Justia Labor & Employment Law Opinion Summaries

Steve L. Michaud sustained a traumatic injury to his left eye on December 26, 2014, while working as an auto mechanic, resulting in an immediate loss of more than eighty percent of his vision. Michaud underwent multiple surgeries between 2015 and 2019 in an attempt to restore his vision, but these efforts were largely unsuccessful. In September 2021, Michaud filed petitions for an award of compensation and specific-loss benefits. A doctor’s report in October 2021 confirmed that Michaud had reached maximum medical improvement (MMI) with a ninety-four percent vision loss in his left eye.An Administrative Law Judge (ALJ) determined that Michaud’s specific-loss benefits became due on October 14, 2021, the date of the doctor’s report, and ordered interest to be paid from that date. Michaud appealed, arguing that the benefits should accrue from the date of his injury in 2014. The Workers’ Compensation Board (WCB) Appellate Division affirmed the ALJ’s decision, relying on the precedent set in Tracy v. Hershey Creamery Co., which held that specific-loss benefits for an eye injury are determined when the injury reaches a reasonable medical endpoint.The Maine Supreme Judicial Court reviewed the case and found that Michaud’s injury immediately resulted in more than eighty percent vision loss and that his condition did not materially improve despite medical interventions. The court held that Michaud’s specific-loss benefits became due on the date of his injury, December 26, 2014, and that interest should accrue from that date. The court vacated the Appellate Division’s decision and remanded the case for entry of a decree ordering Michaud’s employer to pay interest from the date of the injury. View "Michaud v. Caribou Ford-Mercury, Inc." on Justia Law

In October 2020, Elliot Fama, employed by Sanford Contracting, was working on a project in Scarborough, Maine. After work, he and his co-worker, Robert Clarke, consumed alcohol at a hotel and a tavern. Later, in the hotel parking lot, Clarke struck Mr. Fama, causing him to fall and sustain fatal injuries. Laureen Fama, Mr. Fama’s widow, settled a workers’ compensation claim in Massachusetts for $400,000.Laureen Fama then filed a lawsuit in Cumberland County Superior Court against Bob’s LLC, which operated the tavern, and Clarke. She alleged liquor liability, wrongful death, loss of consortium, and battery. The defendants moved for summary judgment, arguing that the workers’ compensation settlement precluded the lawsuit. The Superior Court denied these motions, leading to the current appeal.The Maine Supreme Judicial Court reviewed the case. It held that under Maine’s Workers’ Compensation Act (MWCA), Ms. Fama’s settlement barred her from suing Clarke, as the Act’s immunity provisions extend to co-employees. Consequently, Clarke was exempt from the lawsuit. The court further held that because Clarke could not be retained as a defendant, the claims against Bob’s LLC failed under the “named and retained” provisions of Maine’s Liquor Liability Act (MLLA).The court vacated the Superior Court’s order denying summary judgment and remanded the case for entry of judgment in favor of Bob’s LLC and Clarke. View "Fama v. Bob's LLC" on Justia Law

Rebecca Adeyanju, a White woman, was employed by Foot and Ankle Associates of Maine, P.A. as a medical assistant and radiology technician since 2012. In 2018, she married a Black man from Nigeria. In August 2019, Adeyanju missed three consecutive workdays to assist her husband, who was being sought by ICE agents. She informed her employer of her absences via text messages. Upon returning to work, she was terminated for "job abandonment" due to her three-day absence.The Superior Court (Cumberland County) granted summary judgment in favor of Foot and Ankle Associates, concluding that Adeyanju failed to show sufficient evidence that her termination was motivated by discriminatory animus or that the stated reason for her termination was pretextual. Adeyanju appealed the decision.The Maine Supreme Judicial Court reviewed the case de novo. The court found that the summary judgment record, viewed in the light most favorable to Adeyanju, revealed genuine issues of material fact. These included inconsistencies in the employer's enforcement of its attendance policy, differential treatment of employees with similar absences, and potential racial animus linked to the involvement of ICE. The court concluded that these issues warranted a trial to determine whether the termination was indeed motivated by discriminatory animus or if the employer's stated reason was pretextual.The Maine Supreme Judicial Court vacated the summary judgment and remanded the case for trial, allowing Adeyanju to present her claims of employment discrimination under Title VII and 42 U.S.C. § 1981. View "Adeyanju v. Foot and Ankle Associates of Maine, P.A." on Justia Law

This case involves a dispute over an employer's vicarious liability under the Maine Human Rights Act (MHRA) for an employee's discriminatory behavior towards a customer. The plaintiffs, Tiffany Vargas and Erika Acevedo, alleged that they were subjected to racial discrimination by an employee of Riverbend Management, LLC, at a McDonald's restaurant owned and operated by Riverbend. The employee, Andrew Mosley, used a racial slur against Vargas and Acevedo.The case was initially filed with the Maine Human Rights Commission, which issued a right-to-sue letter, allowing the plaintiffs to commence an action in the Superior Court. Riverbend filed a motion for summary judgment, arguing that it was not vicariously liable for the race discrimination committed by its employee. The court partially granted the motion, entering judgment in favor of Riverbend on the gender discrimination claim but denied summary judgment on the race-discrimination claim.After a bench trial, the court found that while Mosley violated the MHRA when he used a racial slur against Vargas and Acevedo, Riverbend was not vicariously liable for Mosley’s actions. The court relied on both the Restatement (Second) of Agency and the Restatement (Third) of Agency in reaching its conclusion. Vargas and Acevedo appealed this decision.The Maine Supreme Judicial Court affirmed the lower court's judgment. The court applied the Third Restatement's standard for determining an employer’s vicarious liability under the MHRA for an employee’s act of discrimination against a customer. The court found that Mosley's discriminatory act reflected an independent course of conduct "not actuated by a purpose to serve" Riverbend, and therefore, Riverbend was not vicariously liable for Mosley’s conduct. View "Vargas v. Riverben Management LLC" on Justia Law

The Maine Supreme Judicial Court ruled in favor of the University of Maine System (UMS) in a case involving Robert Bocko, who claimed that UMS failed to pay him wages on time as mandated by Maine law. Bocko, who was employed by UMS to teach law courses, argued that UMS violated the state's wage payment laws by not paying him at intervals not exceeding 16 days. UMS countered that Bocko was exempt from these requirements as he was a salaried employee. The court agreed with UMS, ruling that Bocko was indeed exempt from the wage payment requirements as he was compensated on a fee basis for teaching each course, rather than on a regular salary basis. The court found that the payment Bocko received for teaching each course met the salary-basis requirement when converted to an annual rate. Therefore, the court affirmed the Superior Court's judgment in favor of UMS. View "Bocko v. University of Maine System" on Justia Law

The Supreme Judicial Court vacated the order of the superior court granting Stephen Witham's motion for an extension of time to file his notice of appeal and dismissed Witham's appeal as untimely, holding that Witham's notice of appeal was untimely.At issue was the decision of the Board of Trustees of the Maine Criminal Justice Academy adopting a hearing officer's recommended decision to revoke Witham's certificate of eligibility as a law enforcement officer. The superior court affirmed the decision. Witham filed a notice of appeal together with a motion for an extension of time to file a notice of appeal. The court granted Witham's motion for an extension. The Supreme Judicial Court vacated the order and dismissed Witham's appeal as untimely, holding that the lower court erred in granting Witham's motion for an extension under the circumstances. View "Witham v. Bd. of Trustees of Me. Criminal Justice Academy" on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered in the business and consumer docket in favor of Employee on the parties' cross-motions for summary judgment after the trial court concluded that Employer failed to comply with the state's wage payment and minimum wage laws, holding that the trial court did not err.At issue was whether the trial court erred in concluding that Employer violated the State's wage payment laws when it permitted Employee's paycheck to be deposited into a bank account controlled by "cybercriminals" who had stolen Employee's username and password to the online portal where she designated payroll information. The Supreme Judicial Court affirmed, holding that where there was no dispute of material fact that Employer did not deposit Employee's wages into her bank account, Employee was entitled to summary judgment because Employer failed to "pay" her, thus violating Maine's wage payment laws. View "Dorsey v. Northern Light Health" on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered by the superior court in favor of the University of Maine System on Plaintiff's claim of negligence based on an injury he sustained from an industrial kitchen mixer, holding that the University was immune from suit.The superior court granted summary judgment in favor of the University, concluding that the University was immune under the Maine Tort Claims Act (MTCA), 14 Me. Rev. Stat. 8104-A(1)(G), because the alleged negligent act did not fall within the MTCA's exception for negligence set forth in Me. Rev. Stat. 14, 8104-A(1)(G). The Supreme Judicial Court affirmed, holding that the mixer did not fall within the "[o]ther machinery or equipment" exception to immunity under the MTCA. View "Badler v. University of Maine System" on Justia Law

The Supreme Judicial Court affirmed the judgment of the superior court granting the motion of Defendant, Plaintiff's former employer, to dismiss Plaintiff's disability discrimination and failure to accommodate claims as time-barred under the Maine Human Rights Act (MHRA), Me. Rev. Stat. 5, 4551-4634, holding that there was no error.Plaintiff brought this complaint alleging two counts under the Americans with Disabilities Act and two counts under the MHRA. A federal district court dismissed the first two counts and remanded the MHRA counts to the superior court. On remand, the superior court granted Defendant's motion to dismiss the remaining counts. The Supreme Judicial Court affirmed, holding that the action was not commenced within two years after the act of unlawful discrimination complained of, and therefore, the superior court properly determined that Plaintiff's disability discrimination claim was not commenced within he two-year statute of limitations under the MHRA. View "Berounsky v. Oceanside Rubbish, Inc." on Justia Law

The Supreme Judicial Court affirmed the summary judgment entered in the superior court in favor of Defendant and dismissing Plaintiff's complaint alleging unlawful discrimination, retaliation, and discharge, holding that there was no error.In her complaint, Plaintiff alleged that Defendant, her former employer, violated the Whistleblowers’ Protection Act, Me. Rev. Stat. 26 831-840; the Maine Human Rights Act, Me. Rev. Stat. 5, 4551-4634; and Me. Rev. Stat. 26 570. The court granted Defendant summary judgment on all counts. The Supreme Judicial Court affirmed, holding (1) summary judgment in favor of Defendant was appropriate; and (2) the court did not err in denying Plaintiff's motion for relief pursuant to Me. R. Civ. P. 60(b)(4) because Defendant's electronic service did not violate Plaintiff's right to due process. View "Handlin v. Broadreach Public Relations, LLC" on Justia Law