Justia Labor & Employment Law Opinion Summaries

Plaintiff-appellant Rose Jones, an employee of the Regents of the University of California (the University), was injured while riding her bike on University grounds on her way home from work. She and her husband filed suit against the University. The University moved for summary judgment, arguing inter alia, that Jones was limited to workers’ compensation under that system’s “exclusivity” rule. Although an employee’s commute was generally outside the workers’ compensation scheme, the University argued Jones’s injuries were subject to the “premises line” rule, which extended the course of employment until the employee left the employer’s premises. The trial court agreed and granted summary judgment for the University. Appellants challenged the trial court’s ruling, claiming that a triable issue remained as to whether the premises line rule applied to Jones’s accident based on a variety of factors. After review, the Court of appeal determined the factors appellants cited raised no question about the rule’s application. Therefore, judgment was affirmed. View "Jones v. Regents of the University of California" on Justia Law

The Supreme Court affirmed the judgment of the Workers' Compensation Appeals Board (appeals board) affirming the judgment of the Court of Workers' Compensation Claims (trial court) ordering Employer to pay Employee's attorney's fees and costs under Tenn. Code Ann. 50-6-226(d)(1)(B), holding that there was no error.Employee filed a petition for benefit determination seeking additional medical treatment after injuring his hip while working for Employer. The trial court ordered Employer to provide separate panels of specialists to treat Employee's hip and back. Employee subsequently filed another petition for benefit determination seeking temporary disability benefits. Employer agreed pay the requested temporary disability benefits. Thereafter, the trial court ordered Employer to pay attorneys' fees and costs to Employee's attorney. The appeals board affirmed. The Supreme Court affirmed, holding that the trial court did not err in ordering Employer to pay Employee's attorneys' fees and costs under section 50-6-226(d)(1)(B). View "Earheart v. Central Transport" on Justia Law

In 2011, the automaker FCA transferred the work that plaintiffs (engineers) had previously performed at FCA’s company headquarters to a new location. The plaintiffs filed a grievance with their union, UAW, in 2016. UAW failed to pursue it. In 2017, plaintiffs filed essentially the same grievance, but UAW again did not pursue it. By this time, plaintiffs had learned of a massive bribery scheme involving FCA and UAW; they believed that those bribes had affected the 2011 job-relocation process and UAW’s treatment of their grievances. In 2018, plaintiffs filed the same grievance again. Nearly two years later, UAW found the grievance meritorious.Plaintiffs sued FCA, UAW, and individual defendants in 2020, raising claims under the Labor Management Relations Act (LMRA), 29 U.S.C. 185(a), and the Racketeer Influenced and Corrupt Organizations Act (RICO). The Sixth Circuit affirmed the dismissal of the claims as untimely under the LMRA’s six-month limitations period. Plaintiffs pursuing a hybrid LMRA claim must sue once they “reasonably should know that the union has abandoned” their claim. Plaintiffs learned of their RICO injuries as early as 2011 and learned of the bribery allegations in 2017 but waited until 2020 to file their complaint, with no explanation for the delay. View "Baltrusaitis v. United Auto Workers" on Justia Law

Plaintiff is a foreign worker hired by defendant Alco Harvesting LLC to work at farms owned by defendant and appellant Betteravia Farms. He later brought employment claims against appellants. Alco moved to compel arbitration pursuant to an arbitration agreement presented to and signed by Plaintiff at his orientation. The trial court found the agreement void and denied the motion. It considered arbitration a “material term and condition” of Plaintiff’s employment and as such, a job requirement that Alco should have disclosed during the H-2A certification process.   The Second Appellate District affirmed. The court explained that Alco’s arbitration agreement required Plaintiff to forfeit his right to a jury trial in “any claim, dispute and/or controversy that [any] Employee may have against the Company . . . arising from, relating to or having any relationship or connection whatsoever with [or to the] Employee’s . . . employment by, or other association with the Company . . . .” The arbitration agreement also prohibited him from participating in any class action claims against Alco. Thus, the court considered the relinquishing of these rights as “material terms and conditions” of his employment. View "State of Cal. v. Alco Harvest" on Justia Law

In April 2017 and June 2017, Appellant Diane Zilka filed petitions with the Philadelphia Department of Revenue (the “Department”), seeking refunds for the Philadelphia Tax she paid from 2013 to 2015, and in 2016, respectively. During the relevant tax years, Appellant resided in the City, but worked exclusively in Wilmington, Delaware. Thus, she was subject to four income taxes (and tax rates) during that time: the Philadelphia Tax; the Pennsylvania Income Tax (“PIT”); the Wilmington Earned Income Tax (“Wilmington Tax”); and the Delaware Income Tax (“DIT”). The Commonwealth granted Appellant credit for her DIT liability to completely offset the PIT she paid for the tax years 2013 through 2016; because of the respective tax rates in Pennsylvania versus Delaware, after this offsetting, Appellant paid the remaining 1.93% in DIT. Although the City similarly credited against Appellant’s Philadelphia Tax liability the amount she paid in the Wilmington Tax — specifically, the City credited Appellant 1.25% against her Philadelphia Tax liability of 3.922%, leaving her with a remainder of 2.672% owed to the City — Appellant claimed that the City was required to afford her an additional credit of 1.93% against the Philadelphia Tax, representing the remainder of the DIT she owed after the Commonwealth credited Appellant for her PIT. After the City refused to permit her this credit against her Philadelphia Tax liability, Appellant appealed to the City’s Tax Review Board (the “Board”). The issue this case presented for the Pennsylvania Supreme Court's review as whether, for purposes of the dormant Commerce Clause analysis implicated here, state and local taxes had to be considered in the aggregate. The Court concluded state and local taxes did not need be aggregated in conducting a dormant Commerce Clause analysis, and that, ultimately, the City’s tax scheme did not discriminate against interstate commerce. Accordingly, the Court affirmed the Commonwealth Court order. View "Zilka v. Tax Review Bd. City of Phila." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint for a writ of mandamus requiring the Industrial Commission of Ohio to award him a scheduled award of permanent partial disability (PPD) compensation under Ohio Rev. Code 4123.57(B) for the loss of the use of his right hand, holding that the court of appeals correctly denied the writ.Appellant was injured during the course of his employment as a laborer when he fell from a roof onto concrete below. A district hearing officer granted Appellant's request for scheduled-loss compensation, but a staff hearing officer vacated that order on appeal. The court of appeals denied Appellant's ensuing complaint for a writ of mandamus. The Supreme Court affirmed, holding that some evidence supported the commission's decision denying Appellant's request for compensation for the loss of the use of his right hand, and the commission did not abuse its discretion. View "State ex rel. Block v. Industrial Commission of Ohio" on Justia Law

The Supreme Court affirmed the final award of the labor and industrial relations commission affirming and adopting an administrative law judge's award of permanent total disability benefits to Jannie Harper under the Missouri Workers' Compensation Law, holding that the commission's decision was supported by competent and substantial evidence.Harper filed a claim for workers compensation against Springfield Rehab and Health Center and Premier Group Insurance Company Corvel Enterprise Company (collectively, Springfield Rehab). The commission awarded Harper permanent and total disability benefits, finding that Harper suffered a compensable injury arising from a workplace accident. The Supreme Court affirmed, holding that competent and substantial evidence supported the commission's final award of permanent total disability compensation and future medical care. View "Harper v. Springfield Rehab & Health Care Center" on Justia Law

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission finding that Maryann Gray's applications for review were timely filed pursuant to Mo. Rev. Stat. 287.480 and overruling Hawthorn Children's Psychiatric Hospital's motion to strike, holding that the Commission did not err in finding that Gray's applications were timely filed.Gray, a registered nurse at Hawthorn, filed applications for review of the denial of her claims for injuries sustained during her employment. After a hearing, the Commission found Gray timely filed her applications and affirmed the denial of benefits as to a 2012 injury but ordered Hawthorn to pay Gray partial permanent disability benefits for 2013 and 2014 injuries. The Supreme Court affirmed, holding that the Commission did not err in finding that Gray's applications were timely filed under section 287.480. View "Gray v. Hawthorn Children's Psychiatric Hospital" on Justia Law

Above All Termite & Pest Control ("Above All") employed Henry Keim as a salaried pest-control technician and provided him with an employer authorized vehicle for work use. Above All’s policy limited the quantity of supplies technicians could keep in their authorized vehicles overnight. When technicians needed to replenish supplies, Above All authorized them to drive their vehicles to Above All’s shop instead of driving directly to a worksite, to retrieve whatever they required, and then to go from the shop to the scheduled sites. On the morning of the accident, Keim clocked in, received his schedule, and concluded that his vehicle lacked sufficient supplies. On his way to the shop for supplies, Keim sustained injuries in a car accident. The Judge of Compensation dismissed Keim’s claim petition with prejudice, concluding that Keim was merely commuting to work when he sustained injuries. The Appellate Division applied the “authorized vehicle rule” and reversed the dismissal order. The New Jersey Supreme Court concurred with the appellate court, finding Keim was “in the course of employment” under the “authorized vehicle rule” at the time of the accident because Above All authorized a vehicle for him to operate and his operation of that identified vehicle was for business expressly authorized by Above All. View "Keim v. Above All Termite & Pest Control" on Justia Law

The Department of Defense Education Activity (DODEA) operates schools for military families. Smithson has worked as a DODEA science teacher since 2004. Smithson’s medical conditions include migraines, intracranial hypertension, affective disorder, vertigo, and ADHD. These conditions, with the required medications, have caused her problems with balance, walking, driving, breathing, vision, speech, and memory. In 2010, Smithson first obtained accommodations–an occasional flexible start time and permission to be seated during part of the teaching day. In 2014-2016, Smithson's requests for additional accommodations were largely granted. Principal Villareal's response to Smithson’s request for a flexible duty reporting time of up to two hours was, “The employee is approved to use sick leave for any absence from school up to two hours, barring any undue hardship to the school schedule.” Later, Smithson indicated that she would be late every day but would arrive before her first instructional section. Smithson then used sick leave as needed. During the pandemic, Smithson began to work from home, full-time, in DODEA’s Virtual School.Smithson sued under the Rehabilitation Act for disability discrimination and failure to accommodate when she was required to use a half-day of sick leave whenever she arrived late. The Seventh Circuit affirmed summary judgment in favor of DODEA. In-person attendance was an essential function of Smithson’s position and her need to miss up to two hours each morning demonstrated that she could not perform this essential function. A frequent two-hour delay at the beginning of the school day is not the same as an infrequent 15-minute delay, as permitted under her original accommodation. View "Smithson v. Austin" on Justia Law