Justia Labor & Employment Law Opinion Summaries

Olayinka Oye, a director at PricewaterhouseCoopers, applied for long-term disability benefits through her employer's plan, administered by Hartford Life and Accident Insurance Company, due to fibromyalgia. Initially, Hartford denied her claim but later reversed its decision and awarded her benefits. In 2020, Hartford reevaluated her condition and terminated her benefits, concluding she was no longer disabled. Oye filed a lawsuit seeking to reinstate her benefits under the Employee Retirement Income Security Act (ERISA).The United States District Court for the Northern District of Illinois conducted a "paper trial" and found that Oye's fibromyalgia, while limiting, did not render her disabled under the plan. The court noted that consultative reports from Hartford's doctors, which were detailed and tied to Oye's medical records, outweighed the brief and conclusory letters from Oye's treating physicians. Additionally, the court found that Oye's mental health issues contributed significantly to her limitations, disqualifying her from additional benefits under the plan.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, emphasizing that the district court owed no deference to Hartford's prior determination of disability. The appellate court found no clear error in the district court's findings, noting that the district court carefully considered the evidence and provided adequate reasoning for its decision. The court also addressed Oye's contention that the district court should have discussed a 2017 consultative report, concluding that the district court was not obligated to address every piece of evidence and had reasonably focused on more recent reports. The Seventh Circuit affirmed the district court's judgment in favor of Hartford. View "Oye v Hartford Life and Accident Insurance Company" on Justia Law

James Hess filed an employment discrimination lawsuit against Union Pacific Railroad Company, claiming he was unlawfully terminated due to his disability. Union Pacific has a "Fitness-for-Duty" policy requiring employees to disclose certain health conditions. Hess, who began working for Union Pacific in May 2013, was prescribed Xanax for post-traumatic stress disorder in 2015. In 2016, Union Pacific prohibited medications like Xanax, and in January 2017, Hess was removed from service and later disqualified from his job following a fitness-for-duty evaluation.The District Court for the District of Nebraska dismissed Hess's action as untimely, agreeing with Union Pacific that the statute of limitations was not tolled while the Harris class action was pending because Hess was not a member of the certified class. The Harris class action, filed in 2016, alleged that Union Pacific's fitness-for-duty policy discriminated against employees with disabilities. The class was initially defined broadly but was later certified under a narrower definition, excluding Hess. The class was decertified by the Eighth Circuit in March 2020, after which Hess filed an EEOC charge and received a right-to-sue letter.The United States Court of Appeals for the Eighth Circuit reviewed the case. Citing its recent decision in DeGeer v. Union Pacific Railroad Co., the court held that Hess was entitled to American Pipe tolling because he was not unambiguously excluded from the certified class. Therefore, the statute of limitations was tolled until the class was decertified. The Eighth Circuit reversed the district court's dismissal and remanded the case for further proceedings, concluding that Hess's lawsuit was timely filed. View "Hess v. Union Pacific Railroad Co." on Justia Law

Robert L. Palmer, a long-time employee of Union Pacific, alleged that the company discriminated against him due to his disability, diabetes, which led to diabetic retinopathy. After undergoing surgery for his right eye in 2011, Palmer continued working until November 2013, when his left eye developed blurred vision. Union Pacific then initiated a fitness-for-duty evaluation, resulting in a February 2014 letter from Dr. Holland, the Chief Medical Officer, imposing permanent work restrictions on Palmer. Despite submitting medical information from his eye doctor in May 2014, which cleared him for work, Palmer received a December 2014 letter reaffirming the permanent restrictions and stating that no further medical information would be considered.Palmer was part of a putative class action (Harris class) filed in February 2016, which alleged that Union Pacific's fitness-for-duty policy discriminated against employees with disabilities. The class was certified in February 2019 but decertified in March 2020. Palmer then filed an individual charge of discrimination with the EEOC in April 2020 and subsequently filed this action under the ADA, claiming his suit was timely due to tolling during the class action.The United States District Court for the District of Nebraska dismissed Palmer's claims as time-barred, concluding that the only adverse employment action occurred in February 2014, outside the class definition period. Palmer's motion to reconsider or amend was denied, as the court found the December 2014 letter was not a separate adverse action but a consequence of the February 2014 action.The United States Court of Appeals for the Eighth Circuit reviewed the case and found that the district court relied on an outdated standard for adverse employment actions. Under the new standard from Muldrow v. City of St. Louis, Palmer's allegations that the December 2014 letter caused him harm by denying future review opportunities were sufficient to constitute an adverse employment action. The appellate court reversed the district court's denial of reconsideration and leave to amend, remanding for further proceedings. View "Palmer v. Union Pacific Railroad Co." on Justia Law

Michael Satink, an employee of the City of Lakewood's Department of Public Works, was terminated for alleged insubordinate and inappropriate behavior. The union representing Satink, Ohio Council 8, AFSCME, AFL-CIO, filed a grievance, leading to a last-chance agreement (LCA) that reinstated Satink with the condition that any further misconduct would result in immediate termination without recourse to the grievance or arbitration provisions of the collective-bargaining agreement (CBA). Satink was terminated again for workplace misconduct, and the union filed another grievance. The city refused to arbitrate, citing the LCA, prompting the union to seek arbitration through the Cuyahoga County Court of Common Pleas.The common pleas court denied the city's motion to dismiss for lack of subject-matter jurisdiction and granted the union's motion to compel arbitration. The city appealed to the Eighth District Court of Appeals, which reversed the lower court's decision, holding that the State Employment Relations Board (SERB) had exclusive jurisdiction over the matter because the union's claims were dependent on collective-bargaining rights created by R.C. Chapter 4117.The Supreme Court of Ohio reviewed the case and held that the union's claims did not allege an unfair labor practice or conduct constituting an unfair labor practice under R.C. 4117.11. Therefore, SERB did not have exclusive jurisdiction. The court emphasized that the right to arbitrate is a contractual right derived from the CBA, independent of R.C. Chapter 4117. The court also noted that R.C. 4117.09(B)(1) allows a party to bring a suit for a violation of a collective-bargaining agreement in a court of common pleas. Consequently, the Supreme Court of Ohio reversed the Eighth District's judgment and remanded the case for further proceedings. View "Ohio Council 8, AFSCME, AFL-CIO v. Lakewood" on Justia Law

The case involves a workplace accident where the decedent sustained severe head injuries, resulting in a persistent vegetative state and eventual death. The decedent's workers' compensation claim was allowed for several conditions, and he sought scheduled-loss compensation for the loss of use of his bilateral upper and lower extremities. The Industrial Commission of Ohio initially denied this claim, concluding that the loss of use was due to brain injury, not direct injury to the extremities.The decedent filed a mandamus action challenging the denial, but it was dismissed after his death. Subsequently, his surviving spouse, Byk, filed a motion with the commission for scheduled-loss compensation under R.C. 4123.57(B) and 4123.60. The commission denied this motion, stating that the decedent's entitlement to the loss-of-use award had already been determined and denied.Byk then filed a mandamus action in the Tenth District Court of Appeals, which granted a limited writ directing the commission to vacate its order and issue a new order adjudicating the merits of Byk’s claim. The commission and Republic Steel appealed this decision.The Supreme Court of Ohio reviewed the case and reversed the Tenth District's judgment. The court held that Byk was not entitled to scheduled-loss compensation under R.C. 4123.60 because the decedent was not "lawfully entitled to have applied" a second time for the same scheduled-loss compensation that had already been denied. The court emphasized that the statutory language did not authorize an injured worker to reapply for the same compensation after a final denial. Consequently, Byk's request for a writ of mandamus was denied. View "State ex rel. Byk v. Indus. Comm." on Justia Law

Deborah Hemstead filed a workers' compensation claim against her employer, United Indian Health Services, Inc. (United Indian). United Indian argued that it was entitled to tribal sovereign immunity and thus not subject to the state workers' compensation system. The administrative law judge (ALJ) rejected this claim, applying the five-factor "arm of the tribe" test from People v. Miami Nation Enterprises, and found that United Indian did not qualify for sovereign immunity. The ALJ's decision was based on factors such as United Indian's creation under state law, lack of explicit tribal intent to share immunity, and the financial relationship between United Indian and the tribes.The Workers' Compensation Appeals Board (Board) denied United Indian's request for reconsideration, adopting the ALJ's findings. The Board found no abuse of discretion in the ALJ's rejection of United Indian's claim of sovereign immunity.The California Court of Appeal, First Appellate District, Division Five, reviewed the case de novo. The court concluded that the Board and ALJ erred in denying sovereign immunity to United Indian. The court found that United Indian's method of creation, purpose, tribal control, and financial relationship with the tribes all weighed in favor of granting sovereign immunity. The court noted that United Indian was created by several tribes to provide healthcare services under the Indian Self-Determination and Education Assistance Act, which promotes tribal self-governance and self-sufficiency. The court held that United Indian is entitled to sovereign immunity and reversed the Board's decision, remanding the matter for further proceedings consistent with this opinion. View "United Indian Health etc. v. Workers' Comp. Appeals Bd." on Justia Law

Plaintiff, Ann Gima, was employed by the City and County of Honolulu's Department of Budget and Fiscal Services (BFS) for over twenty years. After being promoted to Real Property Technical Officer (RPTO) in 2012, Gima alleged that her supervisor, Robert Magota, began verbally harassing her, leading to her diagnosis of major depressive disorder and anxiety disorder. Gima was placed on workers' compensation leave intermittently from 2014 to 2018. In November 2017, she requested a reasonable accommodation to work under a different supervisor, which was denied. Magota retired in December 2017, and Gima returned to work in February 2018 under a new supervisor, Steven Takara. Shortly after, she received a substandard performance evaluation and was demoted.Gima filed claims with the Hawai‘i Civil Rights Commission (HCRC) for disability discrimination and retaliation and subsequently filed a lawsuit in the Circuit Court of the First Circuit. The circuit court granted summary judgment in favor of the City, concluding that Gima failed to establish a prima facie case of disability discrimination or retaliation and that her request for an alternate supervisor was unreasonable as a matter of law.The Supreme Court of the State of Hawai‘i reviewed the case. The court held that Gima established a prima facie case of disability discrimination, as she demonstrated she had a disability, was qualified for her position, and was demoted because of her disability. The court found a genuine issue of material fact regarding whether the City’s reasons for her negative evaluation and demotion were pretextual. The court also held that Gima’s request for an alternate supervisor was not unreasonable as a matter of law and that there was a genuine issue of material fact as to whether the City could have assigned her a different supervisor.However, the court concluded that the City engaged in an interactive process to accommodate Gima by offering her a position in another department, which she declined after Magota retired. The court also found that Gima established a prima facie case of retaliation, as she engaged in protected activities, suffered adverse employment actions, and demonstrated a causal connection between the two. The court affirmed in part and vacated in part the circuit court’s order, remanding the case for further proceedings. View "Gima v. City and County of Honolulu" on Justia Law

Employees of United Airlines, including pilots, flight attendants, and other staff, challenged the company's COVID-19 vaccination mandate and masking requirement issued in 2021. United required employees to either get vaccinated or apply for religious or medical exemptions by specific deadlines. Plaintiffs alleged that despite submitting or attempting to submit exemption requests, they were either fired, placed on unpaid leave, or subjected to a hostile work environment.The United States District Court for the Northern District of Illinois dismissed the plaintiffs' claims with prejudice, finding that they had not stated any viable claim for relief despite having sufficient opportunities to do so. The court addressed each of the plaintiffs' twelve claims, noting that many were forfeited due to the plaintiffs' failure to respond to substantive arguments. The court also found deficiencies in the proposed amended complaints and ultimately dismissed the action with prejudice after determining that further amendments would be futile.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that the plaintiffs' claims were either improperly preserved or inadequately pled. The court found that the plaintiffs had forfeited their FDCA, invasion of privacy, and negligence claims by failing to address the district court's findings of forfeiture. The court also upheld the dismissal of the Illinois Whistleblower Act claim, as the plaintiffs did not show how receiving a COVID-19 vaccine would violate federal regulations. Additionally, the court affirmed the dismissal of the Title VII claims due to the plaintiffs' failure to obtain right-to-sue letters from the EEOC, which is a prerequisite for such lawsuits. The appellate court concluded that the district court did not err in denying further opportunities to amend the complaint. View "Anderson v. United Airlines" on Justia Law

Jessica Hines, a dancer, sued National Entertainment Group, LLC (NEG), an adult entertainment club, for failing to properly compensate its employees under various federal and state laws, including the Fair Labor Standards Act and Ohio wage laws. Hines had signed three separate Lease Agreement Waivers with NEG, each containing an arbitration provision. NEG moved to dismiss the suit or stay the proceedings pending arbitration, arguing that Hines had agreed to arbitrate any disputes.The United States District Court for the Southern District of Ohio denied NEG’s motion to dismiss, finding that Hines had plausibly alleged sufficient facts to support standing. The court also denied NEG’s motion to stay the proceedings pending arbitration, concluding that the arbitration provision was both procedurally and substantively unconscionable, and thus unenforceable.The United States Court of Appeals for the Sixth Circuit reviewed the case and vacated the district court’s denial of NEG’s motion to stay. The appellate court held that the arbitration provision was neither procedurally nor substantively unconscionable. The court found that Hines had reasonable opportunity to understand the plain terms of the arbitration clause, which were not hidden in fine print. The court also determined that the arbitration agreement was supported by adequate consideration and that any inconvenience or potential inconsistency caused by separate actions was not a legitimate basis for overriding the arbitration agreement.The Sixth Circuit remanded the case for the district court to consider the remaining factors under Stout v. J.D. Byrider, which include whether the claims fall within the scope of the arbitration agreement, whether Congress intended the federal claims to be arbitrable, and whether to stay the case pending arbitration if some but not all claims are subject to arbitration. View "Hines v. National Entertainment Group" on Justia Law

Nakul Karkare, a surgeon affiliated with AA Medical, P.C., brought an action against the International Association of Bridge, Structural, Ornamental & Reinforcing Iron Workers Local 580 (the Union) to recover unpaid benefits under section 502(a)(1)(B) of the Employee Retirement Income Security Act of 1974 (ERISA). Karkare, holding a power of attorney for Patient JN, claimed the Union failed to fully reimburse AA Medical for surgical services provided to Patient JN, a beneficiary under the Union’s self-funded insurance plan. The Union reimbursed only $1,095.92 of the $153,579.94 billed by AA Medical.The United States District Court for the Eastern District of New York dismissed the complaint sua sponte, concluding that a power of attorney did not permit Karkare to maintain an ERISA cause of action on behalf of Patient JN, as it was distinct from an assignment of claim. Karkare did not provide proof of a valid assignment but argued that the power of attorney was sufficient. The district court disagreed and dismissed the complaint, later denying Karkare’s motion for reconsideration.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that Karkare lacked standing under Article III of the United States Constitution to bring the action. The court determined that Karkare was suing in his own name and not on behalf of Patient JN, despite holding a power of attorney. The court held that a power of attorney does not confer Article III standing to file suit in the attorney-in-fact’s own name. However, the court remanded the case to the district court to consider whether Patient JN should be permitted to be substituted into the action pursuant to Federal Rule of Civil Procedure 17. The judgment was affirmed in part, vacated in part, and remanded for further proceedings. View "Karkare v. International Ass'n of Bridge, Structural, Ornamental & Reinforcing" on Justia Law