiefs that purported to reinstate them to employment. The County of Los Angeles refused to honor these settlements, asserting that they lacked proper approval. The deputies, along with their union, sought enforcement of the settlements through claims for mandamus, breach of contract, promissory estoppel, and declaratory relief, arguing that the department had longstanding authority to settle such appeals without further county approval.The Superior Court of Los Angeles County sustained the county’s demurrers to these claims without leave to amend, finding the settlements void for lack of county counsel approval and insufficient authority for department chiefs to bind the county. On appeal, the California Court of Appeal previously reversed in part, directing the trial court to grant leave to amend so petitioners could specify the legal basis for the department’s alleged authority. Petitioners filed several amended complaints, but the trial court again sustained demurrers, ultimately dismissing the action when petitioners failed to allege adequate legal authority for the chiefs to settle commission appeals on the county’s behalf.The California Court of Appeal, Second Appellate District, Division One, treated petitioners’ arguably untimely appeal as a writ petition under the unusual procedural circumstances. On the merits, the court held that petitioners failed to demonstrate that the sheriff and his subordinates had authority to bind the county to settlements of civil service commission appeals without approval from the Board of Supervisors or authority conferred by law. The court denied the writ petition, upholding dismissal of all claims. View "Assn. for L.A. Deputy Sheriffs v. Super. Ct." on Justia Law

Stephen Parr was employed by Union Pacific Railroad Company beginning in 2015. He was trained to report safety concerns via designated company channels and made numerous complaints from 2018 to 2022. In late 2022, Parr began sending complaints to individuals who were not his direct supervisors, which led to discomfort among certain employees. Management responded by instructing Parr to use only the approved reporting channels. After Parr continued to make complaints, Union Pacific initiated an investigation into his conduct, eventually terminating him for insubordination and discourtesy. Parr appealed his termination to the Public Law Board, which reinstated him without backpay.Parr then filed suit in the United States District Court for the Western District of Missouri, alleging Union Pacific retaliated against him for engaging in protected activity under the Federal Rail Safety Act (FRSA). The case proceeded to trial, and the jury found that Parr did not establish a prima facie case of retaliation. The district court denied Parr’s motion for a new trial, based on alleged errors in the jury instructions.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed Parr’s claims of instructional error. The court held that the district court’s instructions were consistent with Eighth Circuit precedent, specifically regarding the requirement to prove intentional retaliation. The court also upheld the business judgment instruction and the restriction of the relevant time period for protected activity to December 2022 through February 2023, finding both legally accurate and supported by the evidence. The Eighth Circuit concluded that no abuse of discretion occurred in the jury instructions, and affirmed the judgment of the district court. View "Parr v. Union Pacific Railroad Co." on Justia Law

The plaintiff worked for a telecommunications company, first as a contractor and later as an employee. His primary responsibilities involved designing, developing, and documenting the company's interactive voice response (IVR) system, an automated system that routes customer calls. He led projects integrating and updating this system and served as the main point of contact for related IT services. Over time, his workload increased significantly, leading him to work long hours. After unsuccessful attempts to resolve concerns about his workload, he resigned.After his employment ended, the plaintiff sued the company in the United States District Court for the Southern District of Ohio, claiming violations of the Fair Labor Standards Act (FLSA) for unpaid overtime and breach of contract for not being paid $75 per hour for all hours worked. The company argued he was exempt from FLSA overtime requirements as a computer employee and that no valid contract for hourly pay existed. The district court granted summary judgment to the company, finding him exempt under the FLSA's computer employee exemption and concluding no contract existed.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. The appellate court found that the plaintiff’s primary duties involved the design, development, and documentation of the IVR system, meeting the statutory criteria for the computer employee exemption under the FLSA, regardless of his lack of formal computer science education. The court also agreed with the lower court that the offer letter did not constitute a contract and that the subsequent at-will employment relationship did not create enforceable terms for hourly pay beyond forty hours. The Sixth Circuit affirmed the district court’s judgment. View "Bennink v. Cincinnati Bell Tel. Co. LLC" on Justia Law

California enacted a law (Senate Bill 399) that prohibits employers from subjecting, or threatening to subject, employees to adverse employment actions if those employees decline to attend employer-sponsored meetings or communications meant to express the employer’s opinion on political or religious matters. Three industry groups representing California employers sued the state officials responsible for enforcing the law, arguing that it violates their First Amendment rights and is preempted by federal labor law. The Western Growers Association, one of the groups, asserted that its members regularly hold “all-hands” meetings to discuss political issues, and that SB 399 would chill this practice due to the threat of enforcement.The United States District Court for the Eastern District of California found that the industry groups had standing and granted a preliminary injunction, preventing California from enforcing SB 399. The district court concluded that the groups were likely to succeed both on their First Amendment claim and the preemption argument. California appealed, contending that the groups lacked standing for a pre-enforcement challenge and were unlikely to prevail on the merits.The United States Court of Appeals for the Ninth Circuit reviewed the case. It held that the Western Growers Association had associational standing because its members intended to engage in conduct arguably proscribed by SB 399, and faced a credible threat of enforcement. The court determined that SB 399 is subject to First Amendment scrutiny because it targets expressive conduct based on content and speaker. Applying strict scrutiny, the court concluded that California had not identified a compelling interest sufficient to justify the law’s content-based restrictions. The Ninth Circuit therefore affirmed the district court’s preliminary injunction, holding that the industry groups are likely to succeed on their First Amendment claim. The court did not address the preemption claim. View "CALIFORNIA CHAMBER OF COMMERCE V. BONTA" on Justia Law

An Arkansas resident applied to work as a warehouse driver for a chemical company. He received a conditional job offer, which was withdrawn after a third-party testing company reported a positive result for marijuana metabolites. The applicant explained to both the employer and the testing company that he had not used marijuana but had consumed a CBD product for anxiety related to a medical condition. He alleged that, despite notifying the employer of his disability and the possible source of a false positive, the employer did not investigate further or engage in any process to accommodate his disability, nor did the employer respond to his request to return to duty.After the withdrawal of the job offer, the applicant filed a charge of disability discrimination with the Equal Employment Opportunity Commission (EEOC) 266 days later. The EEOC dismissed his charge as untimely and issued a right-to-sue letter. The applicant then filed suit in the United States District Court for the Eastern District of Arkansas, alleging violations of the Americans with Disabilities Act (ADA), race discrimination under Title VII and the Arkansas Civil Rights Act, and a negligence claim against the testing company.The district court dismissed all claims against the testing company, noting the plaintiff conceded the federal statutes did not apply and finding no facts alleged to support racial animus. It declined to exercise supplemental jurisdiction over the remaining state law negligence claim. As to the employer, the court granted judgment on the pleadings, finding the EEOC charge was untimely and the complaint lacked facts showing race discrimination.The United States Court of Appeals for the Eighth Circuit affirmed. It held that the Arkansas 180-day filing deadline applied because the applicant was notified of the job offer withdrawal in Arkansas, making his EEOC charge untimely. The court also found the complaint failed to plausibly allege race discrimination and upheld the district court’s decision not to exercise supplemental jurisdiction over the state law claim. View "Stephens v. Harcros Chemicals" on Justia Law

The plaintiff was formerly employed as the CEO of the defendant company, and entered into a bonus agreement providing for eighteen monthly retention bonus payments. Although the company timely paid the first six installments, it failed to pay the remaining bonuses due to cash flow issues. Eventually, the company paid all outstanding bonus amounts and statutory interest in two lump sums, with both payments occurring before the plaintiff filed suit. The plaintiff then initiated legal action seeking, among other things, liquidated damages and attorneys’ fees under Pennsylvania’s Wage Payment and Collection Law (WPCL), alleging that the company’s late payments entitled him to additional statutory damages.The Bucks County Court of Common Pleas sustained preliminary objections to the breach of contract claim but allowed the WPCL claim. On summary judgment, the trial court denied the company’s motion, granted the plaintiff’s cross-motion, and awarded liquidated damages for a subset of late-paid bonuses, limited by the statute of limitations. The Pennsylvania Superior Court affirmed, holding that the WPCL allowed an employee to pursue liquidated damages for untimely paid wages, even if all owed wages and interest were paid before the suit commenced.The Supreme Court of Pennsylvania, Middle District, reviewed the case to determine whether the WPCL authorizes a cause of action for liquidated damages when all wages and interest have been paid prior to filing suit. The Court held that the WPCL does not allow a standalone claim for liquidated damages unless the employee has unpaid wages at the time the action is commenced. Liquidated damages are additive to a claim for unpaid wages, but cannot be sought solely for untimely payments already rectified. The Court reversed the Superior Court’s decision. View "Aita v. NCB Mgmt. Ser." on Justia Law

A police lieutenant in a city police department sent a series of inappropriate and sexual text messages, including a video depicting bestiality, to two female subordinate officers. After an anonymous letter revealed these acts, the department’s Internal Affairs Bureau investigated and the lieutenant was charged with multiple violations of the department’s disciplinary code, including sexual harassment and failure to supervise. The Police Commissioner ordered his dismissal, but the lieutenant, through the union, challenged this action under the collective bargaining agreement, leading to grievance arbitration.At arbitration, the arbitrator found insufficient evidence to support the sexual harassment charge but determined that the lieutenant had violated other sections of the disciplinary code. The arbitrator imposed a fifty-day suspension and ordered the lieutenant’s reinstatement with back pay, concluding that the city lacked just cause for discharge. The city sought to vacate the award in the Court of Common Pleas of Philadelphia County, arguing that the arbitrator exceeded his authority and that the standard of judicial review should be broadened. The trial court denied the city’s petition, holding it was bound by the narrow certiorari scope of review, which permits courts to review only issues concerning the arbitrator’s jurisdiction, regularity of proceedings, excess of powers, or constitutional rights. The Commonwealth Court affirmed, reiterating that the narrow certiorari standard applied and declining to modify it.The Supreme Court of Pennsylvania, Eastern District, reviewed whether to overturn its prior decisions in Pennsylvania State Police v. Pennsylvania State Troopers’ Ass’n (Betancourt) and Pennsylvania State Police v. Pennsylvania State Troopers’ Ass’n (Smith), which established and declined to expand the narrow certiorari scope of review for grievance arbitration awards under the Policemen and Firemen Collective Bargaining Act (Act 111). The court held that stare decisis required adherence to these precedents, reaffirming that judicial review of Act 111 grievance arbitration awards remains limited to narrow certiorari, and declined to create a public policy exception or adopt broader review standards. The judgment of the Commonwealth Court was affirmed. View "City of Phila. v. FOP, Lodge No. 5" on Justia Law

Hall Trucking, Inc., a company that moves oil rigs, was cited by the Occupational Safety and Health Administration (OSHA) after an employee was fatally struck by a truck during a rig-moving operation. OSHA alleged that Hall Trucking violated the general duty clause under 29 U.S.C. § 654(a)(1), which requires employers to provide a workplace free from recognized hazards. The citation suggested that implementing an internal traffic control plan (ITCP)—including measures such as minimizing interactions between employees and trucks, requiring high-visibility gear, and employee training—was a feasible method to reduce the risk.An Administrative Law Judge (ALJ) of the Occupational Safety & Health Review Commission reviewed the case. The ALJ excluded testimony from Hall Trucking’s expert, finding he lacked specialized knowledge in traffic control and that his opinions amounted to legal conclusions. The ALJ admitted the Secretary’s expert, who had specific experience with ITCPs, and found his testimony reliable. The ALJ concluded that Hall Trucking’s existing safety procedures were inadequate and that an ITCP was a feasible and effective abatement method. Hall Trucking’s arguments regarding the adequacy of its measures, the specificity of abatement steps, and the industry standards were rejected. Additionally, Hall Trucking’s argument that a specific OSHA regulation supplanted the general duty clause was deemed waived because it was not properly raised before the Commission.The United States Court of Appeals for the Eighth Circuit reviewed Hall Trucking’s petition for review. The court held that the ALJ’s factual findings were supported by substantial evidence and that the legal conclusions were not arbitrary, capricious, or contrary to law. The court also found the ALJ’s rulings on expert witness admissibility and reliability were proper. The Eighth Circuit denied Hall Trucking’s petition for review, affirming the Commission’s decision. View "Hall Trucking Inc. v. Secretary of Labor" on Justia Law

Eva Stramaski, an academic advisor at Texas A&M University, was concerned her paycheck might arrive late after returning from medical leave. Despite being paid on time, her supervisor, Mark Lawley, accused her of being “aggressive” about the issue, sent her home, and issued a “coaching letter” citing performance problems. Stramaski disputed these allegations, and Lawley fired her a few days later. She then brought suit against Lawley in his personal capacity under the Fair Labor Standards Act (FLSA), claiming retaliation for asserting her right to timely pay.The United States District Court for the Southern District of Texas first heard the case. Lawley moved to dismiss the suit, arguing sovereign immunity and qualified immunity. A magistrate judge recommended dismissing claims for injunctive and declaratory relief but rejected both immunity defenses, and the district court adopted the recommendations over Lawley’s objections. Lawley appealed. In its first review (Stramaski I), the United States Court of Appeals for the Fifth Circuit held that sovereign immunity did not bar the case against Lawley personally but left open the issue of qualified immunity, remanding for further analysis. On remand, the district court again denied Lawley’s qualified immunity defense, and Lawley appealed a second time.The United States Court of Appeals for the Fifth Circuit, in this second appeal, addressed whether a public official may invoke qualified immunity in an FLSA retaliation suit. The court held that qualified immunity does not apply to such claims. It reasoned that, at the time Congress authorized private FLSA retaliation suits, the common law did not shield officials from malicious retaliation, and the purposes underlying qualified immunity are incompatible with the FLSA’s anti-retaliation protections. The court affirmed the district court’s denial of Lawley’s motion to dismiss. View "Stramaski v. Lawley" on Justia Law

A former police officer alleged that he experienced discrimination while employed by a municipal police department, culminating in his termination. The officer identified as Hispanic due to his Ecuadorian heritage and pointed to comments made by a superior several years prior, which he asserted reflected animus based on his background. Over the course of his employment, the officer was subject to multiple disciplinary actions, including remedial training, negative performance reviews, and investigations for failing to properly search arrestees. He was ultimately terminated after a hearing found repeated rule violations and dishonesty during official proceedings.After his termination, the officer filed a complaint in the United States District Court for the Southern District of New York, asserting, among other claims, discrimination based on national origin under 42 U.S.C. § 1983 and the New York State Human Rights Law. The court granted summary judgment to the defendants, finding that the officer failed to establish a prima facie case of discrimination, as he did not provide evidence that his superiors were aware of his Hispanic background or that the adverse employment actions were motivated by discriminatory intent. The court also determined that the municipality had legitimate, non-discriminatory reasons for the termination and that the officer failed to show pretext.On appeal, the United States Court of Appeals for the Second Circuit reviewed only the discrimination claims under Section 1983 and the NYSHRL regarding the officer’s termination. The appellate court affirmed the district court’s decision, holding that the officer failed to provide non-speculative evidence that the defendants knew of his Hispanic national origin or that his termination was the result of discrimination. The court concluded that the employer’s stated reasons for termination were legitimate and not a pretext for discrimination. View "Barberan v. Town of Eastchester" on Justia Law