Justia Labor & Employment Law Opinion Summaries

A school principal used the school's printer after hours to create a coaster as a retirement gift for a friend. The coaster design contained the School District's official logo but altered the District's motto in a disrespectful manner. A custodian took pictures of the coaster, which were shared on social media, leading to public outrage. The principal left the community the next day. The District proposed to terminate him for incompetence and violating anti-harassment policies. After a brief pretermination hearing, the District terminated the principal. The principal appealed, and the Board upheld the termination following an additional hearing.The principal then appealed to the superior court, which also affirmed his termination. The court found that the District had grounds to terminate the principal due to substantial noncompliance with District rules and regulations and that the community's reaction to the coaster was reasonable. The court also rejected the principal's free speech arguments, stating that his speech was not protected under the First Amendment. The court acknowledged that the pretermination hearing process was flawed but deemed the error harmless due to the subsequent post-termination hearing.The Supreme Court of the State of Alaska reviewed the case. The court held that the Board had a reasonable basis to terminate the principal for incompetency under AS 14.20.170(a)(1) due to his inability to perform his duties effectively after the incident. The court also concluded that the principal's termination did not violate his free speech rights under AS 14.20.095 or the First Amendment. However, the court found that the pretermination hearing process did not provide sufficient due process, as the principal was not informed of his right to call witnesses. The court affirmed the termination but reversed the superior court's decision denying back pay, awarding back pay through the date of the Board's post-termination hearing decision. View "Stirling v. North Slope Borough School District" on Justia Law

Elizabeth Perez, a former employee of Rose Hills Company, filed a class action lawsuit on behalf of herself and similarly situated employees, alleging violations of California wage-and-hour laws. The complaint did not specify the amount in controversy or the frequency of the alleged violations. Rose Hills removed the case to federal court under the Class Action Fairness Act (CAFA), which allows removal if the amount in controversy exceeds $5 million.The United States District Court for the Central District of California remanded the case to state court, stating that Rose Hills did not meet CAFA’s $5 million amount-in-controversy requirement. The district court found that Rose Hills failed to provide evidence justifying its assumed violation rate, which was used to calculate the amount in controversy.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court held that a removing defendant under CAFA is permitted to rely on reasonable assumptions based on the plaintiff’s complaint to calculate the amount in controversy. The court found that Rose Hills’ approach, which included assumptions about the violation rate tethered to the language of the complaint, was reasonable. The district court erred by requiring Rose Hills to provide evidence supporting its assumed violation rate.The Ninth Circuit vacated the district court’s remand order and remanded the case for further proceedings, instructing the district court to evaluate whether Rose Hills’ violation-rate assumption was a reasonable interpretation of the complaint. The court emphasized that assumptions need not be proven with evidence if they are reasonable interpretations of the complaint’s allegations. View "Perez v. Rose Hills Company" on Justia Law

A collective bargaining agreement between the Teamsters Union and Quality Custom Distribution guaranteed that the top 80% of senior employees would receive at least 40 paid hours per week. During the early months of the COVID-19 pandemic, many Starbucks stores in or near Chicago closed or reduced their hours, resulting in senior employees averaging only 30 hours a week. The Union demanded that the employer make up the difference, but the employer refused, citing an exception for Acts of God.The dispute was taken to an arbitrator, who ruled in favor of the Union. The arbitrator determined that while epidemics might be considered Acts of God, the reduction in work was primarily due to the Governor of Illinois' orders, which were not Acts of God. The employer then filed a suit in the United States District Court for the Northern District of Illinois to nullify the arbitrator's decision. The district court judge declined to nullify the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The court held that as long as the arbitrator interprets the contract, the award must stand. The arbitrator had interpreted the contract's "Act of God" clause, concluding it did not cover the Governor's orders. The court emphasized that judicial review of arbitration awards is limited to ensuring the arbitrator interpreted the contract, not whether the interpretation was correct. The court also noted that the employer's conduct in the litigation process imposed unnecessary costs and ordered the employer to show cause why sanctions should not be imposed. View "Quality Custom Distribution Services LLC v International Brotherhood of Teamsters, Local 710" on Justia Law

ExxonMobil Technology and Engineering Company (Exxon) operates a research facility in New Jersey where approximately 165 employees are represented by the Independent Laboratory Employees Union (the Union). The collective bargaining agreement (CBA) between Exxon and the Union expired in May 2018. During negotiations for a new CBA, disputes arose over Exxon’s personal time off (PTO) policies and paid parental leave (PPTO). The Union wanted to restore a policy allowing supervisors to review PTO requests and sought eight weeks of PPTO for its members. Exxon refused to negotiate on these issues, citing concerns over inconsistencies and potential grievances.An administrative law judge (ALJ) found that Exxon violated the National Labor Relations Act by refusing to bargain in good faith on the supervisor PTO review issue, retaliating against the Union for past grievances, and suggesting that employees would receive PPTO if they decertified the Union. The National Labor Relations Board (NLRB) initially reversed the ALJ’s findings in a 2020 decision. However, it was later discovered that a Board member involved in the decision had a conflict of interest, leading the NLRB to vacate the 2020 decision and reconsider the case.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the NLRB did not abuse its discretion in vacating the 2020 decision due to the conflict of interest. The court also upheld the NLRB’s findings that Exxon refused to bargain in good faith on the supervisor PTO review issue and retaliated against the Union for past grievances. Additionally, the court supported the NLRB’s conclusion that Exxon unlawfully suggested employees would receive PPTO if they left the Union. The court denied Exxon’s petition for review and granted the NLRB’s cross-petition for enforcement of its order. View "ExxonMobil v. National Labor Relations Board" on Justia Law

Dr. Susan O'Horo, an interventional radiologist and Director of Quality and Safety at Boston Medical Center Corporation (BMC), alleged that she faced discriminatory and retaliatory actions at her workplace. She claimed that her efforts to report safety concerns, particularly regarding a colleague, Dr. Mikhail Higgins, were met with hostility and that she was ultimately forced to resign due to the intolerable work environment.In the United States District Court for the District of Massachusetts, Dr. O'Horo filed claims under Title VII of the Civil Rights Act of 1964, Massachusetts General Laws Chapter 151B, and the Massachusetts Health Care Whistleblower Act (MHCWA). The defendants, including BMC, Boston University Medical Center Radiologists, Inc. (BUMCR), and Dr. Jorge Soto, moved for summary judgment. The magistrate judge recommended granting the motion, and the district court adopted this recommendation, dismissing all of Dr. O'Horo's claims.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's decision, holding that Dr. O'Horo failed to establish a prima facie case of gender discrimination or retaliation. The court found that the alleged adverse actions, such as the reassignment of her duties and the scheduling of reviews, did not constitute materially adverse employment actions. Additionally, the court concluded that the hostile work environment claim was insufficient as the workplace was not objectively hostile or abusive. The aiding and abetting claim under Chapter 151B was dismissed as it was derivative of the failed discrimination claims. Lastly, the court held that Dr. O'Horo did not establish a prima facie case under the MHCWA, as she failed to show that the actions taken against her were retaliatory. View "O'Horo v. Boston Medical Center Corporation" on Justia Law

Catherine Kuo was killed while volunteering at a food distribution event organized by the Dublin Unified School District (DUSD). Her family and estate sued DUSD for negligence and premises liability, alleging failure to implement and communicate safety protocols. DUSD moved for summary judgment, arguing that Labor Code section 3364.5, which deems school volunteers as employees entitled to workers' compensation benefits, barred the plaintiffs' claims.The Superior Court of California, County of Alameda, granted DUSD’s motion for summary judgment. The court concluded that section 3364.5 applied, providing that workers' compensation was the sole remedy for any injury, including death, sustained by volunteers while performing their duties. The court found that the statute's plain language and legislative history supported this interpretation, and thus, it lacked jurisdiction to grant relief.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. The court affirmed the lower court's decision, holding that the term "any injury" in section 3364.5 unambiguously includes fatal injuries. The court also determined that DUSD’s resolution, which declared volunteers entitled to workers' compensation benefits, satisfied the statutory requirement, even though it did not explicitly use the word "deemed." The court rejected the plaintiffs' arguments that the statute did not apply because DUSD did not treat its volunteers as employees in practice, noting that the statute did not require such conduct.The appellate court concluded that the trial court correctly granted summary judgment in favor of DUSD, affirming that workers' compensation was the exclusive remedy for the plaintiffs' claims. View "Kuo v. Dublin Unified School Dist." on Justia Law

Judy Brown, a biracial woman, was hired by Conagra Brands, Inc. in October 1997. After a workplace injury in 2015, she became disabled and filed a workers' compensation claim in 2017. Conagra temporarily transferred her to a different position as an accommodation and continued paying her at the higher rate until July 2020, when her work restrictions became permanent, and her pay was reduced. Following the death of a colleague, Conagra posted job openings, and Brown applied for a position but was not selected. She was assigned to less favorable shifts and subsequently filed discrimination charges. Brown was fired in December 2021 and sued Conagra, alleging race and disability discrimination, retaliation, and violation of Nebraska common law.The United States District Court for the District of Nebraska granted Conagra’s motion to dismiss for failure to state a claim. Brown did not challenge the district court’s finding that her race and disability discrimination claims based on the July 2020 pay reduction were time-barred.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The court affirmed the dismissal, finding that Brown failed to plead sufficient facts to support her claims. Specifically, she did not provide enough details to infer race discrimination, did not plausibly allege a disability under the ADA or NFEPA, and did not establish a causal connection for her retaliation claims. Additionally, the court found that Brown did not state a plausible claim for common law unlawful retaliation, as she did not allege any immediate precipitating events or facts that could infer a causal nexus between her workers' compensation claim and the adverse employment actions. View "Brown v. Conagra Brands, Inc." on Justia Law

Hood River Distillers, Inc. operates a liquor distillery in Oregon, employing approximately twenty-five unionized employees represented by Teamsters Local Union No. 670. In January 2019, the Union and Hood River began negotiating a new collective bargaining agreement. The negotiations focused on health insurance, wages, and other benefits. Despite several bargaining sessions, the parties did not reach an agreement, and Hood River unilaterally implemented its final offer in May 2020, leading to a strike by the Union.The National Labor Relations Board (NLRB) found that Hood River violated the National Labor Relations Act (NLRA) by unilaterally changing employment terms without reaching an impasse in negotiations. Hood River argued that the Union engaged in unjustified delay tactics, justifying its unilateral actions. The administrative law judge (ALJ) ruled against Hood River, and the NLRB affirmed the ALJ's decision, finding that the Union's actions did not constitute unjustified delay tactics and that no impasse had been reached.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that substantial evidence supported the NLRB's conclusion that Hood River acted unlawfully by unilaterally implementing its March 30 offer. The court found that the Union's insistence on in-person mediation during the early stages of the COVID-19 pandemic was not unreasonable and did not constitute unjustified delay tactics. The court also noted that Hood River failed to preserve its challenge to the remedy awarded by the NLRB.The court denied Hood River's petition for review and granted the NLRB's cross-application for enforcement, affirming the NLRB's decision that Hood River violated the NLRA by unilaterally changing employment terms without reaching an impasse and without justification based on the Union's conduct. View "Hood River Distillers, Inc. v. NLRB" on Justia Law

Plaintiff Melissa Mandell-Brown filed a complaint against Novo Nordisk, Inc. and Zamaneh Zamanian, asserting 16 causes of action, including claims for discrimination, sexual harassment, and retaliation under the Fair Employment and Housing Act (FEHA) and the Labor Code, as well as common law claims for breach of contract, wrongful termination, and intentional infliction of emotional distress. Defendants filed a motion for summary judgment, supported by a separate statement of 161 undisputed facts, attorney declarations, and witness declarations. Plaintiff did not file an opposition to the motion or a separate statement.The Superior Court of Los Angeles County granted the defendants' motion for summary judgment after plaintiff failed to file the required opposition or separate statement, despite being granted two continuances. The court found no genuine issues of material fact and concluded that the plaintiff could not prove the elements of her causes of action. Plaintiff appealed the decision.The California Court of Appeal, Second Appellate District, Division Five, reviewed the case. The court held that the trial court did not abuse its discretion under Code of Civil Procedure section 437c, subdivision (b)(3), by granting the motion based on the plaintiff’s failure to file the requisite separate statement. The appellate court noted that the trial court had the discretion to grant the motion for summary judgment when the opposing party fails to comply with the requirement of a separate statement. Given the complexity of the case and the plaintiff's failure to submit any opposition or appear at the hearing, the appellate court affirmed the trial court's judgment. View "Mandell-Brown v. Novo Nordisk Inc." on Justia Law

Space Exploration Technologies Corp. (SpaceX) operates a space launch business and a global satellite-based internet service called Starlink. In June 2022, a group of SpaceX employees sent an open letter demanding certain actions from the company and solicited support through a survey. SpaceX discharged four employees involved in the letter's distribution for violating company policies. Additional employees were later discharged for lying during a leak investigation and for unrelated performance issues. These employees filed charges with the National Labor Relations Board (NLRB) in November 2022, alleging violations of the National Labor Relations Act.The NLRB Regional Director found merit in the claims and issued an order consolidating the employees' cases with a hearing set for March 2024. SpaceX sued the NLRB in the Southern District of Texas (SDTX) in January 2024, challenging the NLRB's structure as unconstitutional and seeking declaratory and injunctive relief. The NLRB moved to transfer the case to the Central District of California (CDCA), arguing improper venue. The SDTX granted the transfer motion in February 2024. SpaceX petitioned for an emergency writ of mandamus to vacate the transfer order, which was initially stayed but later denied.The United States Court of Appeals for the Fifth Circuit reviewed the case. SpaceX argued that the district court effectively denied its motion for a preliminary injunction by failing to rule on it by May 2, 2024. The Fifth Circuit found that SpaceX did not demonstrate the "serious, perhaps irreparable, consequence" required for an immediate appeal. The court noted that participating in the administrative proceeding did not constitute irreparable harm and that the district court did not act unreasonably in waiting to resolve procedural challenges. Consequently, the Fifth Circuit dismissed SpaceX's appeal for lack of subject-matter jurisdiction. View "Space Exploration Technologies Corp. v. National Labor Relations Board" on Justia Law