Justia Labor & Employment Law Opinion Summaries

Articles Posted in Arkansas Supreme Court
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The Supreme Court reversed the judgment of the Arkansas Workers' Compensation Commission denying Appellant's claim for additional medical benefits, holding that the Commission erred in determining that Appellant's claim for additional medical benefits was barred by the statute of limitations.In 2015, Appellant was injured while working for Liberty Trailer and sustained a compensable right-shoulder injury. In 2019, Appellant requested additional benefits. An administrative law judge found that the claim was barred by the statute of limitations. The Commission affirmed. The Supreme Court reversed, holding that, under a plain reading of Ark. Code Ann. 11-9-702(b)(1), Appellant's claim for additional medical benefits was timely. View "Wynne v. Liberty Trailer" on Justia Law

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The Supreme Court reversed the order of the circuit court granting a preliminary injunction in favor of Plaintiffs, holding that the grounds on which the trial court relied in entering the preliminary injunction had become moot.Plaintiffs were five Arkansas residents who had been receiving pandemic-related unemployment benefits through Pandemic Unemployment Assistance, Federal Pandemic Unemployment Compensation, and Pandemic Emergency Unemployment Compensation prior to the State's termination of its participation in these programs. Plaintiffs sought declaratory and injunctive relief, alleging that Defendants - Governor Asa Hutchison and Arkansas Division of Workforce Services Director Charisse Childers - lacked the authority under Ark. Code Ann. 11-10-312 to terminate the State's participation in the programs. The trial court granted Plaintiffs' motion for a preliminary injunction ordering Defendants to reengage in the terminated programs. The Supreme Court reversed, holding that the grounds for the preliminary injunction had been rendered moot by the General Assembly's passage of Act 1 of the First Extraordinary Session of 2021. View "Hutchinson v. Armstrong" on Justia Law

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The Supreme Court affirmed the order of the circuit court that denied Appellant's request for injunctive relief preventing the University of Arkansas for Medical Sciences (UAMS) from terminating his employment and dismissing Appellant's complaint, holding that the relief sought in this complaint was moot.After Appellant, a former tenured professor at UAMS, was terminated he sought an injunction. UAMS moved to dismiss the complaint, arguing that Appellant's claim was moot and that UAMS was immune from suit. The circuit court denied Appellant's request for injunctive relief and dismissed the case with prejudice. The Supreme Court affirmed, holding that Appellant's claims were moot, and therefore, dismissal was appropriate. View "Mahadevan v. Board of Trustees of University of Arkansas System" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Plaintiff's employment discrimination complaint against Mercy Hospital Rogers, holding that the circuit court erred in dismissing Plaintiff's claim under the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-101 to -108.Specifically, the Supreme Court held (1) Plaintiff failed to plead that Mercy made any false representations of material fact sufficient to sustain a fraud action; (2) because Plaintiff failed to state an exception to the at-will doctrine, the circuit court properly dismissed Plaintiff's wrongful termination claim; and (3) given the circuit court's lack of factual development on the issue, the Supreme Court cannot determine whether Mercy is a religious organization entitled to the ACRA religious-organization exemption, and therefore, remand was required. View "Jenkins v. Mercy Hospital Rogers" on Justia Law

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The Supreme Court reversed the decision of the Arkansas Workers' Compensation Commission that Appellant was not entitled to a wage-loss award in addition to his impairment rating because Area Agency on Aging of Southeast Arkansas (AAA) extended to him a bona fide offer of employment, holding that substantial evidence did not support the Commission's decision.Appellant was driving an AAA van that overturned, injuring Appellant. An ALJ determined that Appellant was entitled to a sixty percent wage-loss award and that Appellees made no bona fide job offer of employment because the position and wages were not clear. The Commission reversed, concluding that any wage-loss award was precluded because AAA made a bona fide and reasonable obtainable job offer. The Supreme Court reversed, holding that AAA did not meet its burden to prove that Appellant was offered employment at wages equal to or greater than his average weekly wage at the time of the accident. View "Calhoun v. Area Agency on Aging of Southeast Arkansas" on Justia Law

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The Supreme Court granted a petition for a writ of prohibition filed by Petitioners - Respondent's employer, its corporate parent, and a fellow employee - asking the court to dismiss Respondent's declaratory judgment action because declaratory judgment would be improper on the facts, holding that the circuit court lacked jurisdiction to hear this petition.Respondent was injured in a workplace accident and received workers' compensation benefits because of his injuries. Respondent brought this declaratory judgment action, arguing that the petition was necessary to establish the legal relations between the parties. Petitioners filed this petition for writ of prohibition arguing that the Workers' Compensation Commission held exclusive jurisdiction for any claims Respondent had against his employers. The Supreme Court granted the writ, holding that Respondent's remedies against his employer were those outlined under the Workers' Compensation Act. View "Esterline Technologies Corp. v. Brownlee" on Justia Law

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The Supreme Court affirmed the order of the circuit court granting summary judgment to Professional Background Screening Association, Inc. (PBSA) on PBSA's claim pursuant to the Arkansas Freedom of Information Act (FOIA) and partial summary judgment to Jennifer Jones, the Clerk of the District Court of Benton County, Arkansas, Bentonville Division, holding that the circuit court did not err.PBSA, a nonprofit trade association, filed a complaint against Jones alleging that Jones erred in applying Arkansas Supreme Court Administrative Order Number 19 to PBSA members who request court records to perform background checks in a manner that violated their right to access court records and, instead, PBSA members' requests for court records are governed by the Arkansas Freedom of Information Act. The circuit court granted partial summary judgment in favor of PBSA on its FOIA claim and granted Jones's motion for summary judgment on PBSA's claims alleging that Order 19, as applied by Jones, violated PBSA members' right to access court records under the First Amendment and/or federal common law. The Supreme Court affirmed, holding that the circuit court did not err. View "Jones v. Professional Background Screening Ass'n" on Justia Law

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The Supreme Court affirmed the order of the circuit court granting class certification of Plaintiffs' complaint, holding that the circuit court did not abuse its discretion in certifying the class.Plaintiffs were hourly employees of Koppers, Inc. Plaintiffs filed this action against Koppers alleging that Koppers did not pay them for working overtime in violation of the Arkansas Minimum Wage Act (AMWA), Ark. Code Ann. 11-4-211(a). Plaintiffs filed a motion to certify a class. The circuit court granted the motion. Koppers appealed, arguing that its liability could not be established on a classwide basis because whether a plaintiff could recover depended on individualized facts. The Supreme Court affirmed, holding that the circuit court's findings on commonality, predominance, and superiority were not in error. View "Koppers, Inc. v. Trotter" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Appellant's action against Baptist Health appellees and John Hearnsberger, M.D., holding that the circuit court abused its discretion in denying Appellant's motions to compel production of two types of disputed discovery.Appellant, a surgeon, was on the medical staff of Baptist Health from 2003 until 2011, when his appointment and clinic privileges at Baptist Health Medical Center-Little Rock were terminated, effective immediately. Baptist Health also reported the suspension of Appellant's clinical privileges to the Arkansas State Medical Board, which, in 2014, revoked Appellant's license. Appellant appealed the revocation, and his license was reinstated. In 2011, Appellant filed a lawsuit against Baptist Health and several individuals, asserting several claims. The circuit court entered a consent order dismissing the Medical Board and Dr. Hearnsberger in his official capacity. The circuit court then granted summary judgment on Appellant's remaining claims. The Supreme Court reversed in part, holding that the circuit court abused its discretion in denying Appellant's motions to compel production of two types of discovery, and the discovery error was not harmless as to Appellant's discrimination and tortious-interference claims. View "Williams v. Baptist Health" on Justia Law

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The Supreme Court reversed the vacated the opinion of the court of appeals affirming the decision of the Arkansas Workers' Compensation Commission affirming and adopting the findings of the administrative law judge (ALJ) awarding an additional-benefits claim to Bruce Menser, holding that Menser's additional-benefits claim was time barred by the statute of limitations.At the time Menser requested a hearing before the Commission, he was receiving workers' compensation benefits. The ALJ found that Menser sustained compensable brain and neuropathy injuries during the course and scope of his employment and that the statute of limitations did not bar Menser's claim for additional medical benefits because it had been tolled. The Commission affirmed and adopted the ALJ's decision. The court of appeals affirmed. The Supreme Court reversed, holding that the Commission erred in determining that Menser's claim for additional medical benefits sufficiently tolled the statute of limitations, and to the extent that Arkansas case law does not comport with this holding, those cases are overruled. View "White County Judge v. Menser" on Justia Law