Justia Labor & Employment Law Opinion Summaries

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Cephia Hayes, an employee of the New Jersey Department of Human Services (NJDHS) since 2004, alleged that her supervisor began sexually harassing her in 2016 and retaliated against her when she rebuffed his advances. In October 2019, Hayes filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC). The EEOC decided not to pursue her case and communicated this decision to Hayes's lawyer via email on March 11, 2020, stating that a right-to-sue letter would be issued. The EEOC also posted the right-to-sue letter to its online portal on the same day.The United States District Court for the District of New Jersey granted summary judgment in favor of NJDHS, ruling that Hayes's Title VII claims were time-barred. The court determined that the 90-day filing period began either when the EEOC emailed Hayes's lawyer or when the right-to-sue letter was posted to the EEOC's online portal. Consequently, the court found that Hayes's lawsuit, filed on November 24, 2020, was untimely.The United States Court of Appeals for the Third Circuit reviewed the case and vacated the District Court's decision. The Third Circuit held that the March 11 email from the EEOC to Hayes's lawyer did not start the 90-day clock because it was not equivalent to a right-to-sue letter. The court also ruled that the posting of the right-to-sue letter to the EEOC's online portal did not suffice to start the 90-day period without direct communication to Hayes or her lawyer. The court found that Hayes had presented sufficient evidence to rebut the presumption that she received the right-to-sue letter three days after it was mailed, creating a genuine issue of material fact regarding the timeliness of her lawsuit. The case was remanded for further proceedings. View "Hayes v. New Jersey Department of Human Services" on Justia Law

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Danny Lopez, an airline fuel technician, filed a wage-and-hour lawsuit under California law against his employer, Menzies Aviation (USA), Inc. Lopez alleged that Menzies violated state requirements for meal periods, rest periods, overtime wages, minimum wages, and other employment conditions. Menzies sought to compel arbitration based on an arbitration agreement Lopez signed as part of his employment.The United States District Court for the Central District of California denied Menzies' motion to compel arbitration. The court found that Lopez, as a transportation worker engaged in foreign or interstate commerce, was exempt from the Federal Arbitration Act (FAA) under 9 U.S.C. § 1. The court reasoned that Lopez’s role in fueling airplanes used in interstate and foreign commerce was integral to the transportation process, thus qualifying him for the exemption.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The Ninth Circuit held that a fuel technician who places fuel in planes used for foreign and interstate commerce is a transportation worker engaged in commerce. The court emphasized that such a worker plays a direct and necessary role in the free flow of goods across borders. The court clarified that there is no requirement for the worker to have hands-on contact with goods or be directly involved in their transportation to fall within the FAA exemption. Consequently, the Ninth Circuit concluded that Lopez was exempt from the arbitration requirements of the FAA and affirmed the district court’s denial of Menzies' motion to compel arbitration. View "LOPEZ V. AIRCRAFT SERVICE INTERNATIONAL, INC." on Justia Law

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The claimant, a New Hampshire resident, was employed by a Vermont corporation with its principal place of business in New Hampshire. His job required traveling between New Hampshire and Vermont job sites. On September 13, 2022, while working at the New Hampshire facility, the claimant injured his hand. He filed for workers' compensation benefits with the employer's Vermont insurance carrier, which denied the claim due to lack of jurisdiction.The claimant appealed to the Vermont Department of Labor, arguing that his employment constituted "employment in this State" under 21 V.S.A. § 616(a). Both parties moved for summary judgment. The Commissioner granted summary judgment to the employer, concluding that the claimant did not meet the jurisdictional requirements because he was not hired in, did not reside in, and was not injured in Vermont. The Commissioner also found that the claimant worked more hours in New Hampshire than in Vermont and rejected the claimant's broader interpretation of jurisdiction under the statute.The Vermont Supreme Court reviewed the case de novo and affirmed the Commissioner’s decision. The Court held that 21 V.S.A. § 616(a) requires an injury to occur in Vermont for jurisdiction to attach, with an exception for injuries outside the state if the worker was hired in Vermont. The Court found that the claimant did not meet these criteria. The Court also noted that the claimant's proposed interpretation would lead to absurd results, potentially extending Vermont's workers' compensation jurisdiction nationwide based on corporate domicile alone. The Court concluded that the Commissioner’s interpretation was consistent with legislative intent and precedent, and thus, Vermont lacked jurisdiction to adjudicate the claimant’s workers' compensation claim. View "Burnett v. Home Improvement Company of Vermont" on Justia Law

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Shawn Slezak, a mechanic for Lancaster County, Nebraska, filed a grievance after his performance evaluation for 2021 was completed late and by higher-level supervisors rather than his direct supervisor. The evaluation, which was below the threshold for a merit increase, was delayed due to discrepancies between numerical ratings and written comments. Slezak argued that the late evaluation violated the collective bargaining agreement (CBA) and sought a merit increase.The Lancaster County Personnel Policy Board found that the late evaluation constituted a breach of contract and awarded Slezak a retroactive merit increase. The County challenged this decision, arguing that the remedy was improper since Slezak's evaluation score did not warrant a merit increase. The District Court for Lancaster County agreed with the County, reversing the Board's decision on the grounds that the remedy made Slezak "more than whole" and was inconsistent with the objective of a damages award in a breach of contract case.The Nebraska Supreme Court reviewed the case and affirmed the District Court's decision. The Court held that the Board's remedy was inappropriate because it exceeded the scope of a damages award in a breach of contract case. The Court emphasized that the objective of such an award is to make the injured party whole, not to provide a benefit they would not have received if the contract had been performed. The Court also noted that Slezak's score on the late evaluation was below the threshold required for a merit increase, and thus, the delay in the evaluation did not cause his injury. The Court concluded that the District Court did not err in reversing the Board's decision and affirmed the order. View "Lancaster County v. Slezak" on Justia Law

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A group of plaintiffs, including several states and corporations, challenged a Department of Labor rule that allowed ERISA fiduciaries to consider environmental, social, and governance (ESG) factors when making investment decisions if those factors equally serve the financial interests of the plan. This rule was issued following an executive order by President Biden, which counteracted a previous Trump-era rule that prohibited considering non-pecuniary factors in investment decisions.The United States District Court for the Northern District of Texas upheld the Department of Labor's rule, relying on the Chevron deference doctrine, which allows courts to defer to a federal agency's interpretation of ambiguous statutory language. The district court concluded that the rule was not "manifestly contrary to the statute" after affording the Department the deference due under Chevron.The United States Court of Appeals for the Fifth Circuit reviewed the case. During the appeal, the Supreme Court decided Loper Bright Enterprises v. Raimondo, which overruled Chevron, thus eliminating the deference previously given to agency interpretations. Given this significant change in the legal landscape, the Fifth Circuit vacated the district court's judgment and remanded the case for reconsideration in light of the new Supreme Court decision. The appellate court emphasized the importance of allowing the district court to reassess the merits without the Chevron framework, ensuring that the lower court's independent judgment is applied to the statutory interpretation of ERISA. View "State of Utah v. Su" on Justia Law

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A former transportation security officer (TSO) with the Transportation Security Administration (TSA) alleged that his termination was an act of retaliation under Title VII. The TSA terminated his employment for failing to cooperate in an investigation into whether he received illegal compensation for serving as a personal representative during internal agency investigations. The plaintiff argued that this reason was a pretext for retaliation due to his prior complaints to the TSA’s Equal Employment Office (EEO) about a hostile work environment and denial of Family Medical Leave Act (FMLA) leave.The United States District Court for the Central District of California granted summary judgment in favor of the Secretary of Homeland Security. The court found that the plaintiff had not provided sufficient evidence to show that the TSA’s stated reason for his termination was pretextual. The court noted that the temporal proximity between the plaintiff’s last EEO complaint and his termination (56 days) was not enough to establish pretext, especially given the concurrent timing of the plaintiff’s noncooperation with the investigation.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The appellate court held that the 56-day gap between the plaintiff’s final EEO complaint and his termination was insufficient by itself to show pretext. The court also noted that the timing of the plaintiff’s noncooperation with the investigation supported the TSA’s stated reason for termination. Additionally, the court found that other circumstantial evidence presented by the plaintiff did not create a genuine issue of material fact regarding pretext. The court concluded that the TSA had a legitimate, non-retaliatory reason for terminating the plaintiff’s employment and affirmed the summary judgment. View "KAMA V. MAYORKAS" on Justia Law

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Clyde O. Carter, Jr. filed a complaint under the Federal Rail Safety Act (FRSA) against BNSF Railway Company, alleging retaliation for reporting a work-related injury. Carter claimed that BNSF initiated disciplinary investigations and terminated him due to his injury report. Initially, an administrative law judge (ALJ) found in favor of Carter, and the Administrative Review Board (ARB) affirmed. However, the United States Court of Appeals for the Eighth Circuit vacated the ARB’s order and remanded the case for further proceedings.The Occupational Safety and Health Administration initially found no FRSA violation by BNSF. After Carter objected, the case was transferred to an ALJ, who ruled in Carter’s favor. The ARB affirmed, but the Eighth Circuit vacated this decision, citing errors in the ALJ’s causation theory and lack of substantial evidence supporting the ARB’s findings. On remand, a different ALJ found that Carter’s injury report was not a contributing factor in BNSF’s decisions to investigate and terminate him, attributing the actions to Carter’s dishonesty. The ARB affirmed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and denied Carter’s petition for review. The court held that substantial evidence supported the ALJ’s findings that Carter’s injury report did not contribute to BNSF’s decision to terminate him. The court also found no procedural errors in the ALJ’s handling of the case on remand. Consequently, the court concluded that Carter failed to prove that his injury report was a contributing factor in his termination, and thus, BNSF was not liable under the FRSA. The petition for review was denied. View "Carter v. Secretary, Department of Labor" on Justia Law

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Alexander Behrend, a Work Practice Apprentice (WPA) at the San Francisco Zen Center, filed an employment discrimination lawsuit under the Americans with Disabilities Act (ADA). Behrend, who lived and worked at the Center, performed various tasks including meditation, cleaning, cooking, and maintenance. He argued that his role was not ministerial because it involved mostly menial work and did not include teaching or leading the faith.The United States District Court for the Northern District of California granted summary judgment in favor of the San Francisco Zen Center. The court found that Behrend's role fell within the First Amendment’s ministerial exception, which exempts religious organizations from certain employment laws in relation to their ministers. The court determined that Behrend’s duties, although menial, were integral to the Center’s religious mission and practice.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The Ninth Circuit held that the ministerial exception applied to Behrend’s role as a WPA. The court emphasized that the exception is broad and includes roles that are essential to carrying out a religious organization’s mission, even if they do not involve teaching or leadership. The court concluded that Behrend’s work was a vital part of Zen training and practice, thus fitting within the ministerial exception. The court rejected Behrend’s argument that only those with key roles in preaching and transmitting the faith qualify for the exception, noting that precedent supports a broader application. The court affirmed the district court’s grant of summary judgment, upholding the application of the ministerial exception. View "BEHREND V. SAN FRANCISCO ZEN CENTER, INC." on Justia Law

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Dean Dabbasi was terminated by his employer, Motiva Enterprises, in 2019. Dabbasi filed a lawsuit alleging age discrimination under the Age Discrimination in Employment Act (ADEA) and the Texas Commission on Human Rights Act (TCHRA), as well as disability discrimination under the Americans with Disabilities Act (ADA) and the TCHRA. He claimed that his termination was due to his age and a cardiac incident he experienced during a performance improvement plan (PIP) meeting. Motiva argued that Dabbasi was terminated for poor performance and attitude.The United States District Court for the Southern District of Texas granted summary judgment in favor of Motiva. The court found that Dabbasi's claims related to his transition to a different role and the failure to place him in a promised position were time-barred or not actionable. The court also held that Dabbasi failed to establish a prima facie case of age discrimination because he was not replaced by someone younger in his final position. Additionally, the court concluded that Dabbasi was not disabled at the time of his termination, as he returned to work without restrictions after his medical leave.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the district court erred in evaluating Dabbasi's age-discrimination claim in isolation rather than considering the totality of the evidence. The appellate court determined that there was sufficient circumstantial evidence to create a genuine dispute of material fact regarding whether Dabbasi was terminated because of his age. However, the court agreed with the district court that Dabbasi failed to establish a prima facie case of disability discrimination, as he was not disabled at the time of his termination.The Fifth Circuit affirmed the dismissal of Dabbasi's disability-discrimination claim but reversed the summary judgment on his age-discrimination claim, remanding it for further proceedings. View "Dabbasi v. Motiva Enterprises" on Justia Law

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Jebari Craig, a black employee, worked for Wrought Washer Manufacturing, Inc. from 2010 until his termination in April 2019. Craig, who became the union president in 2018, filed a racial discrimination grievance against Wrought. He alleged that his termination was in retaliation for this grievance. The incident leading to his termination involved a disagreement with a supervisor and subsequent use of his cell phone on the shop floor, which violated company policy. Craig was suspended and later offered a "Last Chance Agreement" to return to work, which he refused to sign, leading to his termination.The United States District Court for the Eastern District of Wisconsin granted summary judgment to Wrought on Craig's claim that his termination was retaliatory. The court found that Craig had not established a prima facie case of retaliation for his written warning and allowed his claim regarding his suspension to proceed. However, it granted summary judgment on the termination claim, crediting Wrought's explanation that the "Last Chance Agreement" did not require Craig to relinquish his discrimination claims, contrary to Craig's later assertions.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court's judgment, agreeing that Schaefer, Wrought's plant manager, was confused during his deposition about the terms of the "Last Chance Agreement" and the severance agreement. The court found that Craig's declaration, which contradicted his earlier statements, did not create a genuine issue of material fact. The court concluded that no reasonable litigant would have withheld the information Craig later provided, supporting the district court's decision to grant summary judgment to Wrought. View "Craig v. Wrought Washer Manufacturing, Inc." on Justia Law