Justia Labor & Employment Law Opinion Summaries

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In this case, Plaintiff Jennifer Akridge, a former employee of Alfa Mutual Insurance Company, appealed the entry of summary judgment in favor of Alfa on her claim under the Americans with Disabilities Act (ADA). Akridge had multiple sclerosis and severe migraines, and she alleged that the company wrongfully terminated her to avoid paying for her healthcare costs. Alfa argued that it eliminated her position because her duties were automated and no longer needed, and the company wanted to cut business expenses.The United States Court of Appeals for the Eleventh Circuit affirmed the summary judgment ruling. The court found that Akridge failed to establish a prima facie case of disability discrimination under the ADA. Even if she had, her evidence failed to show that Alfa’s reason for firing her (that her position was no longer needed and it wished to cut business expenses) was pretext for disability discrimination. The court also rejected Akridge's argument that she merely needs to show that her disability was a motivating factor, rather than a but-for cause, of her termination. The court clarified that, unlike Title VII, the ADA does not incorporate the motivating-factor causation standard, and an ADA plaintiff must show that a cause was outcome determinative. Therefore, it upheld the district court’s decision that Akridge did not produce sufficient evidence to suggest that her termination was a result of discrimination based on her disability.The court also affirmed the district court's award of $1,918 in discovery sanctions against Akridge. The lower court found that Akridge's motion to compel a certain deposition was not substantially justified, and the appeals court found no error or abuse of discretion in that ruling. View "Akridge v. Alfa Mutual Insurance Co." on Justia Law

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The case involves plaintiff Angelo Riccitelli and defendant Town of North Providence, through its Finance Director, Maria Vallee. Riccitelli, a retired firefighter, filed a complaint against the town, alleging that it failed to pay him the full amount required by a collective bargaining agreement. The agreement required the town to provide Riccitelli with a "supplemental pension payment" equal to the difference between his pension and the "monthly net pay" that he received at retirement, less any pension deductions. The dispute centered around the interpretation of the term "monthly net pay."The Supreme Court of Rhode Island found that the Superior Court erred in granting summary judgment in favor of Riccitelli because the collective bargaining agreement was not in the record. The court emphasized that the entire contract must be reviewed to determine whether a provision is clear and unambiguous. Without the agreement in the record, Riccitelli failed to carry his initial burden as the party moving for summary judgment, leaving open a critical question of fact—the content of the collective bargaining agreement. The court vacated the judgment of the Superior Court and returned the record to the Superior Court for further proceedings. View "Riccitelli v. The Town of North Providence" on Justia Law

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The case involves American Medical Response of Connecticut (AMR), a company that operates ambulances and employs emergency medical technicians and paramedics, and the International Association of EMTs and Paramedics (Union). The Union and AMR had a collective bargaining agreement that was in effect from 2019 through 2021. During the COVID-19 pandemic, AMR invoked an emergency provision in the agreement and cut shifts due to reduced demand. The Union raised concerns about AMR's actions and requested specific information from AMR to investigate potential grievances. AMR refused to provide some of the requested information, arguing that the emergency provision in the agreement excused it from providing the information during the pandemic. The Union filed a charge with the National Labor Relations Board (NLRB), alleging that AMR's refusal to provide the information violated the duty to bargain under the National Labor Relations Act (NLRA). The NLRB sided with the Union, and AMR sought review of this decision.The United States Court of Appeals for the District of Columbia Circuit disagreed with the NLRB's decision. The court held that the NLRB was required to determine whether the collective bargaining agreement relieved AMR of the duty to provide the requested information. The court explained that the NLRA requires the enforcement of collective bargaining agreements, including those provisions that limit a union's information rights. The court expressed that the NLRB had put the cart before the horse by concluding that AMR failed to provide information before determining whether AMR had a contractual duty to provide such information. As a result, the court granted AMR’s petition for review, denied the NLRB's cross-application for enforcement, vacated the NLRB's order, and remanded the case back to the NLRB for it to consider whether the collective bargaining agreement excused AMR from providing the requested information. View "American Medical Response of Connecticut, Inc. v. NLRB" on Justia Law

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The United States Court of Appeals for the Fifth Circuit affirmed the decision of the United States District Court for the Northern District of Texas, which dismissed a False Claims Act (FCA) retaliation lawsuit brought by former employee Dana Johnson against his former employer, Raytheon Co.Johnson alleged that Raytheon retaliated against him for reporting fraudulent misrepresentations that the company made to the US Navy. However, the Court of Appeals ruled that the District Court correctly held that it lacked jurisdiction to review Johnson’s claims implicating the merits of the decision to revoke his security clearance, based on the Supreme Court’s ruling in Department of the Navy v. Egan. The court also affirmed that Johnson failed to present a prima facie case of retaliation for the remaining claim, which involved Johnson being instructed not to report problems to the Navy. The court found that such instructions by Raytheon would not have dissuaded a reasonable worker from reporting to the Navy and therefore did not constitute retaliation.The case centered around Johnson's work for Raytheon, a government defense contractor, on a Navy project which required top-secret security clearance. Johnson claimed that after he reported concerns to managers and supervisors about Raytheon making fraudulent misrepresentation to the Navy, Raytheon began to monitor him, made false accusations about him to the Navy, and ultimately fired him. The Navy found that Johnson had committed security violations, and his security clearance was revoked. Raytheon subsequently terminated Johnson's employment. Johnson filed a lawsuit claiming retaliation, which the District Court dismissed and the Court of Appeals affirmed. View "Johnson v. Raytheon" on Justia Law

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In this case, the United States Court of Appeals for the Sixth Circuit was faced with the claims of Cameron Cooper, an employee with Tourette Syndrome, who sued his former employer, Coca-Cola Consolidated, Inc. (CCCI), under the Americans with Disabilities Act (ADA). Cooper's Tourette Syndrome caused him to involuntarily utter racist and profane words. He alleged that CCCI failed to provide him with reasonable accommodations and constructively discharged him by forcing him into an undesirable position.Cooper had been working as a delivery merchandiser for CCCI, a role which required excellent customer service. However, his condition led to complaints from customers due to his use of offensive language. CCCI attempted various accommodations, including having Cooper work alongside another employee and ultimately transferring him to a warehouse position with no customer contact. Cooper claimed that CCCI could have accommodated him by assigning him to a non-customer-facing delivery route.The court held that providing excellent customer service was an essential function of Cooper's job and, given his condition, he could not perform this function without an accommodation. The court further held that Cooper's proposed accommodation (assigning him to a non-customer-facing delivery route) was not objectively reasonable because the suggested delivery route did involve customer contact and there were no other non-customer-facing routes available at the time. Additionally, the court found that the warehouse position offered by CCCI was a reasonable accommodation under the ADA.As to the constructive discharge claim, the court held that Cooper failed to show that CCCI deliberately created intolerable working conditions with the intention of forcing him to quit. The court concluded that CCCI provided Cooper with reasonable accommodations each time he requested, thus, there was no evidence to support a constructive discharge claim.The court affirmed the lower court's decision to grant summary judgment in favor of CCCI. View "Cooper v. Dolgencorp, LLC" on Justia Law

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In the case before the United States Court of Appeals for the Eleventh Circuit, the plaintiff, Taquila Monroe, was a former employee of Fort Valley State University's Head Start and Early Head Start department. She sued the Board of Regents of the University System of Georgia (the "Board") under the False Claims Act's (FCA) anti-retaliation provision, alleging that she was terminated for reporting mismanagement and misuse of federal and state funds meant for the Head Start programs. The district court granted the Board's motion to dismiss, citing the Board's sovereign immunity. The central issue on appeal was whether the FCA's anti-retaliation provision abrogates sovereign immunity for lawsuits against states, and whether the Board is an arm of the state entitled to the same immunity.The Eleventh Circuit affirmed the district court's decision. The court concluded that Congress did not unequivocally express its intent to subject states to suits under the FCA's anti-retaliation provision, and therefore did not abrogate sovereign immunity. The court also held that the Board is an arm of the state and thus entitled to sovereign immunity. In reaching these conclusions, the court considered how Georgia law defines the Board, the degree of control the state exercises over the Board, the Board's source of funding, and who would be responsible for a judgment against the Board. The court found that all of these factors pointed to the Board being an arm of the state that is entitled to sovereign immunity. View "Monroe v. Board of Regents of the University System of Georgia" on Justia Law

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The Supreme Court of Ohio affirmed the decision of the lower court, granting a writ of mandamus to Cassens Corp., a self-insuring employer, against the Industrial Commission of Ohio. The case involved an employee, Luis Ybarra, who was injured on the job when he was struck by a vehicle driven by a coworker who had failed to clear the snow and ice from the windshield. The Commission had found that Cassens Corp. violated a specific safety requirement (VSSR) and granted an application for an additional workers' compensation award. Cassens Corp. sought a writ of mandamus to compel the Commission to vacate its order. The Supreme Court of Ohio held that the Commission erred in finding that the outdoor yard where Ybarra was injured constituted a "workshop" under the applicable administrative code. Therefore, the company could not have committed a VSSR under the code. As a result, Cassens Corp. was entitled to a writ of mandamus ordering the Commission to vacate its decision and refund all additional compensation paid by Cassens Corp. in accordance with the Commission's order. View "State ex rel. Cassens Corp. v. Indus. Comm." on Justia Law

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Shawn Fowler, a former Montana state trooper, sued the Department of Justice, Montana Highway Patrol (MHP) alleging constructive discharge in violation of the Wrongful Discharge from Employment Act (WDEA). He also alleged breach of contract by the Montana Public Employees Association (MPEA) for declining his request to arbitrate. Fowler claimed that he was forced to retire due to a hostile work environment, which was mainly due to disciplinary action taken against him for mishandling two suspected DUI traffic stops in 2017. The MHP argued that Fowler, who was covered by a collective bargaining agreement (CBA), failed to exhaust the grievance procedures of the CBA before filing a lawsuit.The Supreme Court of the State of Montana reversed the judgment of the Sixth Judicial District Court, Park County. The Supreme Court held that an employee covered by a CBA can't bring a claim under the WDEA. The Court determined that Fowler’s alleged constructive discharge was covered by the CBA and he was required to exhaust the grievance procedures for a constructive discharge through the CBA. The Court found that Fowler did not grieve any of the events preceding his suspension, which he claimed contributed to his constructive discharge, and he resigned from employment prior to exhausting the grievance procedure of the CBA. The Court concluded that the District Court erred in denying the State’s two motions for summary judgment and reversed the judgment. View "Fowler v. Department of Justice" on Justia Law

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In this putative class action lawsuit, Maria Johnson, a former employee of Lowe's Home Centers, LLC, brought claims on behalf of herself and other Lowe's employees under California's Private Attorneys General Act of 2004 (PAGA) for alleged violations of the California Labor Code. Johnson had signed a pre-dispute employment contract that included an arbitration clause.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision to compel arbitration of Johnson's individual PAGA claim, as a valid arbitration agreement existed and the dispute fell within its scope. However, the district court's dismissal of Johnson's non-individual PAGA claims was vacated. The lower court had based its decision on the U.S. Supreme Court's interpretation of PAGA in Viking River Cruises, Inc. v. Moriana, which was subsequently corrected by the California Supreme Court in Adolph v. Uber Techs., Inc. The state court held that a PAGA plaintiff could arbitrate their individual PAGA claim while also maintaining their non-individual PAGA claims in court. The case was remanded to the district court to apply this interpretation of California law. The Ninth Circuit rejected Lowe's argument that Adolph was inconsistent with Viking River. View "JOHNSON V. LOWE'S HOME CENTERS, LLC" on Justia Law

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The case involves Albert Collins, who was employed by the Kansas City Missouri Public School District. After the termination of his employment, Collins sued the school district, alleging racial discrimination and retaliation for participating in protected activities. The school district had fired Collins following an investigation into "attendance fraud," a scheme in which Collins admittedly took part. The three claims relevant in this case were racial discrimination during termination in violation of Title VII and 42 U.S.C. § 1983, retaliation for engaging in protected activities under Title VII and § 1983, and violation of a state law prohibiting public employers from retaliating against whistleblowers.The United States Court of Appeals for the Eighth Circuit affirmed the lower court's decision to grant summary judgment in favor of the school district. The court held that Collins failed to provide sufficient evidence for a reasonable jury to conclude that his termination was motivated by his race. He failed to demonstrate that a white employee engaged in the same fraudulent scheme was treated differently, failing to meet the "rigorous" requirement that the comparators must have dealt with the same supervisor, been subject to the same standards, and engaged in the same conduct.The court also found that Collins' retaliation claim failed for lack of evidence linking his termination to any protected conduct. His interviews about the attendance fraud scheme were not related to race, and he failed to demonstrate that another employee's claims, in which he acted as a witness, had anything to do with racial discrimination or retaliation.Regarding the whistleblower claim, the court held that a Missouri law excluding disclosures related to the employee's own violations applied to Collins. Since he failed to argue against the court's application of the statutory exclusion, his challenge to the court's grant of summary judgment on his whistleblower claim was deemed waived. View "Collins v. K.C. MO Public School District" on Justia Law