Justia Labor & Employment Law Opinion Summaries

Clayton Creason worked as an engineer for Elanco US from November 2017 to November 2021. During his employment, Elanco offered a standard paid vacation benefit and an optional “vacation buy” program that allowed employees to purchase an extra week of paid leave by accepting a reduction in weekly salary. Creason participated in this program, reducing his pay by approximately $84 per week for the additional vacation week. After resigning, he filed suit under the Indiana Wage Payment Statute, claiming Elanco owed him the amount of the salary reduction, arguing the program required a written assignment of wages with notice of the right to rescind, as specified by Indiana law.The suit was initially filed in Indiana state court, with Creason seeking class certification for similarly situated employees. Elanco removed the case to the United States District Court for the Southern District of Indiana under the Class Action Fairness Act. The district court denied Creason’s belated motion to remand, finding his delay in seeking remand unreasonable after substantial progress in federal court. The court then dismissed some claims on the pleadings and granted summary judgment to Elanco on the remaining issues, concluding the vacation buy program did not constitute an assignment of wages and that Elanco’s policies concerning unused pandemic-related vacation hours did not violate Indiana law.The United States Court of Appeals for the Seventh Circuit reviewed the case. It held that the district court acted within its discretion in denying the remand request due to Creason’s unreasonable delay. On the merits, the Seventh Circuit affirmed that the vacation buy program was not an assignment of wages under Indiana law and that Elanco was not obligated to pay out unused COVID-related vacation hours. The district court’s decision was affirmed. View "Creason v Elanco US Inc." on Justia Law

The case centers on an employee who was involved in a workplace motor vehicle accident. Initially, the employer did not pay any workers’ compensation benefits. The employee, after reporting neck and back injuries through counsel, filed a claim for compensation. During a deposition, the employee claimed he had received emergency room treatment for his injuries two days after the accident, but medical records contradicted this. The employer asserted that this was a willful misrepresentation made to obtain workers’ compensation benefits.The Office of Workers’ Compensation, District 6, reviewed the claim. The workers’ compensation judge found the employee to be temporarily totally disabled for a period prior to the deposition and awarded indemnity and medical benefits for that period. However, the judge also found the employee had willfully made false statements in his deposition, resulting in a forfeiture of his right to benefits from the date of the deposition forward and assessed a civil penalty. The employer appealed, seeking retroactive forfeiture from the date of the accident, and the employee argued his statements were not willful misrepresentations. The Court of Appeal, First Circuit, upheld the prospective forfeiture, relying on its precedent, and partially modified the attorney’s fee award.The Supreme Court of Louisiana reviewed the case to resolve a circuit split regarding the timing of forfeiture under Louisiana Revised Statute 23:1208. The Court held that forfeiture of workers’ compensation benefits for willful misrepresentation is prospective only, commencing from the date of the misrepresentation, not retroactive to the date of the accident. The Court affirmed the judgment of the appellate court and overruled contrary precedent to the extent it held forfeiture was retroactive. View "COUSAIN VS. SMITTY'S SUPPLY, INC." on Justia Law

Kevin Flowers, a participant in an employee benefits plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), receives prescription drug benefits administered by Caremark, a pharmacy benefits manager. Flowers alleges that Caremark unjustly enriches itself by limiting maintenance prescription coverage to either CVS retail pharmacies or Caremark’s mail-order delivery service. He claims this violates Arkansas statutes requiring PBMs not to mandate home delivery and to provide reasonably adequate and accessible pharmacy networks, leading him and similarly situated individuals to pay out of pocket at local pharmacies.Reviewing the case, the United States District Court for the Western District of Arkansas granted Caremark’s motion to dismiss. The court determined that Flowers failed to plausibly plead a violation of the Mail Order Provision because Caremark did not require prescriptions to be filled solely through home delivery. Regarding the Network Adequacy Provision, the district court found that ERISA preempted the Arkansas requirements, particularly those imposing geographic coverage standards for pharmacy networks.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The court affirmed the district court’s ruling, holding that Flowers did not plausibly allege a violation of the Mail Order Provision. The court also concluded that the geographic coverage requirements imposed by Arkansas regulations under the Network Adequacy Provision are preempted by ERISA, as they force PBMs to tailor their networks in ways that interfere with nationally uniform plan administration and constitute an impermissible connection with ERISA plans. The court expressly left open whether the Network Adequacy Provision, without its implementing regulations, would also be preempted. The court affirmed the district court’s dismissal of Flowers’s claims. View "Flowers v. Caremark PCS Health, LLC" on Justia Law

The plaintiff worked as a delivery driver for a furniture distribution company, transporting goods from California warehouses to customers. The furniture was sourced both within and outside California, including from Mexico, and arrived at the distribution centers before being delivered to customers. The plaintiff signed an independent contractor agreement with a delivery-service provider that included an arbitration clause, and subsequently filed two lawsuits against the furniture company and the delivery company: a class action alleging wage and hour violations, and a separate action under the Private Attorneys General Act (PAGA) for civil penalties.The Alameda County Superior Court reviewed the defendants’ omnibus motion to compel arbitration of all claims and to dismiss the plaintiff’s representative PAGA claims. The trial court found that, although the arbitration agreement was valid and enforceable and the defendants had not waived their right to arbitrate, the plaintiff qualified as a “transportation worker” under section 1 of the Federal Arbitration Act (FAA) and was thus exempt from FAA coverage. As a result, state law governed the enforcement of the arbitration agreement. The court ordered certain claims (reimbursement of expenses, wage statement claims, and unfair competition) to arbitration, but allowed wage claims to proceed in court under Labor Code section 229. It denied the motion to dismiss the representative PAGA claims, citing California Supreme Court precedent, and stayed both actions pending arbitration of individual claims.The Court of Appeal of the State of California, First Appellate District, Division One, reviewed these consolidated appeals. The court held that the plaintiff is a transportation worker exempt from the FAA because he played a direct and active role in the interstate movement of goods, even though his deliveries were intrastate and retail in nature. The court affirmed that the plaintiff has standing to pursue non-individual PAGA claims in court, following Adolph v. Uber Technologies, Inc. The order by the trial court was affirmed. View "Betanco v. Living Spaces Furniture, LLC" on Justia Law

In August 2018, an employee was injured when an aircraft sprayed him with toxic herbicide during a work-related incident. He filed a workers’ compensation claim and identified the herbicide applicator as a potentially liable third party. The state workers’ compensation agency accepted the claim for certain injuries and later terminated benefits, determining the incident was not a substantial cause of his ongoing symptoms. The employee did not appeal that termination. He subsequently sued the third party and settled for $100,000 but did not notify the agency of the settlement, as required. The agency then asserted a statutory subrogation lien against the settlement proceeds to recover payments it had made on his behalf.The employee contested the agency’s subrogation order, arguing that judicial estoppel should bar the agency’s claim because the agency had previously denied benefits for some injuries but now sought reimbursement from the third-party settlement. He also challenged the constitutionality of the statute requiring appellants to pay the costs of preparing the administrative record for judicial review and claimed he should be allowed to apply for a waiver of those costs as a low-income person. An administrative law judge rejected his arguments and affirmed the subrogation order. The District Court of Burleigh County affirmed the administrative decision and granted the agency’s motion for the employee to pay the record preparation costs.The Supreme Court of North Dakota held that the equitable doctrine of judicial estoppel does not apply to statutory subrogation interests under the state’s workers’ compensation law. The Court also concluded the statute requiring payment of record preparation costs on appeal is not unconstitutional as applied in this case and that the district court did not abuse its discretion in declining to waive those costs because the employee failed to provide evidence of low-income status. The judgment was affirmed. View "Moos v. WSI" on Justia Law

An employee of the Chicago Transit Authority (CTA), represented by a union, was terminated after repeatedly failing to follow the proper procedure for reporting Family and Medical Leave Act (FMLA) absences. The CTA required employees to notify a third-party administrator, ReedGroup, as well as their work location, when taking FMLA leave. The employee, who is transgender and had previously advocated for workplace accommodations and insurance coverage related to his transition, applied for intermittent FMLA leave for back pain, but his application was denied after he failed to complete the required process for obtaining a third medical opinion. Despite the denial, he continued to report absences as FMLA leave only to his work location, not ReedGroup, resulting in his termination for falsification of leave.After his discharge, the employee sought the union’s assistance in contesting his termination and pursued the available grievance and arbitration procedures. He also filed charges with the Equal Employment Opportunity Commission, then sued both the CTA and the union in the United States District Court for the Northern District of Illinois, Eastern Division. He asserted claims of transgender discrimination and retaliation under Title VII, as well as FMLA interference and retaliation against the CTA, and a municipal liability claim. The district court granted summary judgment in favor of the CTA and the union, concluding that the employee had failed to produce evidence that would allow a reasonable jury to find in his favor.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the employee failed to provide sufficient evidence that similarly situated non-transgender employees were treated more favorably, or that the CTA or the union’s actions were pretextual or motivated by discriminatory or retaliatory animus. The court also found no error in the exclusion of evidence and upheld the dismissal of the FMLA claims. The summary judgment for both defendants was affirmed. View "Brown v Chicago Transit Authority" on Justia Law

The appellant was employed by an insurance company and struggled with mental health issues, including major depressive disorder and later posttraumatic stress disorder and anxiety. Over several years, he received annual salary increases and bonuses. In 2020, after transferring to a new team and informing his supervisor about his mental health struggles, he took FMLA leave for treatment. While he was on leave, his supervisor approved a significantly reduced bonus and salary increase compared to prior years. Upon returning to work, he received positive performance reviews and requested accommodations related to his disability. He was granted some accommodations and continued working remotely. In 2021, after requesting further accommodations, he received another reduced bonus and salary increase. Later, after extended medical leave and unsuccessful attempts to return with additional accommodations, his employment was terminated.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the employer on all claims. It found that the appellant had not established a prima facie case of discrimination or retaliation under the ADA and FMLA. Specifically, the District Court held that the reduced bonuses and salary increases did not constitute adverse employment actions and that there was no causal connection between the protected activities (requests for leave and accommodations) and the adverse actions.The United States Court of Appeals for the Third Circuit reviewed the summary judgment order. The court applied the Burlington Northern standard, holding that the less restrictive “materially adverse” standard for retaliation claims under Title VII also applies to ADA and FMLA retaliation claims. The court found that unusually suggestive temporal proximity between the appellant’s FMLA leave and his 2020 bonus established a prima facie case for retaliation, but that such proximity was lacking for the 2021 bonus. The Third Circuit vacated the summary judgment as to the 2020 bonus retaliation claims and remanded for the District Court to consider pretext, while affirming summary judgment as to the 2021 bonus retaliation claims. View "Steidle v. United States Liability Insurance Co" on Justia Law

Dr. Jeffrey M. Ahn, an otolaryngologist practicing in New Jersey and New York, treated patients insured by Cigna Health and Life Insurance Company, which provides ERISA-governed health plans. After submitting claims for approximately fifty treatments, Dr. Ahn received denial notices from Cigna, many of which stated his claims were rejected because he was not a licensed provider. Upon appeal, Cigna sometimes reversed or modified the denial reasons. Dr. Ahn contended that these statements were defamatory and filed suit in New Jersey Superior Court, alleging defamation, defamation per se, and tortious interference.Cigna removed the case to the United States District Court for the District of New Jersey and sought dismissal or summary judgment, arguing ERISA preemption and a statute of limitations defense. Initially, the District Court deferred ruling on preemption, as it was unclear which claims related to ERISA plans. After discovery, Dr. Ahn withdrew two claims, leaving only defamation per se. Cigna again moved for summary judgment, submitting evidence that all relevant plans were governed by ERISA. Dr. Ahn presented no contrary evidence. The District Court found the plans were ERISA plans and held that Dr. Ahn’s defamation per se claim was preempted because it concerned statements made in explanation of benefits forms, which are part of ERISA plan administration.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s decision de novo. The Third Circuit held that ERISA preempts a healthcare provider’s state-law defamation claim when the alleged defamatory statements appeared in explanation of benefits forms sent to beneficiaries of ERISA plans. The court reasoned that such communications are a central aspect of plan administration and that allowing state-law claims would undermine uniformity in ERISA administration. The Third Circuit affirmed the District Court’s grant of summary judgment in favor of Cigna. View "Ahn v. Cigna Health and Life Insurance Co" on Justia Law

Two former flight attendants alleged that their employer terminated them because of their religious beliefs after they commented on the company’s internal communications platform regarding the company’s public support for proposed federal legislation expanding protections for LGBTQ individuals. One plaintiff’s comment explicitly referenced religious concerns, while the other plaintiff’s comment raised a question about the regulation of morality. Both plaintiffs were members of the flight attendants’ union, which actively participated in the internal investigation and disciplinary process. The union representatives made statements that could be interpreted as disparaging the plaintiffs’ religious beliefs. Both plaintiffs had good employment records, though one had a prior disciplinary history.The United States District Court for the Western District of Washington granted summary judgment for the employer and the union on the federal Title VII claims, finding no genuine dispute of material fact as to whether the terminations were motivated by religious discrimination. The district court also ruled that the Railway Labor Act preempted the plaintiffs’ state-law anti-discrimination claims against the union, dismissing those claims.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s rulings de novo. The appeals court held that, based on the evidence and under both direct/circumstantial and burden-shifting standards, there was a genuine dispute of material fact as to whether the employer terminated the plaintiffs because of their religious beliefs, and as to whether the union attempted to cause or acquiesced in their terminations for the same reason. The court also held that the Railway Labor Act’s duty of fair representation does not impliedly preempt state anti-discrimination claims against unions. The Ninth Circuit reversed the district court’s grant of summary judgment and its dismissal of the state-law claims, remanding for further proceedings. View "BROWN V. ALASKA AIRLINES, INC." on Justia Law

Sara Dobbins worked for the U.S. Department of Agriculture (USDA) and experienced mental health issues related to domestic abuse, leading to accommodations at work such as flexible schedules and telework. After her supervisor retired, the USDA allowed her to continue with adjusted scheduling, but with new requirements. When Charles Parr became her supervisor in 2021, he restricted these accommodations due to her frequent unapproved absences and tardiness. Over four months, Dobbins accumulated over thirty “absent without leave” infractions. The USDA suspended her, and later terminated her employment. Dobbins filed an EEOC complaint alleging sex and disability discrimination, hostile work environment, failure to accommodate, and retaliation. The EEOC found no actionable harassment or discrimination.The United States District Court for the Western District of Missouri granted summary judgment in favor of the USDA, finding that Dobbins did not provide sufficient evidence of discrimination or harassment, and failed to exhaust administrative remedies for her failure to accommodate claim.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment order de novo. The appellate court agreed that Dobbins did not present direct or indirect evidence that her suspension or termination were motivated by discrimination based on sex or disability. The court found that her absences, not her disabilities, were the basis for the adverse actions, and that her comparator evidence was insufficient as the other employee was not similarly situated. The court further held that Dobbins’s hostile work environment claim failed because the conduct described was not sufficiently severe or pervasive, nor clearly linked to her disability. Additionally, her failure to accommodate claim was barred for failure to exhaust administrative remedies, and her sex discrimination and retaliation claims were waived because she did not contest them at summary judgment. The court affirmed the district court’s judgment. View "Dobbins v. Rollins" on Justia Law