Justia Labor & Employment Law Opinion SummariesArticles Posted in Indiana Supreme Court
Fayette County Bd. of Comm’rs v. Price
Howard Price was the Fayette County Highway Supervisor from 1991 to 2002 and again resumed the position in 2006. In 2011, the Fayette County Board of Commissioners decided not to reappoint Price as Highway Supervisor. Thereafter, Price brought this action requesting a review of the Board’s decision to terminate his continued employment. The Board filed a motion to dismiss, which the trial court treated as a motion for summary judgment, asserting that its employment decision was not subject to judicial review. The trial court denied summary judgment, concluding that the Board’s decision was quasi-judicial in nature and thus subject to judicial review. The court of appeals affirmed on interlocutory appeal. The Supreme Court reversed, holding that the Board’s employment decision with respect to Price was a ministerial decision, not a quasi-judicial one, and therefore not subject to judicial review. View "Fayette County Bd. of Comm'rs v. Price" on Justia Law
Comm’r of Labor v. Int’l Union of Painters & Allied Trades AFL-CIO, CLC Dist. Council 91
In 2008, Stephen and Edward were beaten in Union elections and lost their positions. Deborah, Edward's wife, was a clerical employee and voluntary member of the Union, but the business manager/secretary-treasurer terminated Deborah's employment as well. Deborah, Stephen, and Edward all sued the Union to recover compensation for unused accrued vacation pay. The trial court granted summary judgment for the Union. The Supreme Court (1) affirmed the trial court's decision as to Edward and Stephen's claims, holding that because the Union bylaws clearly addressed the compensation, including vacation pay, of its elected officers, the Union was the sole arbiter of disputes arising under its governing documents; and (2) reversed summary judgment against Deborah's claim, holding (i) Deborah, as an employee, was entitled to accrue vacation pay unless there was an arrangement or policy to the contrary; and (ii) there was an issue of material fact as to whether an arrangement or policy regarding vacation time existed during Deborah's employment. Remanded. View "Comm'r of Labor v. Int'l Union of Painters & Allied Trades AFL-CIO, CLC Dist. Council 91" on Justia Law
Berry v. Crawford
After certain members of the Indiana House of Representatives Democratic Caucus left the state to prevent the formation of a quorum in order to block a vote on impending legislation, House Republicans passed motions to fine the absent legislators. The fines were withheld from the legislators' pay. Plaintiffs brought suit seeking to recover the withheld pay. The trial court concluded that the determination of the fine was outside the court's jurisdiction because the determination of the fine was within the House's "exclusive constitutional authority" but that review of the collection of fines was within the court's jurisdiction. The court then ordered return of the withheld pay and issued an injunction preventing future withholding. The Supreme Court reversed, holding that when, as here, the Indiana Constitution expressly assigns certain functions to the legislative branch without any contrary constitutional limitation or qualification, disputes arising in the exercise of such legislative powers are nonjusticiable, and the doctrine of separation of powers precludes judicial consideration of the claims for relief. Remanded for dismissal of Plaintiffs' claims for lack of justiciability. View "Berry v. Crawford" on Justia Law
Walczak v. Labor Works – Fort Wayne LLC
Plaintiff successfully applied for employment at Labor Works, received job assignments an paychecks, and was never fired or laid off. Plaintiff later filed a class action lawsuit against Labor Works under the Indiana Wage Payment Act seeking to recover unpaid wages. Labor Works moved for summary judgment, arguing that day laborers like Plaintiff were involuntarily separated from the payroll at the end of every shift and thus were required to proceed under the Wage Claims Act. The trial court granted Labor Works's motion and dismissed Plaintiff's claim. The Supreme Court reversed, holding that because Plaintiff had a reasonable expectation of continuing to receive job assignments from Labor Works on the day she filed her claim, she was not separated from the payroll for the purpose of the Wage Claims Act, and therefore, Plaintiff could proceed with her claim under the Wage Payment Act. View "Walczak v. Labor Works - Fort Wayne LLC" on Justia Law
Haegert v. Univ. of Evansville
An encounter between a tenured professor at a private university and his department head turned into a formal complaint of harassment against the professor. After extensive internal proceedings, the professor's tenure was rescinded and he was dismissed from the university's faculty. The professor filed suit claiming breach of his employment contract and tenure agreement. The trial court granted summary judgment in favor of the university. The Supreme Court affirmed the decision of the trial court, holding (1) the professor's conduct constituted harassment under the terms of his employment contract such that the university could dismiss him; (2) the university did not deny the professor the procedural entitlements afforded under the professor's employment contract's terms; and (3) the university did not deprive the professor of due process. View "Haegert v. Univ. of Evansville" on Justia Law
J.M. v. Review Bd. of Ind. Dep’t of Workforce Dev.
Employer allowed Employee to take a college class during his normal work hours but informed him he would have to use his vacation, compensation, or unpaid time rather than take shorter lunches, come in early, or stay later. Employee enrolled in the class but did not follow Employer's instructions and failed properly to account for his time off. Consequently, Employee was fired and denied unemployment benefits. An ALJ overturned that decision and granted Employee unemployment benefits, concluding that the discipline was too severe for only a small amount of misreported time. The review board of the department of workforce development upheld the original denial of unemployment benefits, finding that J.M. was discharged for just cause and thus ineligible for unemployment benefits. The Supreme Court affirmed the review board's denial of benefits, holding that the findings of fact by the review board showed Employee violated his supervisor's instructions and the employee handbook, which were statutory grounds for just-cause discharge. View "J.M. v. Review Bd. of Ind. Dep't of Workforce Dev." on Justia Law
Shepherd Props. Co. v. Int’l Union of Painters & Allied Trades
In this case, Plaintiff prevailed on its Access to Public Records Act (Act) claim against a public agency and an intervening private party. As required by statute, the trial court awarded Plaintiff attorney's fees. The fees were awarded against both the public agency and the intervening private party, jointly and severally. The private party argued that the Act does not contemplate the award of attorney's fees against an intervening private party and that only the public agency should be liable for the fees. The Supreme Court affirmed the trial court's award of attorney's fees to Plaintiff, holding (1) the Act, in light of the legislature's liberal-construction mandate and the statute's underlying policy, permits the award of attorney's fees against an intervening private party; and (2) in this case, the trial court did not abuse its discretion in its apportionment of liability. View "Shepherd Props. Co. v. Int'l Union of Painters & Allied Trades" on Justia Law
Loparex, LLC v. MPI Release Techs., LLC
Stephan Odders and Gerald Kerber were former employees of Loparex, a corporation in the release liner industry. Both employees were subject to a one-year noncompetition agreement upon termination of employment. After ceasing employment at Loparex, both employees began employment with MPI Release Technologies, a competitor in the release liner industry. Loparex sued Kerber and Odders (Defendants) in the U.S. district court, seeking injunctive relief under the Illinois Trade Secrets Act and damages resulting from Defendants' breach of the noncompetition agreement. Defendants filed amended answers and counterclaims accusing Loparex of blacklisting in violation of Indiana law. The Supreme Court accepted certification to answer questions of state law and held (1) Wabash Railroad Co. v. Young, which held that Indiana's Blacklisting Statute did not provide a cause of action to individuals who voluntarily leave their employment, is no longer good law and individuals who voluntarily leave employment are not barred from making a claim under the Blacklisting Statute; (2) attorney fees are not an element of compensatory damages under the Blacklisting Statute; and (3) an employer's suit against a former employee to protect trade secrets is not a basis for recovery under the Blacklisting Statute.
Thatcher v. City of Kokomo
The City of Kokomo terminated the employment of Mark Thatcher, a police officer, after Thatcher sustained a knee injury in the line of duty. Thatcher was a member of the 1977 Fund, a disability and pension fund for police officers. Thatcher began receiving disability benefits subsequent to his injury. After Thatcher's knee was repaired, he sought reinstatement to active duty. The City decided not to reinstate Thatcher, who was fifty years of age and had completed four years of service in the police department, based on Ind. Code 36-8-4-7(a). Thatcher brought claims in federal district court against the City and Kokomo Police Department (KPD) under the Age Discrimination in Employment Act and Americans with Disabilities Act. The Supreme Court accepted certification and held that the City correctly determined that Thatcher was statutorily prohibited from returning to the KPD, as (1) section 36-8-4-7(a) applies to a member of the 1977 Fund who is receiving disability benefits and who has been determined to have been recovered; and (2) the time period during which a person receives disability benefits does not count toward "years of service" as that term is used in section 36-8-4-7(a).
Richmond State Hosp. v. Brattain
For over twenty-five years, the State required certain employees to work forty-hour weeks while requiring other employees to work only 37.5-hour weeks. Through the employees received the same biweekly paycheck, the effect of the State's policy was a disparity in actual hourly wage. The State ended the policy in 1993, but this class action was brought on behalf of those forty-hour employees. The court of appeals found (1) the merit employees were owed back pay on their statute-base claims from the day they filed their complaint or grievances until the day the State eliminated its split-pay system; and (2) the non-merit employees were owed back pay on their constitutional claims from the day the State eliminated its split-pay system and extending back approximately twenty years. The Supreme Court affirmed in part and reversed in part, holding that, under the doctrine of laches, the back pay recovery of the non-merit employees should be limited in the same manner as the court of appeals set forth for that of the merit employees.