Justia Labor & Employment Law Opinion Summaries

Employees at a truck dealership in Summit, Illinois, worked under a collective bargaining agreement through Laborforce and M&K Employee Services. In 2023, a union steward in the Parts Department, dissatisfied with union representation, initiated a decertification petition. Nineteen out of thirty-one Parts Department employees signed, but no Service Department employees did. Laborforce, responding without encouraging or interfering in the process, announced its intention to withdraw union recognition for the Parts Department after the three-year bar in the collective bargaining agreement expired. Laborforce also filed a unit clarification petition with the National Labor Relations Board (NLRB), which was denied. Nevertheless, Laborforce withdrew recognition and improved wages and benefits for Parts Department employees. In 2024, a second, broader decertification petition was signed by a majority of both Parts and Service Departments, prompting Laborforce to withdraw union recognition for all affected employees and again change compensation and benefits.The union filed multiple unfair labor practice charges with the NLRB, and the Board’s Regional Director issued an administrative complaint in June 2024. The complaint argued that the first withdrawal was unlawful due to lack of majority support and that the second withdrawal was tainted by the prior removal. An administrative law judge (ALJ) held a hearing in October 2024 and subsequently found Laborforce had committed unfair labor practices.Seeking immediate relief, the Director petitioned the United States District Court for the Northern District of Illinois for a preliminary injunction under NLRA § 10(j), requesting reinstatement of union recognition and reversal of wage and benefit changes. The district court denied the injunction, finding insufficient evidence of irreparable harm, likelihood of success, or public interest.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed. It held that the Director failed to show specific irreparable harm warranting the “extraordinary” § 10(j) remedy, especially given employee-initiated decertification and improved compensation. The delay in seeking an injunction further undermined the request. View "Hamada v Laborforce, LLC" on Justia Law

A police officer at a university was disciplined after corroborating a fellow officer’s allegations of sexual misconduct during a Title IX investigation. He had encouraged the officer to report the misconduct but did not report it himself. After participating in the investigation, he experienced several incidents he believed were retaliatory, including changes to his work routine and being denied promotion opportunities. He later recorded a conversation between his department chief and assistant chief, believing it would provide evidence of retaliation. The chief suspended him for the recording and initiated an investigation conducted by police chiefs from other schools, which resulted in a recommendation that he be fired and dishonorably discharged. Before the termination could take place, he resigned but was still given a dishonorable discharge. He filed a complaint with the EEOC, received a right to sue letter, and brought a Title VII retaliation claim.The United States District Court for the Northern District of Texas granted summary judgment to the university, finding that the plaintiff had not established a prima facie case for retaliation. The court held that he did not suffer an adverse employment action and that there was no causal link between his participation in the Title IX investigation and any adverse action.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision de novo. The Fifth Circuit held that the plaintiff established a prima facie case of retaliation concerning his suspension and the investigation into the phone recording, but not for the dishonorable discharge, as that decision was made by an independent panel with no knowledge of his protected activity. The court found a genuine dispute of material fact about whether the rationale for the suspension and investigation was pretextual. The Fifth Circuit reversed the district court’s grant of summary judgment and remanded the case for further proceedings. View "Crawford v. West Texas A&M" on Justia Law

The Commonwealth of Kentucky initiated a lawsuit against several pharmacy benefit managers (PBMs) and related entities, asserting that these firms contributed to the opioid crisis in Kentucky by conspiring with drug manufacturers to increase opioid supply. Kentucky alleged the PBMs negotiated with drug companies to give opioids preferred placement on formularies in exchange for rebates and fees, thus violating state consumer protection laws and creating a public nuisance. The PBMs served both federal and commercial clients, including federal workers under the Federal Employees Health Benefits Act, TRICARE members, and Veterans Health Administration beneficiaries.Following removal of the case to the United States District Court for the Eastern District of Kentucky by the PBMs under the federal officer removal statute (28 U.S.C. § 1442), Kentucky sought to remand the case to state court, arguing its complaint disclaimed liability for conduct undertaken at the direction of federal officers. The district court granted Kentucky’s motion to remand.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision de novo. Relying on its prior decision in Ohio ex rel. Yost v. Ascent Health Services, LLC, and similar decisions from other circuits, the Sixth Circuit determined the PBMs acted under federal officers when administering federal health benefits and that Kentucky’s claims related to conduct performed under federal supervision. The court found the PBMs had raised colorable federal defenses, including immunity and preemption under federal statutes governing federal health plans, TRICARE, ERISA, and Medicare Part D. The court concluded that Kentucky’s complaint targeted indivisible conduct relating to federal duties, so the PBMs met the requirements for removal under § 1442. The Sixth Circuit reversed the district court’s remand order and remanded the case for further proceedings. View "Commw. of Ky. v. Express Scripts, Inc." on Justia Law

Consumers Concrete Corp. participated in a multiemployer pension plan administered by Central States Southeast and Southwest Areas Pension Fund. After making a partial withdrawal from the plan in 2017, Consumers fully withdrew in 2019, triggering statutory withdrawal liability for the complete withdrawal. The dispute focused on how to apply a credit for the prior partial withdrawal liability when determining the amount owed for the subsequent complete withdrawal. The parties agreed on the underlying figures for unfunded vested benefits and annual payments, but disagreed on whether the credit should be applied before or after the statutory cap limiting payments to twenty annual installments.Following Consumers’s challenge, an arbitrator adopted the Fund’s approach, applying the partial withdrawal credit at the second step of the statutory calculation process. Consumers appealed to the United States District Court for the Northern District of Illinois, Eastern Division. The district court consolidated the competing actions and vacated the arbitration award, siding with Consumers. It held that the credit should be applied after completing all four statutory steps, including the twenty-year payment limitation.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s legal conclusions de novo. It determined that the statutory language and structure favored Consumers’s interpretation, concluding that the partial withdrawal liability credit must be applied after the four-step process outlined in 29 U.S.C. § 1381(b), rather than at step two. The court’s holding was that the credit for prior partial withdrawal liability under 29 U.S.C. § 1386(b)(1) should reduce the fully-adjusted withdrawal liability amount determined after the application of all steps, including the twenty-year cap. The Seventh Circuit affirmed the district court’s judgment. View "Consumers Concrete Corp. v Central States, SE and SW Areas Pension Fund" on Justia Law

Two Black firefighters employed by the Springfield Fire Department alleged racial and religious discrimination, retaliation, and hostile work environment, claiming harassment beginning around 2014. One plaintiff, who is Muslim, reported being denied a promotion despite being the only eligible applicant, and later experienced unfavorable treatment regarding training, evaluations, and disciplinary actions compared to white colleagues. The other plaintiff, a Jehovah’s Witness, alleged discriminatory promotion practices and procedural irregularities that favored white candidates. Both plaintiffs asserted that the department tolerated and sometimes participated in hostile conduct, including racist and anti-Muslim social media posts by fellow firefighters, some of whom held supervisory positions. The plaintiffs claimed the fire department failed to protect them from harassment, even after formal complaints.After mediation failed, the plaintiffs brought suit in the United States District Court for the District of Massachusetts, asserting violations of Title VII of the Civil Rights Act of 1964 and Massachusetts General Laws Chapter 151B, among other claims. The District Court dismissed several claims and defendants but allowed the core allegations of discrimination, retaliation, and hostile work environment against the City of Springfield to proceed. At trial, both sides presented evidence about departmental procedures, supervisor obligations, and the City’s response to the alleged harassment. The jury found in favor of the defendants on all counts, and the plaintiffs appealed.The United States Court of Appeals for the First Circuit reviewed the appeal. The court held that the District Court did not abuse its discretion in responding to a jury question, nor did it err in its instructions regarding the relevance of Civil Service decisions, the First Amendment, or employer liability under Massachusetts law. The appellate court found no reversible error and affirmed the judgment in favor of the defendants. View "Savage v. City of Springfield" on Justia Law

An employee of the New York State Unified Court System was terminated after she failed to comply with her employer’s COVID-19 vaccination mandate. She had requested a religious exemption, but her request was denied after she did not complete a supplemental form to the satisfaction of the vaccine exemption review committee. After her termination, the employer eventually rescinded the vaccination requirement and permitted her reinstatement, but she nonetheless brought a lawsuit alleging that the employer failed to accommodate her religious beliefs, in violation of Title VII.The United States District Court for the Eastern District of New York denied the employer’s motion to dismiss, then later granted partial summary judgment in favor of the employee. The district court relied on what it deemed to be judicial admissions by the employer that the employee’s initial exemption request was “perfectly adequate” and explained a religious belief. The district court held that the employee had established a prima facie case of religious discrimination under Title VII, using the Second Circuit’s previous standard, and determined that the employer had not shown that accommodation would pose an undue hardship.On appeal, the United States Court of Appeals for the Second Circuit held that its prior standard for establishing a prima facie case in Title VII religious accommodation cases was abrogated by the Supreme Court’s decision in EEOC v. Abercrombie & Fitch Stores, Inc., 575 U.S. 768 (2015). The Second Circuit clarified that a plaintiff must now show (1) an actual need for accommodation, and (2) that the employer’s desire to avoid providing that accommodation was a motivating factor in an adverse employment decision. The appellate court also found the district court erred in treating certain discovery statements as judicial admissions. The Second Circuit vacated the district court’s judgment and remanded for further proceedings. View "Bergin v. N.Y. State Unified Court System" on Justia Law

Six former employees of a regional public transportation agency challenged the agency’s mandatory COVID-19 vaccination policy, asserting that it failed to accommodate their sincere religious objections to vaccination. In late 2021, the agency required all employees to be fully vaccinated unless exempted for medical or religious reasons. The agency’s leave management department evaluated religious exemption requests and determined that 70 employees qualified for potential accommodations but ultimately concluded that none could be accommodated without undue hardship. These employees were told to get vaccinated or lose their jobs; many resigned, retired, or were terminated.A group of former employees who lost their jobs filed suit in the United States District Court for the Northern District of California, bringing claims under Title VII, the California Fair Employment and Housing Act (FEHA), and 42 U.S.C. § 1983 (alleging a violation of their right to free exercise of religion). The district court granted summary judgment for the defendant on the § 1983 claim and denied summary judgment on the other claims. After consolidation and a first trial that ended in a mistrial on the defendant’s undue hardship defense, six employees proceeded to a second trial. There, a jury found in their favor, awarding over $7.8 million in damages. The district court denied the defendant’s renewed motion for judgment as a matter of law and its request for a new trial.On appeal, the United States Court of Appeals for the Ninth Circuit held that the employer was not entitled to judgment as a matter of law or a new trial. The court concluded that the employees established a prima facie case and that the employer failed to prove that accommodating the employees’ religious objections would have caused an undue hardship, as required by law. The appellate court affirmed the district court’s judgment. The court also found no reversible error in the remedial order and deemed the cross-appeal on the free exercise claim moot. View "LEWIS-WILLIAMS V. SAN FRANCISCO BAY AREA RAPID TRANSIT DISTRICT" on Justia Law

A former police officer for a federally recognized Indian tribe was terminated from his position and subsequently brought a lawsuit in federal court against several of his superior officers and the tribe's general counsel. His claims, brought against these individuals in their personal capacities, included federal civil rights causes of action under 42 U.S.C. §§ 1981, 1985(2), and 1985(3), a Bivens claim, and a state tort claim for intentional interference with contractual relations. He did not sue the tribe itself. The complaint alleged that the defendants treated him less favorably than Native American employees, subjected him to a racially hostile work environment, interfered with his court testimony, and conspired to deprive him of due process in his employment and reputation.The United States District Court for the District of Nevada dismissed the action. The court held that the individual defendants were entitled to absolute personal immunity, and, alternatively, that the tribe was a required party under Federal Rule of Civil Procedure 19 that could not be joined due to tribal sovereign immunity. The court did not address arguments regarding tribal sovereign immunity or qualified immunity as independent grounds for dismissal.The United States Court of Appeals for the Ninth Circuit reversed. The court held that tribal sovereign immunity does not bar suits seeking money damages from tribal officials in their individual capacities where any judgment would not operate against the tribe itself. The court further held that the individual defendants were not entitled to absolute immunity, as the functions at issue—personnel and employment decisions—were not historically protected by such immunity at common law. Additionally, the tribe was not a required party under Rule 19 because it lacked a legally protected interest that could be impaired by the litigation’s outcome. The court remanded for the district court to address any qualified immunity defenses in the first instance. View "ERWINE V. WESTBROOK" on Justia Law

A mail carrier employed by the United States Postal Service in Carpentersville, Illinois, alleged that he was subjected to discrimination and retaliation based on his race and national origin, as well as a hostile work environment. The central incident occurred after a heated dispute over overtime with his supervisor, which escalated to yelling and profanity. The supervisor called police, who escorted the employee from the facility, after which he was placed on emergency leave without pay for two days. The employee later filed a grievance under the collective bargaining agreement, resulting in rescission of the emergency placement and compensation for lost pay. The employee identified additional workplace incidents, including timekeeping errors and a supervisor’s presence during a route observation, as part of an alleged pattern of discriminatory treatment.The United States District Court for the Northern District of Illinois granted summary judgment for the Postal Service on all claims. Because the employee failed to properly dispute the Postal Service’s Statement of Facts as required by local rule, the district court deemed those facts admitted. The court reviewed the evidence submitted, including deposition transcripts, and concluded that the employee had not established a prima facie case of discrimination, retaliation, or hostile work environment under Title VII.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit found that the district court properly enforced its local rules and did not abuse its discretion. On the merits, the appellate court held that the employee failed to present evidence showing similarly situated comparators, a causal link for retaliation, or harassment based on a protected characteristic. The court affirmed the district court’s entry of summary judgment in favor of the Postal Service on all claims. View "Ismail v Steiner" on Justia Law

A former certified nursing assistant at a health center suffered a work-related back injury in March 2011. Her employer reported the injury and began providing disability compensation and medical benefits voluntarily. She formally filed a claim for workers’ compensation benefits in November 2011. The employer continued benefits until December 2012, when it offered a “light duty” position, which the employee declined, resulting in the cessation of further payments. She also received medical benefits until March 2015, when those were discontinued following an independent medical evaluation finding her capable of sedentary work. The employee did not pursue further action regarding the termination of her benefits for several years.After voluntarily ending her wage-loss and medical benefits, the employee attended an informal conference in early 2013, reportedly resulting in a recommendation to continue her disability benefits. However, her employer did not accept this, and no formal hearing was ever held. The record does not explain why the employee did not pursue further administrative remedies at that time. Years later, in 2022, now with new counsel, she filed a new claim seeking reinstatement of wage-loss benefits and reimbursement for medical expenses incurred since the prior terminations.An Administrative Law Judge for the D.C. Department of Employment Services denied her claim as untimely under the relevant statute. The Compensation Review Board affirmed, determining that her 2022 claim was subject to the one-year statute of limitations under D.C. Code § 32-1514(a), which applies to new claims for benefits, and that she had not filed a timely claim within one year of the last payment of either wage-loss or medical benefits.The District of Columbia Court of Appeals agreed with the Compensation Review Board, holding that the employee’s 2022 claims were time-barred under D.C. Code § 32-1514(a) because she failed to file within one year of the last payment of compensation or medical benefits. The court affirmed the Board’s decision. View "Crutchfield v. District of Columbia Department of Employment Services" on Justia Law