Justia Labor & Employment Law Opinion Summaries

Matthew Bare sued his former employer, Rainforest Alliance, Inc., in the Superior Court of the District of Columbia, alleging that the company failed to pay him a redundancy settlement after his position was made redundant due to a reorganization. Bare claimed that he had agreed to resign in exchange for the settlement, which was contingent upon his execution of a release-of-claims agreement. However, after Bare made critical comments about the company, Rainforest Alliance terminated him and refused to pay the settlement, leading to claims of breach of contract and violation of the District of Columbia Wage Payment and Collection Law.The Superior Court dismissed Bare's complaint with prejudice, agreeing with Rainforest Alliance that Bare had failed to allege the occurrence of a condition precedent—specifically, the execution of a release agreement. The court found that without alleging this, Bare could not claim he had earned the redundancy payment under the contract or the wage law. Bare had argued that the issue of the condition precedent was a factual matter for summary judgment or trial and that Rainforest Alliance had waived the condition by not providing a release agreement. He also requested leave to amend his complaint if the motion to dismiss was granted.The District of Columbia Court of Appeals reviewed the case and held that the trial court should have granted Bare's request to amend his complaint. The appellate court found that Bare's request to amend was his first, the case had been pending for a short time, there was no evidence of bad faith or dilatory motives, and there was no prejudice to Rainforest Alliance. The court also determined that Bare's proposed amendment, which would include allegations that Rainforest Alliance waived the condition precedent by not providing a release agreement, was not futile. Consequently, the appellate court reversed the dismissal and remanded the case for further proceedings. View "Bare v. Rainforest Alliance, Inc." on Justia Law

Dominique Robison, a bus operator for the Washington Metropolitan Area Transit Authority (WMATA), was suspended from her job after bringing her own bottle of urine to a scheduled drug test, which was deemed an automatic failure under WMATA’s policy. She was suspended without pay for 180 days and subsequently filed for unemployment benefits, which were initially granted by the claims examiner due to WMATA's failure to provide evidence of misconduct.WMATA appealed to the Office of Administrative Hearings (OAH), where an administrative law judge (ALJ) found that Robison had committed simple misconduct, not gross misconduct, and was disqualified from benefits for the first eight weeks of her unemployment. The ALJ reasoned that Robison’s violation was her first drug-related offense and that WMATA’s decision to suspend rather than terminate her undercut the severity of the offense. The ALJ did not consider WMATA’s argument that Robison was ineligible for benefits because she was merely suspended, not terminated.WMATA then appealed to the District of Columbia Court of Appeals. The court reviewed whether the ALJ made findings of fact on each materially contested issue, whether substantial evidence supported each finding, and whether the ALJ’s conclusions flowed rationally from its findings. The court concluded that Robison’s actions did not rise to the level of gross misconduct, as there was no direct evidence of drug use or impairment, no demonstrable impact on passenger safety or WMATA’s operations, and it was her first offense. The court also determined that Robison was "unemployed" within the meaning of the statute because she was suspended without pay and did not work during the suspension period.The District of Columbia Court of Appeals affirmed the ALJ’s decision. View "WMATA v. Robison" on Justia Law

Travon Celey, a former employee of Children’s National Medical Center, was terminated on March 1, 2022, for accumulating six instances of tardiness within a twelve-month period. Celey subsequently applied for unemployment benefits, but a claims examiner from the District of Columbia Department of Employment Services (DOES) disqualified him, citing gross misconduct due to repeated tardiness following warnings.Celey appealed the decision to the Office of Administrative Hearings (OAH). Despite filing the appeal well beyond the fifteen-day deadline, OAH extended the deadline due to good cause and excusable neglect. During the hearing, the Hospital presented evidence and testimony showing that Celey had been warned and suspended for his tardiness, referencing both the independent Attendance Policy and the collective bargaining agreement (CBA) policy. The CBA policy mandated termination after the sixth instance of tardiness, while the independent Attendance Policy allowed for termination only after the eighth instance.The OAH administrative law judge (ALJ) found that the Hospital had issued inconsistent rules, failing to clearly notify Celey of the specific policy that applied to him. The ALJ concluded that Celey did not willfully violate the Hospital’s expectations and was therefore qualified to receive unemployment benefits.The District of Columbia Court of Appeals reviewed the case and affirmed the OAH decision. The court held that substantial evidence supported the ALJ’s finding that Celey was not adequately informed about the CBA policy, which was crucial for determining his eligibility for unemployment benefits. The court emphasized that the issue was whether Celey was on notice that his conduct could lead to termination, not whether the Hospital was justified in terminating him. View "Children's National Medical Center v. Celey" on Justia Law

Samuel Murray, a motor-vehicle operator for the District of Columbia Department of Youth Rehabilitation Services (DYRS), was wrongfully terminated after taking leave due to an injury sustained at work. In September 2020, DYRS was ordered to reinstate Mr. Murray and awarded him back-pay with benefits. Mr. Murray did not initially request interest on the back-pay. In February 2021, he petitioned the Office of Employee Appeals (OEA) to reopen his case for enforcement of the back-pay and benefits, which had not yet been provided, and for the first time sought accrued interest on the back-pay.The OEA Administrative Judge (AJ) ruled that OEA had the authority to award interest on back-pay and ordered DYRS to pay Mr. Murray prejudgment interest. DYRS sought review in the Superior Court, which reversed the AJ's decision, holding that the AJ did not have jurisdiction to grant interest on the back-pay award. The Superior Court reasoned that the AJ's jurisdiction was limited to correcting the record, ruling on attorney fees, or processing enforcement petitions, and Mr. Murray's request for prejudgment interest fell outside these parameters.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court's judgment. The court held that D.C. Code § 1-606.03(c) clearly precluded Mr. Murray's belated request for prejudgment interest, as it was made over three months after the back-pay award became final and did not fall within the AJ's limited post-award jurisdiction. The court also noted that it did not address whether OEA has the authority to award prejudgment interest when timely requested or whether post-judgment interest could be part of enforcing an award not promptly paid. View "Murray v. District of Columbia Dep't of Youth and Rehabilitation Services" on Justia Law

A national news reporter employed by a prominent newspaper sued her employer and six of its editors in Superior Court, alleging violations of the D.C. Human Rights Act and the common law tort of negligent infliction of emotional distress. She claimed that the defendants discriminated against her based on her status as a sexual assault victim and her gender, took adverse employment actions against her, subjected her to a hostile work environment, and retaliated against her for protesting their discriminatory actions.The defendants moved to dismiss the complaint under Superior Court Civil Rule 12(b)(6) for failure to state a claim and filed a special motion to dismiss under the D.C. Anti-SLAPP Act, arguing that the claims arose from acts in furtherance of the right of advocacy on issues of public interest. The Superior Court denied the special motion to dismiss, finding that the claims did not arise from speech protected by the Anti-SLAPP Act, but granted the Rule 12(b)(6) motion, concluding that the complaint failed to plausibly allege unlawful discrimination or retaliation.The District of Columbia Court of Appeals reviewed the case and affirmed the denial of the special motion to dismiss, agreeing that the Anti-SLAPP Act did not apply. The court reversed the dismissal of the counts alleging adverse action discrimination, finding that the complaint plausibly alleged that the defendants took certain adverse employment actions against the reporter in violation of the Human Rights Act. However, the court affirmed the dismissal of the hostile work environment and retaliation claims, concluding that the allegations did not meet the necessary legal standards. The court also noted that it was premature to decide whether the defendants' actions were protected by the First Amendment, leaving that issue open for further proceedings. View "Sonmez v. WP Company, LLC" on Justia Law

Dennis Neal, a heating, ventilation, and air conditioning technician at Howard University Hospital, was injured on the job when a ladder gave way beneath him. He experienced pain and underwent spinal surgery. After attempting to return to work and experiencing further pain, he quit and sought reinstatement of his disability benefits and vocational rehabilitation services. The hospital terminated his benefits when he accepted new employment but quit after four days due to physical discomfort from long drives and job duties.An Administrative Law Judge (ALJ) granted Neal's claim for reinstatement of benefits and services, and the Compensation Review Board (CRB) affirmed. The hospital appealed, arguing that the CRB lacked substantial evidence to support its findings that Neal did not voluntarily limit his income and did not fail to cooperate with vocational rehabilitation. The hospital contended that the ALJ and CRB ignored critical testimony from witnesses.The District of Columbia Court of Appeals reviewed the case and found that the CRB's decision was supported by substantial evidence. The court noted that the ALJ's findings were based on credible evidence, including medical evaluations and Neal's testimony about his physical limitations and the nature of the job duties at his new employment. The court also found that Neal had cooperated with vocational rehabilitation services and had demonstrated a willingness to continue doing so.The court held that the CRB's decision flowed rationally from the facts and was supported by substantial evidence. The court affirmed the CRB's decision to reinstate Neal's temporary total disability benefits and vocational rehabilitation services. View "Howard University Hospital v. D.C. Department of Employment Services" on Justia Law

Leroy Williams, a special police officer with the D.C. Department of General Services (DGS), was terminated in August 2019 for conduct related to unauthorized traffic stops. He was given three options to appeal: filing an appeal with the Office of Employee Appeals, having his union (Fraternal Order of Police, FOP) file a grievance, or filing a grievance personally. Williams chose the second option, and FOP filed a grievance on his behalf. When the grievance could not be settled, it was advanced to arbitration, where the arbitrator upheld Williams's termination.FOP then sought review from the Public Employee Relations Board (PERB), which upheld the arbitrator's decision. FOP subsequently petitioned the Superior Court of the District of Columbia for review, which affirmed PERB's decision. After FOP's counsel withdrew, Williams filed an appeal to the District of Columbia Court of Appeals on his own.The District of Columbia Court of Appeals reviewed whether Williams had standing to bring the appeal. The court noted that the collective bargaining agreement granted the union the sole authority to arbitrate grievances and, consequently, the sole authority to appeal arbitration decisions. The court found that Williams lacked standing to appeal because only the union could pursue such an appeal unless the union breached its duty of fair representation, which was not argued in this case.The court dismissed Williams's appeal for lack of standing, concluding that he could not independently challenge the arbitration award under the terms of the collective bargaining agreement. View "Williams v. Department of General Services" on Justia Law

Appellant Yvonne Gant sued The Lynne Experience LTD (TLE) and Giant Foods, LLC (Giant) for negligence after allegedly being struck and injured by a golf cart operated by a TLE employee. Gant claimed that TLE and Giant failed to properly train and supervise their employees, leading to her injuries. TLE moved to dismiss the case, arguing that the District of Columbia’s Workers’ Compensation Act (WCA) provided Gant’s exclusive remedy, thus removing the court’s jurisdiction over the matter. The Superior Court agreed, dismissing Gant’s claims against TLE with prejudice, and later granted summary judgment in favor of Giant, finding no employer-employee relationship that could support Gant’s negligence claim.The Superior Court determined that the WCA provided Gant’s exclusive remedy and that the District of Columbia Department of Employee Services (DOES) had primary jurisdiction over her claims. The court dismissed Gant’s claims against TLE with prejudice, reasoning that any claim under the WCA would be time-barred. Subsequently, the court granted summary judgment for Giant, based on undisputed evidence that Giant was merely a sponsor of the event and had no role in managing or supervising the staff involved.On appeal, Gant argued that TLE failed to secure payment of compensation as required by the WCA and that she should be allowed to maintain her civil action. Alternatively, she requested a stay to present her claim to DOES. The District of Columbia Court of Appeals agreed that the WCA appeared to provide Gant’s exclusive remedy but held that the Superior Court should have dismissed her claim without prejudice. The court affirmed the summary judgment in favor of Giant, noting that Gant failed to present any arguments against it on appeal.The main holding by the District of Columbia Court of Appeals was that the Superior Court should have dismissed Gant’s claim against TLE without prejudice, allowing her the opportunity to pursue her claim with DOES. The court affirmed the summary judgment for Giant, as there was no evidence to support an employer-employee relationship necessary for Gant’s negligence claim. View "Gant v. The Lynne Experience, LTD" on Justia Law

Two employees sued their employers, alleging underpayment for work at a restaurant due to improper wage deductions for meal breaks. The employers deducted thirty minutes twice daily for breakfast and lunch breaks, but the employees claimed their breaks lasted only ten to fifteen minutes each.The Superior Court of the District of Columbia held a bench trial and found in favor of the employers, concluding that the breaks lasted at least twenty minutes. The court based its decision on the credibility of the employees' testimony and other evidence, including testimony from another employee and the restaurant's rules. The employees appealed, arguing that the trial court's findings were clearly erroneous and that the breaks should have been classified as compensable rest periods.The District of Columbia Court of Appeals reviewed the case and determined that the trial court had clearly erred in its evaluation of the employees' credibility and the evidence. The appellate court noted that the trial court misunderstood key aspects of the employees' testimony and other evidence. Consequently, the appellate court vacated the trial court's judgment and remanded the case for further examination of the evidence.The appellate court did not decide whether the breaks should be classified as rest periods, as this determination depends on the length of the breaks, which the trial court must reassess on remand. The burden of proof remains on the employees to demonstrate that their meal breaks were compensable. View "Sanchez v. Sundely" on Justia Law

Christian Greene, the Ombudsman for the District of Columbia Child & Family Services Agency (CFSA), was terminated from her position and subsequently filed a lawsuit against the District, claiming her termination violated the District of Columbia Whistleblower Protection Act (WPA). Greene argued that her termination was in retaliation for her disclosures about CFSA's non-compliance with the Foster Youth Statements of Rights and Responsibilities Amendment Act of 2012 (FYAA).The Superior Court of the District of Columbia granted summary judgment in favor of CFSA, concluding that Greene's disclosures were merely policy disagreements about the role of the Ombudsman and not protected under the WPA. The court did not address whether Greene reasonably believed her disclosures revealed unlawful activity or whether there was a causal connection between her disclosures and her termination.The District of Columbia Court of Appeals reviewed the case and found that Greene's disclosures were indeed protected under the WPA. The court held that Greene reasonably believed her disclosures revealed violations of the FYAA, which required CFSA to report on the outcomes of investigations and ensure compliance with relevant laws. The court noted that Greene's belief was genuine and reasonable, given the evidence she provided and the context of her role.The Court of Appeals reversed the trial court's grant of summary judgment in part and remanded the case for further proceedings. The trial court was instructed to determine whether there is a genuine dispute of material fact regarding whether Greene's WPA-protected disclosures were a cause of her termination. View "Greene v. D.C. Child & Family Services Agency" on Justia Law