Justia Labor & Employment Law Opinion Summaries

Jose E. Amstutz, a police officer employed by Harris County Precinct 6, was terminated after his wife filed a police report alleging domestic abuse. Amstutz was placed on leave and later terminated following an internal investigation that found he violated several policies. Amstutz claimed his wife had a history of making false allegations and had informed his supervisors about this potential. After his termination, Amstutz struggled to find other law enforcement employment, which he attributed to the General Discharge noted in his F-5 report.The United States District Court for the Southern District of Texas dismissed Amstutz’s Age Discrimination in Employment Act (ADEA) claims for failure to exhaust administrative remedies and for not responding to the timeliness challenge. The court also dismissed his 42 U.S.C. § 1983 claims, finding that he had not pleaded a protected property interest in his at-will employment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s dismissal of the ADEA claims, agreeing that Amstutz failed to address the timeliness challenge, thus waiving opposition to that argument. The court also affirmed the dismissal of the § 1983 claims, concluding that Amstutz did not identify any independent source of law that would create a property interest in his employment. The court found that Amstutz’s employment was at-will and that he did not have a legitimate claim of entitlement to continued employment. Consequently, the court also dismissed Amstutz’s Monell claim against Harris County, as there was no underlying constitutional violation. The court affirmed the district court’s denial of leave to amend, finding no abuse of discretion. View "Amstutz v. Harris County" on Justia Law

A group of former managers of Ruby Tuesday, Inc. participated in two top-hat retirement plans administered by Regions Bank. These plans were unfunded and designed for high-level employees, meaning they were exempt from certain ERISA fiduciary duties. When Ruby Tuesday filed for bankruptcy, the managers lost their benefits and sued Regions Bank, alleging breaches of state-law fiduciary, trust, contract, and tort duties. They also sought equitable relief under ERISA to recover their lost benefits.The United States District Court for the Eastern District of Tennessee dismissed the state-law claims, ruling that ERISA preempted them. The court also granted summary judgment to Regions Bank on the ERISA claim, concluding that the requested monetary relief did not qualify as equitable relief under ERISA.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that ERISA preempted the state-law claims because they related to an ERISA-covered plan. The court emphasized that allowing state-law claims would undermine ERISA's uniform regulatory scheme. Additionally, the court held that the monetary relief sought by the plaintiffs did not qualify as equitable relief under ERISA. The court reasoned that the plaintiffs' request for an "equitable surcharge" was essentially a request for legal damages, which ERISA does not permit under its equitable relief provision.Thus, the Sixth Circuit affirmed the district court's judgment in favor of Regions Bank, concluding that the plaintiffs could not pursue their state-law claims or obtain the requested monetary relief under ERISA. View "Aldridge v. Regions Bank" on Justia Law

Clinton Mahoney, the sole member and manager of Mahoney & Associates, LLC, signed an agreement obligating the company to contribute to the Railroad Maintenance and Industrial Health and Welfare Fund, an employee benefit fund. When the Fund could not collect delinquent contributions from Mahoney & Associates, it sued Mahoney personally, citing a personal liability clause in the agreement. The district court granted summary judgment to the Fund, concluding that Mahoney was personally liable based on the clause.The United States District Court for the Central District of Illinois initially entered judgment on July 31, but it did not comply with Federal Rule of Civil Procedure 58. Mahoney filed a notice of appeal on September 26, and the district court later entered a corrected judgment on October 11. Mahoney filed a second notice of appeal the same day. The district court had awarded the Fund attorneys’ fees based on the trust agreement.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that there was a genuine dispute of material fact regarding Mahoney’s intent to be personally bound by the trust agreement, as he signed the memorandum in a representative capacity, which conflicted with the personal liability clause. The court concluded that this issue could not be resolved at summary judgment. The court also addressed Mahoney’s laches defense but found it waived due to his failure to address relevant complications. Consequently, the Seventh Circuit reversed the district court’s grant of summary judgment and vacated the award of attorneys’ fees, remanding the case for further proceedings. View "Railroad Maintenance and Industrial Health & Welfare Fund v. Mahoney" on Justia Law

The case involves Medical Staffing of America, LLC, doing business as Steadfast Medical Staffing, and its owner, Lisa Ann Pitts, who were found to have violated the Fair Labor Standards Act (FLSA) by misclassifying approximately 1100 nurses as independent contractors instead of employees. This misclassification led to the nurses not receiving proper overtime compensation, resulting in nearly five million dollars in unpaid wages and an equal amount in liquidated damages.The United States District Court for the Eastern District of Virginia conducted a bench trial in 2021, where it found that Steadfast exercised significant control over the nurses, including setting their pay rates, controlling their schedules, and enforcing workplace policies. The court concluded that the nurses were employees under the FLSA and awarded the Secretary of Labor unpaid overtime compensation and liquidated damages. Steadfast's defense, claiming they acted in good faith based on legal advice, was rejected as the court found their reliance on incomplete legal advice unreasonable.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment. The appellate court agreed with the lower court's findings that the nurses were employees based on the economic realities of their relationship with Steadfast. The court also upheld the district court's rejection of Steadfast's good faith defense and its adoption of the damages computations presented by the Secretary of Labor. The final judgment included over nine million dollars in unpaid overtime compensation and liquidated damages, along with an injunction against further FLSA violations by Steadfast. View "Chavez-DeRemer v. Medical Staffing of America, LLC" on Justia Law

Katrina Beran, a certified nursing assistant, was employed at Linden Court, a skilled nursing facility owned by VSL North Platte Court, LLC. In December 2019, Christopher Eugene was hired as another certified nursing assistant. Eugene made derogatory comments about women and engaged in inappropriate physical conduct, including groping Beran and other female staff. Beran reported Eugene's behavior to her supervisors, but they dismissed her concerns and failed to take effective remedial action. Beran continued to experience harassment, leading to severe emotional distress and exacerbation of her post-traumatic stress disorder. She was eventually terminated after reporting Eugene's misconduct.The United States District Court for the District of Nebraska denied Linden Court's motion for summary judgment, and the case proceeded to trial. The jury found in favor of Beran, awarding her $500,000 in compensatory damages and $2,500,000 in punitive damages. The district court reduced the punitive damages to $200,000 due to statutory caps and awarded Beran attorney fees and costs. Linden Court's post-trial motions for judgment as a matter of law and a new trial were denied.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court's decision, holding that there was sufficient evidence to support the jury's findings of a hostile work environment and that Linden Court failed to take prompt and effective remedial action. The court also upheld the award of punitive damages, finding that Linden Court acted with reckless indifference to Beran's rights. Additionally, the court found that the compensatory damages awarded for Beran's emotional distress were not excessive and were supported by the evidence. View "Beran v. VSL North Platte Court LLC" on Justia Law

Workforce Safety and Insurance (WSI) initiated a civil action against Boechler PC and Jeanette Boechler for unpaid workers' compensation premiums, penalties, and interest for periods ending in mid-August 2019. WSI was awarded a judgment of $11,661.99, mostly penalties, against the corporation, and the claim against Boechler personally was dismissed without prejudice. In May 2022, WSI filed a second action against the corporation and Boechler personally for additional amounts not included in the previous judgment. The district court granted summary judgment in favor of WSI against the corporation for $10,854.53 but identified issues regarding Boechler’s personal liability.The district court found that Boechler, as president of the corporation, was personally liable for unpaid premiums but not for penalties related to the failure to file payroll reports. The court awarded WSI $5,802, holding that Boechler’s personal liability did not extend to penalties for failing to file payroll reports and that personal liability only applied to amounts determined as of the date of WSI’s decision.The North Dakota Supreme Court reviewed the case and held that the district court correctly interpreted N.D.C.C. § 65-04-26.1 to mean that Boechler’s personal liability does not include penalties for failing to file payroll reports. However, the Supreme Court found that the district court erred in determining that personal liability only applied to amounts existing as of the date of the decision. The Supreme Court concluded that Boechler’s personal liability should include amounts accruing after the WSI determination of her liability. The court affirmed in part, reversed in part, and remanded the case for entry of a judgment consistent with its opinion. View "WSI v. Boechler" on Justia Law

Jonathan Egelston, a youth correctional officer, was dismissed from his position by the Department of Corrections and Rehabilitation after he allegedly assaulted and harassed his girlfriend, J.G., and subsequently lied about the incident. The State Personnel Board (SPB) upheld his dismissal following an evidentiary hearing. Egelston then petitioned for a writ of mandate to reverse the SPB's decision, but the trial court denied his petition.The family law court had previously dismissed J.G.'s request for a domestic violence restraining order (DVRO) against Egelston without prejudice. Egelston argued that this dismissal should bar the findings of assault and dishonesty under the doctrines of res judicata and collateral estoppel. However, the trial court found that the SPB's credibility determinations, which favored J.G.'s testimony over Egelston's, were entitled to great weight.The California Court of Appeal, Second Appellate District, reviewed the case. The court concluded that Egelston's contention regarding res judicata and collateral estoppel was forfeited because it was not raised in the lower court. Additionally, the court found that the claim lacked merit. The family law court's dismissal of the DVRO without prejudice did not constitute a final judgment on the merits, and thus had no preclusive effect. The causes of action in the DVRO proceeding and the SPB proceedings were different, and the parties were not in privity.The Court of Appeal affirmed the trial court's judgment, upholding Egelston's dismissal from his position. The Department of Corrections and Rehabilitation was awarded its costs on appeal. View "Egelston v. State Personnel Board" on Justia Law

Ka’Toria Gray filed a lawsuit against her former employer, Koch Foods of Alabama, LLC (Ala-Koch), its parent company Koch Foods, Inc., and former Ala-Koch employees Melissa McDickinson and David Birchfield, alleging harassment. The jury found in favor of Koch Foods and Ala-Koch on all claims, in favor of Birchfield and McDickinson on Gray’s claims of invasion of privacy and outrage, and in favor of Gray on her claims for assault and battery, awarding her $50,000 in total damages.The United States District Court for the Middle District of Alabama denied all parties' motions for judgment as a matter of law (JMOL) and entered a final judgment consistent with the jury verdict. The court also awarded costs to Gray against Birchfield and McDickinson and to Koch Foods and Ala-Koch against Gray.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court’s denial of Birchfield and McDickinson’s renewed motion for JMOL on the assault and battery claims, finding sufficient evidence to support the jury’s verdict. The court also upheld the punitive damages awarded to Gray, concluding that the evidence met the clear and convincing standard required under Alabama law.The court rejected Gray’s argument for a new trial on her Title VII sexual harassment claim, noting that she waived her right to contest the verdicts as inconsistent by not objecting before the jury was discharged. The court also affirmed the district court’s grant of summary judgment on Gray’s constructive discharge claim, as the jury’s verdict on the hostile work environment claim precluded her constructive discharge claim.Finally, the court affirmed the district court’s prevailing party determinations, awarding costs to Gray against Birchfield and McDickinson and to Koch Foods and Ala-Koch against Gray. The court found no abuse of discretion in these awards. View "Gray v. Birchfield" on Justia Law

John Gilchrist and Byron Brockman sued their former employer, Schlumberger Technology Corp., for failing to pay them overtime in violation of the Fair Labor Standards Act (FLSA). They worked as Measurements While Drilling Field Specialists (MWDs), providing essential data to Schlumberger's clients for drilling operations. Their duties included monitoring drilling data, ensuring data quality, and advising clients on drilling operations. Both earned over $200,000 annually but were not paid overtime.The United States District Court for the Western District of Texas held a bench trial and found that Schlumberger failed to prove that Gilchrist and Brockman were exempt from the FLSA's overtime requirements under the Highly Compensated Employee (HCE) exemption. The court determined that their duties did not qualify as administrative or executive tasks that would exempt them from overtime pay. Schlumberger appealed this decision.The United States Court of Appeals for the Fifth Circuit reviewed the case and reversed the district court's decision. The appellate court held that Gilchrist and Brockman qualified as highly compensated employees exempt from the FLSA's overtime pay requirement because they performed administrative duties, specifically quality control and advisory roles, which are directly related to the management or general business operations of Schlumberger's clients. The court noted that the MWDs' tasks were performed customarily and regularly, meeting the criteria for the HCE exemption. Consequently, the appellate court remanded the case with instructions to dismiss the claims for overtime pay. View "Gilchrist v. Schlumberger" on Justia Law

Kara Mitchell, a laboratory technician at Exxon Mobil Corporation, was terminated in 2020 after a little over a year of employment. ExxonMobil claimed her termination was due to poor performance compared to her peers in the company's annual employee assessment process. Mitchell alleged that her termination was due to sex discrimination and sued the company under Title VII of the Civil Rights Act of 1964.The United States District Court for the Northern District of Illinois granted summary judgment in favor of ExxonMobil, concluding that Mitchell failed to provide sufficient evidence to support her claim of sex discrimination. Mitchell appealed the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and upheld the district court's decision. The appellate court found that Mitchell did not present enough evidence to show that she was treated less favorably than similarly situated male employees. The court noted that Mitchell's comparators, two male lab technicians, were not similarly situated because they were not part of the same assessment group. Additionally, the court found that Mitchell failed to prove that ExxonMobil's reason for her termination was pretextual.The Seventh Circuit also considered Mitchell's argument under the holistic approach articulated in Ortiz v. Werner Enterprises, Inc., but concluded that there was no evidence of a pattern or practice of sex discrimination at the Cicero plant. The court affirmed the district court's grant of summary judgment to ExxonMobil, finding that no reasonable jury could conclude that Mitchell was terminated because of her sex. View "Mitchell v Exxon Mobil Corp." on Justia Law