Justia Labor & Employment Law Opinion Summaries

Apria Healthcare provides home healthcare products and services, employing delivery drivers through third-party agencies and licensed vocational nurses directly. Travis Smith and Uriel Arauz, both former employees, commenced a class action against Apria in Sutter County Superior Court alleging wage and hour violations on behalf of similarly situated employees. Proposed interveners Angela Tisdale and Terrance Pratt are former delivery drivers and named plaintiffs in a separate, related federal action against Apria for similar wage and hour claims, covering delivery drivers hired after the class certification date in another Los Angeles County action.The Sutter County Superior Court preliminarily approved a settlement in the Smith action, which conditionally certified a class and found the settlement fair. Tisdale and Pratt, concerned about a collusive “reverse auction” settlement that might undermine the rights of putative class members in their federal action, filed an ex parte application to intervene in the Smith action after the court’s preliminary approval and class notice. Their application was supported by evidence of their early awareness and concern over the settlement process, but was filed several months after those concerns were first raised.The Court of Appeal of the State of California, Third Appellate District, reviewed the trial court’s denial of the intervention application. The appellate court held that Tisdale and Pratt’s application was untimely, noting that they knew or should have known of risks to their interests well before filing, and their delay prejudiced the settlement process and the original parties. The court affirmed the trial court’s order denying intervention, concluding that the untimeliness of the application defeated both mandatory and permissive intervention. Respondents were awarded costs on appeal. View "Smith v. Apria Healthcare" on Justia Law

A group of nine tenured professors at a public Kansas university were terminated after the Kansas Board of Regents (KBOR) temporarily amended its policy, citing COVID-19-related financial pressures. The amendment permitted universities to suspend or terminate tenured faculty without the usual protections, including hearings or proof of financial exigency. ESU administrators drafted a framework for implementing these terminations, which KBOR approved. The professors received termination letters referencing general financial concerns, but allegedly lacking specific reasons. The professors claimed ESU was not facing financial exigency, and that their terminations were motivated by their political activities and beliefs. All nine appealed through the Office of Administrative Hearings (OAH); six had their terminations reversed and three had them affirmed. Litigation ensued, with the professors asserting constitutional violations under 42 U.S.C. § 1983, including due process, liberty, association, and equal protection claims.The United States District Court for the District of Kansas denied the defendants’ motion to dismiss most claims, finding that qualified immunity did not bar them. It ruled the professors had adequately alleged deprivation of a property interest in continued employment without due process and allowed other constitutional claims to proceed. The court dismissed liberty interest claims against KBOR and some administrators where no statements were attributed to them, but denied dismissal for others allegedly involved in drafting termination letters.The United States Court of Appeals for the Tenth Circuit reviewed the appeal at the motion-to-dismiss stage, adopting facts as alleged. It held that the professors had a state-created property interest in tenure and that the process used to terminate their employment plausibly violated clearly established procedural due process rights. The court affirmed denial of dismissal for procedural due process and related conspiracy claims, but reversed as to substantive due process claims, finding no clearly established violation. It also reversed denial of dismissal for liberty, association, equal protection, and conspiracy claims against KBOR and certain administrators, instructing the district court to dismiss those claims, while leaving claims against the university president intact. View "Miracle v. Hush" on Justia Law

A Colorado-based retailer employed a sales associate who, after contracting a severe illness in March 2020 (suspected COVID-19), experienced ongoing and worsening symptoms including gastrointestinal pain, weakness, difficulty breathing, and intermittent inability to speak. She initially received twelve weeks of leave under the Family and Medical Leave Act (FMLA), which was set to expire in June 2020. Before her leave expired, the employee communicated with the company’s human resources specialist about her persistent symptoms and medical procedures, including a scheduled endoscopy. She requested an extension of leave, explaining she needed more time to recover and receive results from her medical tests. The retailer declined to grant additional leave and terminated her employment shortly after the FMLA leave expired.After the termination, the employee filed a discrimination charge with the Equal Employment Opportunity Commission (EEOC), which investigated and brought suit against the retailer in the United States District Court for the District of Colorado. The retailer moved for summary judgment, arguing the EEOC had not established the employee had a qualifying disability, had not provided sufficient notice of her disability and limitations, and had requested an unreasonable, indefinite leave. The district court granted summary judgment for the retailer on all claims, finding the employee had not put the company on notice of her disability and her request for an indefinite leave was not a reasonable accommodation.On appeal, the United States Court of Appeals for the Tenth Circuit reversed the district court’s summary judgment. The Tenth Circuit held that a reasonable jury could find the employee provided sufficient notice of her disabling condition and that her request for a few weeks of additional leave constituted a plausibly reasonable accommodation under the Americans with Disabilities Act. The court remanded for further proceedings. View "EEOC v. A & A Appliance" on Justia Law

The appellant worked as a maintenance worker and suffered a work-related back injury in March 2022. He ceased working, reported the injury, and began receiving medical treatment, including physical therapy and medication. The Wyoming Workers’ Compensation Division recognized his injury as compensable and awarded him temporary total disability (TTD) benefits. Over the following year, the appellant continued to experience back pain, but his doctor noted improvements, and by March 2023, multiple medical professionals—his treating physician and two independent medical examiners—agreed he had reached maximum medical improvement (MMI). Based on these findings, the Division terminated his TTD benefits and awarded him permanent partial impairment (PPI) benefits.The appellant contested the Division’s determination, arguing he had not yet reached MMI and that the TTD benefits should not have been terminated. He did not present additional medical evidence to support his claim but relied on his own testimony. The Medical Commission held a contested case hearing and found, based on the medical evidence, that he had reached MMI as of March 2023. Consequently, the Medical Commission upheld the Division’s termination of TTD benefits. The appellant appealed to the District Court of Laramie County, which affirmed the Medical Commission’s decision.On further appeal, the Supreme Court of Wyoming reviewed the case as if it had come directly from the Medical Commission, without deference to the district court’s decision. The Supreme Court held that substantial evidence supported the Medical Commission’s finding that the appellant had achieved MMI as of March 2023. Therefore, the termination of TTD benefits was proper under Wyoming law, and the Supreme Court affirmed the Medical Commission’s and district court’s decisions. View "Martinez v. State of Wyoming" on Justia Law

A marketing and communications specialist employed by a state university alleged that she was subjected to sex-based discrimination, was paid less than a male counterpart for equivalent work, and experienced a hostile work environment. After raising concerns about this treatment, she alleged the university retaliated against her, culminating in her termination. She further claimed that, following her dismissal, the university provided false information to the state workforce agency, which delayed her receipt of unemployment benefits.After being terminated, the employee filed a pro se complaint in the District Court of Albany County, Wyoming, asserting claims for retaliation, sex-based discrimination, hostile work environment, fraud, and intentional infliction of emotional distress, and sought both monetary and injunctive relief. The university removed the case to U.S. District Court on federal question grounds, but after the employee amended her complaint to assert only state-law claims, the federal court remanded the case to the state district court. The university then moved to dismiss, arguing governmental immunity, failure to exhaust administrative remedies, and failure to state a claim. The district court granted the motion, dismissing the case without prejudice because the employee had not exhausted her administrative remedies under the Wyoming Fair Employment Practices Act (WFEPA).The Supreme Court of Wyoming reviewed the dismissal de novo. It held that the Wyoming Governmental Claims Act barred the employee’s tort claims for monetary damages, including for fraud, intentional infliction of emotional distress, and wrongful termination in violation of public policy, but did not bar claims for injunctive relief. However, the court further determined that the wrongful termination and discrimination claims were not cognizable because the WFEPA provides an adequate statutory remedy, which requires exhaustion of administrative remedies before seeking judicial review. Because the employee had not followed the required administrative process, the court affirmed the district court’s dismissal of her complaint. View "Hinckley v. University of Wyoming" on Justia Law

The plaintiff worked remotely as a Senior Data Architect for a health savings account provider beginning in May 2023. She identified security vulnerabilities in a company database and reported these issues to her supervisor, who dismissed her concerns and instructed her to drop the matter. The plaintiff continued to raise these issues with other employees. She also alleged that a project manager made gendered remarks toward her and that other male colleagues used similar language. Over the course of her employment, she was placed on two performance improvement plans (PIPs), received a lower-than-expected bonus, and was eventually excluded from meetings. In April 2024, believing she was being set up for failure and anticipating potential legal claims, she forwarded company documents to her personal email. The company discovered this, placed her on administrative leave, and terminated her for violating internal policy.The plaintiff filed suit in Massachusetts state court, alleging sex discrimination, retaliation, wrongful termination in violation of public policy, and interference with future employment under Title VII and Massachusetts law. The defendant removed the case to the United States District Court for the District of Massachusetts. The district court dismissed her complaint for failure to state a claim, holding that her allegations did not plausibly show discrimination or retaliation, nor did they identify a well-defined public policy that protected her internal reporting of HIPAA concerns. The plaintiff appealed, abandoning her interference claim.The United States Court of Appeals for the First Circuit reviewed the dismissal de novo and affirmed. The court held that the plaintiff failed to allege sufficient facts to plausibly support claims of sex discrimination or retaliation, as she did not connect the adverse actions to discriminatory motive or show that the employer knew she was engaging in protected conduct. The court also found her wrongful termination claim insufficient, as Massachusetts law does not protect employees from termination for raising general compliance concerns. Accordingly, the First Circuit affirmed the district court’s dismissal. View "Grygiel v. HealthEquity, Inc." on Justia Law

In this case, Indiana enacted legislation in 2021 that imposed new requirements on public school teachers who wished to have union dues automatically deducted from their paychecks. These requirements included submitting a written authorization containing a specific statement regarding their First Amendment rights, annual renewal of the authorization, confirmation via official work email, and annual notice of their right to resign from the union. These procedures applied only to teachers and not to other public employees in Indiana.Previously, the United States District Court for the Southern District of Indiana reviewed the case after teachers’ unions and individual members challenged the law, arguing it violated their First Amendment rights to free speech and association. The district court initially found that the mandated statement on the authorization form constituted compelled speech and issued a preliminary injunction. After Indiana amended the statute in response, the district court concluded that the revised law no longer violated the Free Speech Clause, but still found that the additional requirements on teachers constituted viewpoint discrimination against their freedom of association. The court permanently enjoined enforcement of the provisions and the State appealed.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s judgment. The Seventh Circuit held that the authorization form’s required statement was government speech, not compelled private speech, and did not violate the Free Speech Clause. However, the court agreed with the district court that the additional requirements imposed only on teachers and their unions amounted to unconstitutional viewpoint discrimination under the First Amendment’s Freedom of Association protections. The court applied strict scrutiny and found Indiana’s justifications insufficient. As a result, the Seventh Circuit affirmed the district court’s judgment permanently enjoining enforcement of the challenged provisions. View "Anderson Federation of Teachers v. Rokita" on Justia Law

A union representing state employees challenged a new workplace policy implemented by the State of Vermont. After years of allowing certain employees to request telework arrangements under a bargained-for policy that gave agency “appointing authorities” broad discretion to approve or terminate such arrangements, the State adopted a new “Hybrid Work Standard.” This new standard, announced in 2025, required all executive branch employees to be physically present in the office for at least three days per week, rescinded all prior telework agreements, and established a process for exceptions only for “compelling reasons.” The union alleged that this new standard unilaterally changed an existing condition of employment without negotiation, amounting to an unfair labor practice.The Vermont Labor Relations Board considered the union’s unfair labor practice charge. It found that the new Hybrid Work Standard materially changed the terms of the Telework Policy by removing discretion from individual agency heads and imposing a uniform, statewide minimum in-office requirement. The Board concluded that the Governor’s unilateral action, rather than action by appointing authorities, was not permitted under the Telework Policy. The Board ordered the State to rescind the Hybrid Work Standard, return to the prior telework practices, and reinstate any affected employees.The Supreme Court of Vermont reviewed the case. It held that the plain language of the Telework Policy gave the State, as employer, broad discretion to approve, deny, or terminate telework arrangements and did not limit that discretion to appointing authorities as distinct from the Governor. The Court concluded that the Hybrid Work Standard was a permissible exercise of the State’s management authority under the existing policy and did not constitute an unlawful unilateral change. Accordingly, the Supreme Court of Vermont reversed the Board’s decision. View "Vermont State Employees' Association v. State of Vermont" on Justia Law

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