Justia Labor & Employment Law Opinion Summaries

Spa workers including massage therapists, estheticians, nail technicians, fitness instructors, and hair stylists were employed at a hotel in South Maui. The hotel required them to work a minimum number of hours and shifts each week, but compensated them solely through commissions based on services provided to clients. When no clients were present, workers were still required to remain on-site and perform other tasks such as cleaning, laundering linens, sweeping floors, taking inventory, and staffing a retail store. Plaintiffs alleged that this unpaid work often comprised most or all of their scheduled shifts, and they received no compensation for those hours.Plaintiffs filed suit in the United States District Court for the District of Hawaiʻi, alleging, among other claims, that the hotel failed to pay minimum wage as required by Hawaiʻi Revised Statutes (HRS) §§ 387-2 and 387-12. The District Court certified a question to the Supreme Court of Hawaiʻi, asking whether minimum wage compliance and damages under Hawaiʻi law should be assessed using a per-hour measure, as specified in the state statutes, or using a per-workweek unit, as under the federal Fair Labor Standards Act (FLSA).The Supreme Court of Hawaiʻi answered the certified question, holding that Hawaiʻi’s minimum wage law requires employers to pay at least the statutory minimum wage for each hour worked. The court found the statutory language “per hour” to be unambiguous and rejected the workweek-averaging approach used under the FLSA. Compliance and damages must be measured per hour, not averaged over a workweek. Workweek averaging is not permitted under HRS §§ 387-2 and 387-12. View "Bolos v. Waldorf=Astoria Management LLC." on Justia Law

Albert Hayes worked as an IT systems administrator for GStek, Inc., a contractor providing services for the U.S. Army at Fort Polk. After the COVID-19 pandemic, Hayes was required to return to in-person work. He subsequently received diagnoses of Autism, Major Depressive Disorder, and Social Anxiety Disorder. Hayes requested permission to telework as a reasonable accommodation for his disabilities. The Army, which controlled conditions for contractors at Fort Polk, determined that full-time telework was not in its best interests and denied the request. GStek allowed Hayes to telework two to three days per week, but after a mental health crisis and continued absenteeism, Hayes was terminated.Hayes pursued administrative remedies against the Army under the Rehabilitation Act, but his claims were dismissed because he was not an Army employee and had not timely pursued administrative procedures. He did not appeal that dismissal. Hayes then filed a charge of discrimination against GStek with the Equal Employment Opportunity Commission and, after receiving a right-to-sue notice, sued GStek in the United States District Court for the Western District of Louisiana, bringing claims for failure-to-accommodate, disability discrimination, and retaliation under the Americans with Disabilities Act (ADA). The district court granted GStek’s motion for judgment on the pleadings, finding that Hayes received a reasonable accommodation, was not a qualified individual under the ADA, and failed to establish prima facie cases for discrimination or retaliation.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The court held that in-person attendance was an essential function of Hayes’s job and telework was not a reasonable accommodation under the circumstances. Hayes was not a qualified individual because he could not perform the essential functions of his position, even with accommodations. As a result, his claims for failure-to-accommodate, discrimination, and retaliation under the ADA all failed. View "Hayes v. GStek" on Justia Law

The plaintiff worked as a Project Director and participated in her employer’s long-term disability (LTD) plan, which was administered by Matrix Absence Management on behalf of the Federal Reserve Bank of Cleveland. After taking leave due to ongoing symptoms from long-haul COVID-19, the plaintiff applied for LTD benefits under the plan, which required proof of total disability. Matrix reviewed the medical evidence—including opinions from both treating and independent physicians—and denied her claim, concluding that as of her leave date, she was not totally disabled under the plan’s terms. The plaintiff appealed this denial, but Matrix upheld its decision after additional review.The United States District Court for the Northern District of Ohio heard the plaintiff’s subsequent lawsuit against the Bank, Matrix, and the plan, asserting breach of contract and breach of fiduciary duty. The district court denied the plaintiff’s requests for discovery beyond the administrative record and granted judgment on the administrative record in favor of the defendants. The court found that New York contract law, not ERISA, applied, and review was limited to whether Matrix’s decision was arbitrary, made in bad faith, or the result of fraud, given the plan’s broad delegation of discretionary authority to Matrix.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the district court correctly applied New York contract law and the arbitrary-and-capricious standard of review. The appellate court found no abuse of discretion in denying discovery beyond the administrative record, as the plaintiff did not establish a colorable claim of conflict of interest or procedural defect. The Sixth Circuit concluded that Matrix’s denial had a reasonable basis in the administrative record and thus was not arbitrary or capricious. The judgment for the defendants was affirmed. View "Martin v. Fed. Rsrv. Bank of Cleveland" on Justia Law

An employee of the Department of Veterans Affairs (VA), serving as an Associate Director, was removed from his position following allegations of inappropriate conduct, including harassment and creating a hostile work environment. After the agency conducted an investigation and found lapses in professionalism, the acting director proposed removal based on these findings. The employee, who had previously raised concerns about personnel decisions and filed whistleblower complaints, alleged that his removal was in retaliation for his protected disclosures and challenged the process as procedurally flawed.The initial challenge was reviewed by an administrative judge of the Merit Systems Protection Board (MSPB), who sustained the charge of inappropriate conduct, finding that the VA had proved its case by a preponderance of the evidence. The administrative judge also found that, although the employee engaged in protected whistleblower activity, the VA demonstrated by clear and convincing evidence that it would have removed him regardless of his disclosures. Additionally, the administrative judge found no harmful procedural error in the agency’s investigation and removal process. The full MSPB denied the employee’s petition for review, adopting the administrative judge’s findings and affirming the removal.Upon appeal, the United States Court of Appeals for the Federal Circuit reviewed the MSPB’s decision. The court applied the appropriate standards of review, considering whether the agency’s actions were supported by substantial evidence and adhered to proper legal procedures. The court held that substantial evidence supported the findings that the VA would have removed the employee independent of his whistleblower activity and that there was no harmful procedural error in the removal process. The Federal Circuit affirmed the MSPB’s decision, upholding the removal. View "OLIVA v. DVA " on Justia Law

A group of employees working at a regional healthcare system sought religious exemptions from their employer’s COVID-19 vaccination policy, which was instituted in August 2021 amid the rise of the Delta variant. These employees, whose positions required close contact with patients or staff, timely applied for religious exemptions, but their requests were denied. As a result, most were placed on administrative leave and then terminated; one employee eventually complied with the policy and returned to work.The employees brought claims for religious discrimination under Title VII of the Civil Rights Act and Washington state law in the United States District Court for the Western District of Washington. The district court assumed the employees established a prima facie case of religious discrimination but granted summary judgment for the employer. The court found that the employer had demonstrated that granting the exemptions would impose a substantial burden on its ability to provide quality healthcare, citing risks to staffing, patient safety, and overall operations, and that the employees failed to rebut this showing.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s summary judgment in favor of the employer. The Ninth Circuit held that, under the standard articulated in Groff v. DeJoy, an employer must show a substantial burden in the overall context of its business, not merely a de minimis cost, to establish undue hardship. The court determined that the healthcare employer’s evidence of substantial risks to health, safety, and operations sufficed to establish undue hardship. The court also clarified that an employer is not required to prove exclusively financial hardship, nor to provide individualized accommodations if any accommodation would present an undue hardship. The judgment of the district court was affirmed. View "WILLIAMS V. LEGACY HEALTH" on Justia Law

Robert Toothman was initially employed by Apex Life Sciences, LLC, a temporary employment agency, which placed him at Redwood Toxicology Laboratory, Inc. During his employment with Apex, Toothman signed an arbitration agreement that required him to arbitrate employment disputes with Apex and its defined affiliates, subsidiaries, and parent companies. In April 2018, Toothman’s employment with Apex ended, after which he was hired directly by Redwood and worked there until June 2022. Toothman and Redwood did not sign an arbitration agreement. Several months after leaving Redwood, Toothman filed a class action alleging Labor Code violations based solely on his direct employment with Redwood, not his prior period as an Apex employee.The Sonoma County Superior Court reviewed Redwood’s motion to compel arbitration and to dismiss the class claims. Redwood argued that it was either a party to the Apex arbitration agreement as an affiliate, a third-party beneficiary, or entitled to enforce the agreement under equitable estoppel. Redwood also claimed that Toothman’s class claims should be dismissed based on the arbitration agreement. The trial court denied Redwood’s motion, finding that Redwood was not a signatory to the arbitration agreement, was not an affiliate as defined by the agreement, and could not compel arbitration under any alternative theory.The California Court of Appeal, First Appellate District, Division Four, reviewed the trial court’s order de novo. It held that Redwood was not a party to the arbitration agreement and did not qualify as an affiliate or third-party beneficiary. The court further determined that Toothman’s claims were not sufficiently intertwined with the arbitration agreement to justify equitable estoppel. The appellate court affirmed the trial court’s order denying Redwood’s motion to compel arbitration and to dismiss the class claims. View "Toothman v. Redwood Toxicology Laboratory" on Justia Law

After suffering a workplace injury just two months into his role as an immigration officer at the United States Citizenship and Immigration Services (USCIS), the plaintiff took medical leave and received workers’ compensation for more than three years. When it became clear that he could not return to work, the agency terminated his employment. He challenged this decision before the Merit Systems Protection Board (MSPB), which ordered his reinstatement based on new medical opinions indicating he could return with restrictions. However, his attempt to resume work was unsuccessful due to worsening symptoms, and he quickly returned to medical leave. During his extended absence, the Office of Inspector General investigated his freelance activities, ultimately concluding that he had misused his federal position. The agency terminated him again.The plaintiff then filed complaints with the USCIS Office of Equal Opportunity and Inclusion and the Equal Employment Opportunity Commission (EEOC), alleging disability discrimination, failure to accommodate, a hostile work environment, and retaliation under the Rehabilitation Act. After EEOC proceedings concluded against him, he filed suit in the United States District Court for the Northern District of Illinois. The district court entered summary judgment for the Secretary of Homeland Security, finding that most of the claims were unexhausted because the plaintiff did not timely pursue administrative remedies. The court also found that, on the merits, he was not a “qualified individual” under the Rehabilitation Act because he could not perform the essential functions of his job, and that there was insufficient evidence of a hostile work environment or retaliation.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed only the accommodation and hostile-workplace claims. The court held that both claims were barred for failure to timely exhaust administrative remedies. Alternatively, the court held that the claims also failed on the merits. The judgment of the district court was affirmed. View "Shiba v Mullin" on Justia Law

Two Vermont residents who worked as delivery drivers for a baked goods company sued the company, alleging violations of the Fair Labor Standards Act (FLSA) because they were not paid overtime despite regularly working more than 40 hours per week. The company classified them as independent contractors, not employees, and both the drivers and the company are located in different states: the drivers in Vermont, and the company is incorporated in Delaware with its principal place of business in Pennsylvania. The drivers brought the lawsuit in the United States District Court for the District of Vermont, both on their own behalf and on behalf of other similarly situated delivery drivers.After the case was filed, the plaintiffs asked the district court to allow notification of potential collective action members not just in Vermont, but also in Connecticut and New York. The company objected, arguing that the district court did not have personal jurisdiction over claims by out-of-state drivers. The district court disagreed, concluding that it did have personal jurisdiction over the company regarding claims by non-Vermont drivers, and permitted notification to potential plaintiffs in all three states. The district court then certified the personal jurisdiction issue for interlocutory appeal and stayed its decision.The United States Court of Appeals for the Second Circuit reviewed the case and disagreed with the district court. The appellate court held that, unless Congress has provided otherwise (which it has not in the FLSA), a federal district court’s personal jurisdiction over a defendant for out-of-state plaintiffs’ claims is limited by the same rules that bind state courts. Because there was no showing that the claims by Connecticut and New York drivers arose out of the company's contacts with Vermont, the district court lacked personal jurisdiction over those claims. The Second Circuit reversed the district court’s ruling and remanded the case for further proceedings. View "Provencher v. Bimbo Foods Bakeries Distribution LLC" on Justia Law

Several individuals who worked as warehouse associates at fulfillment centers operated by the defendants brought a class action, claiming that they and similarly situated employees were not paid for time spent undergoing mandatory security screenings before being allowed to leave the premises at the end of their shifts. The screenings, required by the employer, varied in duration depending on the items employees carried, and could range from a few seconds to up to twenty minutes. The plaintiffs alleged that this uncompensated time violated Connecticut wage laws, specifically the statutory definition of “hours worked,” and sought damages and related relief.The case was filed in Connecticut Superior Court, but was removed to the United States District Court for the District of Connecticut. The defendants moved for summary judgment, arguing that Connecticut’s wage laws were intended to mirror the federal Fair Labor Standards Act (FLSA), as amended by the Portal-to-Portal Act, and cited Integrity Staffing Solutions, Inc. v. Busk, in which the United States Supreme Court determined that such security screening time was not compensable under federal law. The District Court agreed, finding that the time was not compensable under Connecticut law and entered summary judgment for the defendants. The plaintiffs appealed to the United States Court of Appeals for the Second Circuit, which certified questions to the Supreme Court of Connecticut regarding whether Connecticut law requires compensation for such time and whether a de minimis exception applies.The Supreme Court of Connecticut held that, under Connecticut law, employees must be compensated for all time during which they are required by the employer to remain on the employer’s premises, including time spent undergoing mandatory security screenings, as this constitutes “hours worked” under the relevant statute. The court also clarified that Connecticut law does not recognize a de minimis exception to compensability, distinguishing its law from federal standards and regulations. View "Del Rio v. Amazon.com Services, Inc." on Justia Law

A community hospital in western Michigan, previously operating under a different name, was acquired by a nationwide health system in June 2022. The hospital’s collective bargaining agreement with its employee union expired shortly before the acquisition, and the union affiliated with the SEIU. Negotiations for a new contract stalled, and an employee, Jamie Quinn, initiated a decertification petition to remove the union. After sufficient signatures were gathered, a formal decertification election was held in September 2023. The union attempted to block the ballot count with pending unfair labor practice charges, but eventually withdrew the blocking request. The next day, Quinn submitted a “disaffection petition” to hospital management, claiming majority support for removing the union, though the petition had multiple defects. Despite these issues, hospital management immediately withdrew recognition from the union, but the official election results, announced soon after, showed the union still had majority support.The National Labor Relations Board’s Regional Director filed a formal complaint against the hospital for unfair labor practices. An Administrative Law Judge found the hospital’s withdrawal of recognition unjustified, citing the petition’s defects and lack of objective evidence. The Board certified the union as the bargaining representative. While the Board’s review was pending, the Regional Director petitioned the United States District Court for the Western District of Michigan for a preliminary injunction under § 10(j) of the NLRA. The district court granted the injunction, ordering the hospital to resume bargaining with the union.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. While agreeing that the Director was likely to succeed on the merits, the appellate court found that the Director failed to show a clear likelihood of irreparable harm as required by Supreme Court precedent. The Sixth Circuit reversed the district court and vacated the injunction, holding that a § 10(j) injunction requires a clear showing of irreparable harm, which was not demonstrated here. View "Kerwin v. Trinity Health Grand Haven Hosp." on Justia Law