Justia Labor & Employment Law Opinion Summaries

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Mathews worked for Happy Valley Conference Center in the Santa Cruz Mountains. Valley is an affiliate of the Community of Christ. When a younger male employee confided in Mathews that Valley’s female executive director had been sending him sexually inappropriate text messages, Mathews reported the allegation to the board of directors and the Church’s general counsel. The director admitted sending the messages, was reprimanded, and was allowed to continue supervising Mathews and the younger male employee. Mathews, terminated less than a month later, alleged retaliatory termination. Defendants were ordered to pay almost $900,000 in damages (including punitive damages) and $1 million in attorney’s fees. The court of appeal affirmed, rejecting arguments that the Church cannot be held liable for Valley’s actions because the two do not fall within the single employer doctrine and that the single employer doctrine jury instruction was prejudicially erroneous; that Valley is not liable under Title VII, 42 U.S.C. 2000, because it does not have enough full-time employees; that defendants are not liable under the version of the whistleblower statute in effect at the time of the events; that the evidence was insufficient to establish that the Church breached Mathews's implied or actual contract; that the Title VII damages were beyond the maximum allowed; that noneconomic and punitive damages were not recoverable for breach of contract; that punitive damages were excessive; and that attorney’s fees were not recoverable. The judgment must be modified to reflect that defendants are exempt from liability under the California Fair Employment and Housing Act, Gov. Code, 12900. View "Mathews v. Happy Valley Conference Center, Inc." on Justia Law

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In 2002 or 2003, Sonoma County authorized increased pension benefits for County employees, pursuant to a settlement of employee lawsuits alleging past miscalculation of retirement benefits. In doing so, the County failed to comply with state laws requiring local legislative bodies to obtain an actuarial statement of the future annual costs of proposed pension increases and to make the future annual costs public at a public meeting, before authorizing the pension increases, Gov. Code 7507, 23026, 31515.5, 31516. In 2017, Plaintiff, a county resident and taxpayer filed a mandamus petition, alleging those violations and seeking to enjoin payment of the increased pension benefits. The trial court dismissed, finding the claim barred by the statute of limitations. The court of appeal affirmed., holding that the continuous accrual doctrine does not trigger a new limitations period every time retirement benefits are paid pursuant to the increased pension benefits approved in 2002 and 2003. Neither delayed discovery nor estoppel applies to toll the statute of limitations. View "Luke v. Sonoma County" on Justia Law

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Bile Salat appealed the discontinuation of his disability benefits. In 2016, Salat slipped and fell at work. On March 31, 2016, WSI accepted liability for a contusion of the lower back and pelvis and a right ankle sprain. By November 2016, an independent medical examination revealed Salat's ankle injury had not healed and was not at pre-injury status, but low back pain was unrelated to the work injury. Salat's personal physician reviewed the IME's opinion and did not have any "objective findings on physical exam to challenge or disagree with his medical opinion." On August 5, 2016, WSI issued an order discontinuing Salat’s disability benefits after June 29, 2016. On December 15, 2016, WSI issued a notice of decision denying further benefits of Salat’s lumbar spine after November 11, 2016. The North Dakota Supreme Court reversed the discontinuation of benefits, finding Salat's physician's statement was misunderstood by the district court as a "blanket agreement" with the independent medical examiner: Salat's physician's "statement is better understood as stating she had no objective findings on physical exam to challenge or disagree with [the IME] opinion regarding the source of Salat’s back pain." On this record, the Supreme Court surmised the ALJ could have reasonably found the two physicians had conflicting medical opinions on the source of continued back pain, and that a "reasoning mind reasonably could determine" Salat suffered low back pain after November 11, 2016 that was attributable to the compensable work injury. View "WSI v. Salat, et al." on Justia Law

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Robert Sheffield was injured on the job while working for S.J. Louis Construction (S.J. Louis). Sheffield filed a petition to contravert, and the administrative law judge (AJ) awarded Sheffield permanent-partial disability benefits. S.J. Louis appealed the decision to the full Mississippi Workers’ Compensation Commission (Commission), and the Commission reversed this finding, concluding that Sheffield did not suffer any additional disability from the 2015 injury than that caused by a 2010 injury. Sheffield appealed, and the Court of Appeals reversed the Commission’s decision. S.J. Louis filed a petition for writ of certiorari with the Mississippi Supreme Court. Because the Supreme Court found, after review, that the Commission’s decision was supported by substantial evidence, it reinstated and affirmed that decision. View "Sheffield v. S.J. Louis Construction Inc." on Justia Law

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The Ninth Circuit reversed the district court's approval of a settlement notice process and a class action settlement, negotiated without a certified class, in a case arising out of a dispute under federal and California labor law regarding whether exotic dancers working at various nightclubs in San Francisco were misclassified as independent contractors rather than being treated as employees. The panel held that the settlement notice did not meet Federal Rule of Civil Procedure 23's "best notice that is practicable under the circumstances" standard. The panel also held that the district court abused its discretion in approving the settlement, because the district court applied an incorrect legal standard and failed to employ the heightened scrutiny required to meet the strict procedural burden the panel imposed for assessing class settlements negotiated prior to class certification. The panel also reversed the district court's award of attorneys' fees, and remanded for further proceedings. View "Murphy v. SFBSC Management" on Justia Law

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The Supreme Judicial Court held that Congress intended the Federal Volunteer Protection Act (VPA), 42 U.S.C. 14503(a), to provide qualified immunity from suit for officers in nonprofit organizations who receive no compensation, that the state charitable immunity statute, Mass. Gen. Laws ch. 231, 85W, may only expand the scope of that immunity and that Defendant, as a volunteer for a nonprofit organization, was entitled to interlocutory review of the denial of his motion for summary judgment. After a company was dissolved, Plaintiffs, former employees of Company, brought suit against Defendant, alleging that, as the company's president, he was among the employers who had violated the Wage Act, Mass. Gen. Laws ch. 149, 148, by failing to pay them the wages they were due. Defendant moved for summary judgment, arguing that even if he were the company's president, he served without compensation and was thus immune from suit under the VPA and section 85W. The superior court denied the motion. The Supreme Judicial Court affirmed, holding that there were genuine issues of material fact as to whether Defendant was placed outside of the immunity otherwise provided by section 85W. View "Lynch v. Crawford" on Justia Law

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A collective bargaining agreement between Local 1982 and Midwest consisted of a Master Agreement (MA), formed between the parties’ affiliated regional employer group and the union, and a Local Agreement. The union filed a grievance for Midwest's failure to establish and contribute to benefit trust plans under MA Section 5.5A. Midwest responded that it considered the grievance procedurally invalid. The Union escalated the grievance to Step Two under the MA, referral to a Joint Grievance Committee comprised of an employer representative and a union representative. Midwest refused to participate; the hearing went forward without Midwest. The Committee determined that Midwest had failed to comply with Section 5.5A. Midwest did not appeal the unfavorable award, which became final. The union filed suit to enforce it. The Sixth Circuit directed the district court to enforce the award. The parties returned to court over ambiguities in the award's content. The Sixth Circuit affirmed a remand to the Committee, rejecting Midwest’s argument that it complied with the award by negotiating about terms of the trust agreement. After the remand but before clarification of the award, the composition of the two-person Committee changed. The new Committee deadlocked. Local 1982 sought to escalate the grievance to Step 3 with an expanded grievance committee. The Sixth Circuit agreed. The award did not lose its effect simply because the original Committee cannot agree on clarification of its contents. Grievance procedure Step Three specifies that if a grievance “is not satisfactorily settled or adjusted in Step 2, it shall be referred to an Expanded Joint Grievance Committee.” View "Local 1982, International Longshoremen v. Midwest Terminals of Toledo" on Justia Law

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After the Board found that the company violated Sections 8(a)(1) and 8(a)(3) of the National Labor Relations Act by suspending and discharging one of its employees, the company petitioned for review. The DC Circuit granted the petition for review, denied the Board's application for enforcement of its order as it related to the employee, and held that, although the Board was not obliged to agree with either the judge or its dissenting member, the Board was obligated to confront evidence detracting from its conclusions, particularly where the dissenting member has offered a nonfrivolous analysis. The court held that the Board failed to adequately explain the basis of its disagreement with the ALJ and took action against the company without the support of substantial evidence. In this case, the Board's decision relating to the company's suspension and discharge of the employee, the Board's conclusion regarding the significance of the post-discharge investigations, and the Board's disparate treatment finding were all unsupported by substantial evidence. View "Windsor Redding Care Center, LLC v. NLRB" on Justia Law

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Plaintiff filed suit against her former employer for retaliation under the False Claims Act. The Fifth Circuit affirmed the district court's grant of summary judgment to the employer. Under the totality of the circumstances and in the light most favorable to plaintiff, the court found that she failed to create a genuine dispute as to whether she would have been fired but for the employer's retaliation. The court held that plaintiff failed to establish that the stated reason for her termination -- her position was eliminated as unnecessary -- was pretext for retaliation. View "Musser v. Paul Quinn College" on Justia Law

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The Eighth Circuit affirmed the employer's motion for summary judgment in an action brought by plaintiff, a former employee, alleging gender-based discrimination. The court held that summary judgment was appropriate where, assuming his assertions were true, none of plaintiff's purported direct evidence established the required specific link between his termination and gender-based animus; plaintiff failed as a matter of law to provide sufficient evidence to give rise to a jury question on the issue of disparate treatment; and any error in declining to consider plaintiff's direct evidence argument was harmless. View "Rinchuso v. Brookshire Grocery Co." on Justia Law