Justia Labor & Employment Law Opinion Summaries

A fifty-nine-year-old General Manager (GM) at a Chili’s restaurant in Nashville, Tennessee, was terminated and replaced by a thirty-three-year-old with no managerial experience. The employer, Brinker International, Inc., claimed the termination was due to the GM creating a toxic "culture" and not "living the Chili’s way," despite the restaurant being one of the top performers in the market. The GM alleged that the termination was due to age discrimination, as he was the oldest manager in the region and believed Brinker was systematically replacing older employees with younger ones.The United States District Court for the Middle District of Tennessee granted summary judgment in favor of Brinker, accepting the company's explanation of "culture" as a legitimate, non-discriminatory reason for the termination. The court found that the GM could not sufficiently rebut this explanation to show it was pretext for age discrimination. The court also granted in part and denied in part the GM's motion for sanctions due to Brinker’s spoliation of evidence, awarding fees and costs but not excluding the TMR Report, which documented the termination decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that the TMR Report could not be authenticated under Federal Rule of Evidence 901 and was therefore inadmissible. The court vacated the district court’s order on sanctions and instructed it to consider whether additional sanctions beyond fees and costs were appropriate. The appellate court also reversed the district court’s grant of summary judgment for Brinker, finding that the GM had provided sufficient evidence to rebut Brinker’s explanation and create a genuine issue of material fact regarding age discrimination. The court affirmed the district court’s denial of the GM’s motion for summary judgment. View "Kean v. Brinker Int'l, Inc." on Justia Law

Two plaintiffs, a middle school teacher and an assistant principal, were employed by a school district in Oregon. They created the "I Resolve" campaign, which included a website and a video uploaded to YouTube, advocating for policies on gender identity, parental rights, and education. They used their own devices and time but also sent emails from their school accounts to district employees with links to the campaign. Following complaints from employees, students, and concerned citizens, and an independent investigator's determination that they violated district policies, the district terminated them but later reinstated them and transferred them to other positions.The United States District Court for the District of Oregon granted summary judgment in favor of the school district and individual defendants on all claims. The plaintiffs alleged that their termination was in retaliation for their protected speech and that they were discriminated against based on their religion and viewpoint. The district court concluded that the defendants' interests in avoiding disruption outweighed the plaintiffs' First Amendment rights and that the individual defendants were entitled to qualified immunity.The United States Court of Appeals for the Ninth Circuit reviewed the case. The court affirmed in part and vacated in part the district court's summary judgment. It held that there were genuine disputes regarding the circumstances of the plaintiffs' expressive conduct and the extent of the resulting disruption. The court affirmed the summary judgment for the individual defendants on the First Amendment claim for damages due to qualified immunity but vacated the summary judgment for the district on the First Amendment claim for damages and the related claims for declaratory and injunctive relief. The court also vacated the summary judgment on the plaintiffs' Fourteenth Amendment Equal Protection claim and the Title VII claim, finding genuine issues of material fact regarding the credibility of the district's proffered reasons for the terminations. View "DAMIANO V. GRANTS PASS SCHOOL DISTRICT NO. 7" on Justia Law

Workers United initiated a unionizing campaign at a Starbucks store in Los Angeles in May 2022. The store manager, Leticia Nolda, held one-on-one meetings with employees to discuss unionization. During a meeting with shift supervisor Yesenia Alarcon, Nolda expressed her opposition to the union, mentioned potential union dues, and suggested that unionization could affect benefits and raises. Alarcon did not feel free to leave the meeting but did not face any adverse consequences or feel discouraged from supporting the union. The store later voted to unionize.An administrative law judge (ALJ) found that Nolda's statements to Alarcon violated Section 8(a)(1) of the National Labor Relations Act (NLRA) by threatening economic retaliation and coercively interrogating her about union activities. The ALJ disregarded Nolda's intent and Alarcon's subjective impressions as "immaterial." The National Labor Relations Board (NLRB) affirmed the ALJ's decision. Starbucks petitioned for review, arguing that the Board applied an incorrect standard for Section 8(a)(1) violations.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court concluded that the NLRB applied an improper legal standard by disregarding the factual context, including the employee's reactions, in evaluating the alleged Section 8 violations. The court emphasized that the totality of circumstances, including employees' subjective impressions, should be considered to determine if an employer's conduct would reasonably tend to coerce an employee. The court vacated the NLRB's opinion and order and remanded the case for further proceedings consistent with its opinion. View "Starbucks Corporation v. NLRB" on Justia Law

Lorna Orabona, a high-earning mortgage development officer, was terminated by Santander Bank, N.A. for allegedly violating the company's Code of Conduct by forwarding company emails to her private email address. As a result, she was deemed ineligible for severance benefits under Santander's Employee Retirement Income Security Act (ERISA) Severance Policy. Orabona claimed that her termination was a pretext to avoid paying her severance benefits, especially since Santander was planning a large-scale layoff in her department shortly after her termination.The case was initially filed in Rhode Island Superior Court but was removed to the United States District Court for the District of Rhode Island. Santander moved to dismiss the case, arguing that Orabona's claims were preempted by ERISA. The district court allowed limited discovery to determine the applicability of the ERISA plan. After discovery, the district court granted summary judgment in favor of Santander, holding that all of Orabona's state law claims were preempted by ERISA because they related to the Severance Policy and required reference to it for determining liability and damages.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The court held that Orabona's claims were preempted by ERISA under section 514(a) because they related to the Severance Policy. The court also found that her claims seeking relief for the denial of severance benefits conflicted with the remedial scheme established by ERISA section 502(a). The court emphasized that determining liability and damages for Orabona's claims would require interpreting the terms of the ERISA-regulated Severance Policy, thus necessitating preemption. View "Orabona v. Santander Bank, N.A." on Justia Law

Ryan West, a former employee of Village Practice Management Company, LLC ("Village"), sought a declaratory judgment from the Court of Chancery of Delaware. West argued that Village could not declare a forfeiture of his vested Class B Units after he joined a competitor post-employment, as the Agreement did not limit post-employment competitive activities. Village contended that West forfeited his vested Class B Units by joining a competitor, invoking the Management Incentive Plan's ("Plan") forfeiture provisions.The Court of Chancery denied Village's motion to stay proceedings and compel West to submit his claims to Village's Compensation Committee. The court then granted West's motion for judgment on the pleadings, holding that the Agreement only restricted "detrimental activity" during employment. Consequently, Village could not enforce a forfeiture of West's vested Class B Units for activities occurring after his resignation. The court also awarded West his attorneys' fees.On appeal, the Supreme Court of Delaware reversed the Court of Chancery's decision. The Supreme Court found that the term "Participant" in the Agreement could reasonably be interpreted to include former employees, making the Agreement ambiguous. Therefore, the grant of judgment on the pleadings in favor of West was improper. The Supreme Court also reversed the award of attorneys' fees to West, as he was no longer the prevailing party. However, the Supreme Court upheld the Court of Chancery's denial of Village's request for a stay, distinguishing the case from others that required disputes to be resolved by a committee first. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Village Practice Management Company, LLC v. West" on Justia Law

Susan Miele was hired by Foundation Medicine, Inc. (FMI) in 2017 and signed a restrictive covenant agreement that included a nonsolicitation provision. In 2020, Miele and FMI executed a transition agreement upon her separation, which incorporated the restrictive covenant agreement and included a forfeiture clause. FMI paid Miele approximately $1.2 million in transition benefits. After joining Ginkgo Bioworks in 2021, Miele allegedly solicited FMI employees to join Ginkgo, leading FMI to cease further payments and demand repayment of benefits.Miele sued FMI in late 2021 for breach of the transition agreement, and FMI counterclaimed for breach of contract. Miele moved for judgment on the pleadings, arguing that the provisions FMI relied on were unenforceable under the Massachusetts Noncompetition Agreement Act. A Superior Court judge granted Miele's motion in part, ruling that FMI could not enforce the forfeiture provision but allowed FMI to assert Miele's breach as a defense and seek damages. The judge concluded that the transition agreement qualified as a "forfeiture for competition agreement" under the act.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that the Massachusetts Noncompetition Agreement Act does not apply to a nonsolicitation agreement, even if it includes a forfeiture provision. The court reasoned that the act explicitly excludes nonsolicitation agreements from its scope, and a forfeiture clause does not change this exclusion. The court reversed the Superior Court's order partially granting Miele's motion for judgment on the pleadings and remanded the matter for further proceedings consistent with its opinion. View "Miele v. Foundation Medicine, Inc." on Justia Law

Jesus Yanez was hired by EchoStar Communications Corporation in 2001 and signed an arbitration agreement as part of his employment. Over the years, EchoStar underwent several corporate changes, including a name change to DISH Network Corporation and the creation of a new company, EchoStar Corporation. Yanez was terminated in 2018 and subsequently filed discrimination claims. After receiving right to sue letters, he sued in Texas state court, alleging age and nationality discrimination. The case was removed to federal court, where the district court granted a motion to compel arbitration and transferred the case. The arbitration proceeded slowly, and the district court eventually dismissed the case without prejudice due to the parties' failure to file a status report.The United States District Court for the Western District of Texas granted the motion to compel arbitration and stayed the case pending arbitration. The case was transferred to the Western District of Texas, El Paso division. The district court issued multiple show cause notices due to slow arbitration proceedings and ultimately dismissed the case without prejudice when the parties failed to file a required status report. Yanez filed a motion to alter or amend the judgment, which was denied by the district court, citing a recent Supreme Court decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision to compel arbitration, finding that the arbitration agreement was valid and enforceable under Texas law. However, the court reversed the district court's dismissal of the case, holding that the dismissal was effectively with prejudice due to the statute of limitations and did not meet the heightened standard required for dismissals with prejudice. The case was remanded for further proceedings consistent with the ruling. View "Yanez v. Dish Network" on Justia Law

Efrain Oliveras-Villafañe, Mirta Rosario-Montalvo, and their conjugal partnership (collectively, "Appellants") filed a lawsuit against Baxter Healthcare SA and related entities ("Appellees"), alleging unlawful discrimination. Oliveras worked for Baxter from 1990 until 2019, holding various positions, including Engineering Director. In 2018, he was transferred to a lower position, which he claimed was part of a discriminatory effort to remove senior Puerto Rican personnel. In 2019, his position was eliminated, and he chose termination over accepting two part-time roles. He filed a discrimination charge with the EEOC in May 2019.The United States District Court for the District of Puerto Rico granted summary judgment in favor of the Appellees. The court found that the Appellants failed to comply with Local Rule 56(c) and disregarded non-compliant facts. It dismissed the Title VII claims, ruling that the EEOC charge did not encompass the February 2018 transfer and was untimely. The court also found that the Appellants did not establish a prima facie case of discrimination regarding the March 2019 termination. The remaining claims were dismissed based on the Appellants' concessions.The United States Court of Appeals for the First Circuit affirmed the district court's judgment. The appellate court noted that the Appellants failed to challenge the district court's finding that the EEOC charge did not encompass the February 2018 transfer, leaving an independent ground for affirmance. The court emphasized that arguments must be clearly articulated and supported, and the Appellants' failure to address the exhaustion issue was fatal to their appeal. Thus, the district court's decision was upheld. View "Oliveras-Villafane v. Baxter Healthcare SA" on Justia Law

Three former or current employees of Cross Country Staffing, Inc. (plaintiffs) filed a lawsuit against their employer, alleging various labor law violations. Upon hiring, each plaintiff signed two agreements: an Arbitration Agreement mandating arbitration for all employment-related claims and an Employment Agreement that included provisions favoring the employer, such as non-compete clauses and the right to seek injunctive relief in court without posting a bond.The Superior Court of Los Angeles County denied Cross Country Staffing's motion to compel arbitration, finding that the Arbitration Agreement, when read together with the Employment Agreement, was unconscionable. The court determined that the agreements were procedurally unconscionable due to their adhesive nature and substantively unconscionable because they unfairly favored the employer by allowing it to litigate its likely claims in court while forcing employees to arbitrate their likely claims. The court also noted the non-mutual attorney fees provisions and the employee's mandated concessions regarding injunctive relief.The California Court of Appeal, Second Appellate District, Division Five, affirmed the trial court's decision. The appellate court agreed that the two agreements should be read together under Civil Code section 1642, as they were part of the same transaction and related to the same subject matter. The court found significant substantive unconscionability in the agreements' imbalance of arbitration obligations and the employer's access to court for its claims. The court also upheld the trial court's refusal to sever the unconscionable provisions, concluding that the agreements' unconscionability permeated the entire arbitration framework and that refusing to enforce the Arbitration Agreement served the interests of justice. View "Silva v. Cross Country Healthcare, Inc." on Justia Law

Troy Grove and Vermilion Quarry, divisions of RiverStone Group, Inc., were found by the National Labor Relations Board (NLRB) to have violated the National Labor Relations Act (NLRA). The case involved seven employees at the two quarries, represented by the International Union of Operating Engineers, Local 150, AFL-CIO. The company was accused of unfair labor practices in bargaining over a pension fund and in its treatment of two employees.The NLRB ruled that the company had not bargained in good faith, declaring that the parties were not at an impasse and that the company had threatened to cease contributions to the pension fund. The company and the union both petitioned for judicial review, and the NLRB sought enforcement of its order. The company argued that the parties were indeed at an impasse after five years of negotiations and a three-year strike, and that the union's last-minute information request did not change this.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the NLRB's decision was not supported by substantial evidence and that the parties were at an impasse. The court noted that the union's denial of an impasse and its information request were insufficient to rebut the clear evidence of a deadlock. Consequently, the court vacated the NLRB's order regarding the pension fund issue.Regarding the treatment of the two employees, the NLRB had found that the company violated Section 8(a)(1) of the NLRA by issuing layoff notices shortly after the employees participated in union activities. The court upheld this part of the NLRB's decision, finding that the timing and circumstances of the layoff notices could reasonably be seen as coercive.The court granted the company's petition for review on the pension fund issue, vacated the relevant parts of the NLRB's order, denied the union's petition for review, and granted the NLRB's cross-application for enforcement in all other respects. View "Troy Grove v. NLRB" on Justia Law