Justia Labor & Employment Law Opinion Summaries

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Paulo Trindade, a former employee of Grove Services, Inc., sued his previous employer for breach of contract and violations of the Massachusetts Wage Act, claiming he had been underpaid on his sales commission compensation for the years 2014, 2015, and 2016. Following a bench trial, the United States District Court for the District of Massachusetts ruled in part for Trindade and in part for Grove, awarding Trindade $330,597 in damages. Both parties appealed. The United States Court of Appeals for the First Circuit affirmed the lower court's judgment. The Court of Appeals agreed with the district court's conclusion that Trindade's amended complaint, which included a claim for unpaid wages for 2016, related back to his original complaint, making the claim timely under Massachusetts law. The Court of Appeals also concluded that the district court was correct in its decision to award the damages it did, including an amount for the late payment and underpayment of Trindade's 2016 commission. View "Trindade v. Grove Services, Inc." on Justia Law

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The case involves plaintiff-appellant Cassandra Kincaid, an assistant principal at Central Middle School in Kansas, who claimed that she was harassed by the Unified School District No. 500 in retaliation for her reporting a student-on-student sexual assault. The United States Court of Appeals for the Tenth Circuit affirmed the district court's grant of summary judgment in favor of the school district. The court concluded that Kincaid did not satisfy her burden of creating a genuine dispute of material fact that the reasons given for the alleged material adverse actions against her were pretextual. The court examined various aspects of the case under Title VII and Title IX, which prohibit retaliation against individuals for complaining of sex discrimination. It considered numerous allegedly adverse employment actions, including two emails sent by the school principal, a request for Kincaid's transfer, and a letter of concern. The court concluded that none of the evidence Kincaid provided created a genuine dispute of material fact about pretext. View "Kincaid v. Unified School District No. 500, Kansas City, KS" on Justia Law

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Jeffrey Bruno, a veteran firefighter with the Kankakee Fire Department, sued Mayor Chasity Wells-Armstrong, James Ellexson, the Human Resources Director for the City of Kankakee, and the City of Kankakee, alleging discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA). Bruno suffered a severe cardiac event in 2017 and upon his return to work was promoted to Deputy Chief. However, in 2019, he was denied a raise and presented with an employment contract that tied additional compensation to his enrollment in college courses. When Bruno requested the removal of this education condition, citing his heart condition as a barrier to attending classes, his request was denied. After signing the contract, Bruno retired and initiated legal proceedings.The United States Court of Appeals For the Seventh Circuit affirmed the district court's decision, which had granted summary judgment for the defendants. The court concluded that Bruno's request to remove the education condition was not a request for a reasonable accommodation under the ADA, as it would not impact his ability to perform his job. The court also rejected Bruno's claim of disparate treatment, as his argument of pretext was contradicted by the evidence. Bruno's ADA retaliation claim also failed because his identified protected activity was not protected under the ADA. As Bruno's IHRA and indemnification claims were dependent on his ADA claims, these too were rejected. View "Bruno v. Wells-Armstrong" on Justia Law

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In the case before the United States Court of Appeals for the Fourth Circuit, Bikachi Amisi, a contract nurse, sued Officer Lakeyta Brooks and Officer Roy Townsend for violating her Fourth Amendment rights when she was mistakenly strip searched on her first day of work at Riverside Regional Jail. Amisi also brought several tort claims under Virginia state law. The defendants moved for summary judgment, arguing they were entitled to qualified immunity and good-faith immunity under Virginia law. They also argued that the Virginia Workers’ Compensation Act’s exclusivity provision barred Amisi's claims. The district court denied their motions and the defendants appealed.The Court of Appeals affirmed the district court's decision. It held that both officers were not entitled to qualified immunity, a legal protection that shields officers who commit constitutional violations but who could reasonably believe their actions were lawful, because their actions were not reasonable and Amisi’s right to be free from unreasonable strip searches was clearly established. The court also held that the Virginia Workers' Compensation Act did not bar Amisi's state-law claims because her injuries did not arise out of her employment. The Court further held that Officer Townsend was not entitled to immunity under Virginia law as his belief that his conduct was lawful was not objectively reasonable. View "Amisi v. Brooks" on Justia Law

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In a case before the Supreme Court of Pennsylvania, Ursinus College utilized financing from the Montgomery County Health and Higher Education Authority (Authority) to undertake a construction project. The International Brotherhood of Electrical Workers, Local No. 98 (IBEW) asserted that this project was a public work under the Pennsylvania Prevailing Wage Act (PWA), which would require workers on the project to receive prevailing minimum wages. The court was tasked with determining whether this project constituted a public work under the PWA. The court found that the project was not a public work as defined in the PWA, as the funds for the project did not come from a public body. Rather, the Authority served as a conduit for financing, with private funds generated from the Authority's ability to issue bonds being used to pay for the project. The Authority did not hold or disburse these funds, nor did it bear any risk or liability with respect to the repayment of the bonds. Therefore, the court held that the project was not subject to the PWA's prevailing wage requirements. View "Ursinus College v. Prevailing Wage Appeals Board" on Justia Law

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In a dispute between Valley Hospital Medical Center and the National Labor Relations Board, the United States Court of Appeals for the Ninth Circuit denied the Hospital's petition for review, granted the Board's cross-application for enforcement, and enforced the Board's order. The court previously remanded the case to the Board to better explain its decision that an employer may unilaterally cease union dues checkoff after the expiration of a collective bargaining agreement. Upon remand, the Board reversed its prior decision, readopting its rule prohibiting employers from unilaterally ceasing dues checkoff after expiration of a collective bargaining agreement, and found that Valley Hospital engaged in an unfair labor practice. Valley Hospital contended that the Board exceeded its mandate from the court, which only authorized supplementing its reasoning, not changing its interpretation of the National Labor Relations Act. However, the Ninth Circuit held that its earlier mandate did not explicitly prohibit the Board from reconsidering its rule, so the Board was not bound by its prior decision. The court also found that the Board's new decision was rational and consistent with the Act. Thus, the Board's order was enforced. View "NATIONAL LABOR RELATIONS BOARD V. VALLEY HOSPITAL MEDICAL CENTER, INC." on Justia Law

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The United States Court of Appeals for the Ninth Circuit ruled that employers cannot unilaterally stop deducting union dues from employee paychecks after the expiration of a collective bargaining agreement. The case involved Valley Hospital Medical Center and Desert Springs Hospital Medical Center (collectively known as the "Hospitals") and the Service Employees International Union, Local 1107 ("the Union”). The Union and the Hospitals had entered into collective bargaining agreements that included checkoff provisions requiring the Hospitals to deduct union dues from participating employees’ paychecks and to remit those dues to the Union. After the agreements expired, the Hospitals ceased dues checkoff, arguing that the written assignments authorizing this did not include express language concerning revocability upon expiration of the collective bargaining agreement. They believed this omission violated the Labor Management Relations Act, also known as the Taft-Hartley Act. The Union filed unfair labor practice charges, and the National Labor Relations Board determined that the Hospitals had committed an unfair labor practice by unilaterally ceasing dues checkoff. The court held that the Taft-Hartley Act did not require specific language in the written assignments, so the Hospitals could not rely on that statute to justify their unilateral action. Consequently, the court granted the Board’s application for enforcement, denied the Hospitals' petition for review, and enforced the Board’s order in full. View "NATIONAL LABOR RELATIONS BOARD V. VALLEY HEALTH SYSTEM, LLC DBA DESERT SPRINGS HOSPITAL MEDICAL CENT" on Justia Law

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The plaintiff, Srecko Bazdaric, was injured while painting an escalator during a renovation project. The escalator was covered with a plastic sheet, which Bazdaric slipped on, sustaining injuries that left him unable to work. He and his wife sued the owners of the premises and the general contractor, alleging violations of Labor Law § 241 (6), which requires employers to provide safe working conditions. The Court of Appeals of New York held that the plaintiffs were entitled to summary judgment as to liability on their Labor Law § 241 (6) claim. The court found that the plastic covering was a slipping hazard that the defendants failed to remove, in violation of Industrial Code 12 NYCRR 23-1.7 (d), making the defendants liable under Labor Law § 241 (6). The court also found that the plastic covering was not integral to the paint job but was a nonessential and inherently slippery plastic that caused Bazdaric's injuries. The court reversed the lower court's conclusion to the contrary. View "Bazdaric v Almah Partners LLC" on Justia Law

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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