Justia Labor & Employment Law Opinion Summaries

The Supreme Judicial Court affirmed the order of the superior court denying Benton, LLC’s motion for summary judgment and rejecting its claim that section 104 of the Maine Workers’ Compensation Act of 1992, Me. Rev. Stat. 39-A, 104, provided it with immunity from Chauncey Clark’s negligence suit for injuries sustained on Benton, LLC’s property in Benton, Maine.On appeal, Benton, LLC argued that an extension of the dual persona doctrine regarding the scope of the Act’s immunity and exclusivity provisions provided it with immunity from Clark’s suit as a matter of law. Specifically, Benton, LLC argued that once Clark’s actual employer secured workers’ compensation for Clark’s injuries and lost wages, section 104 of the Act immunized the employer and Benton, LLC from Clark’s negligence action because those entities were “functionally one and the same.” The Supreme Judicial Court disagreed, holding that the superior court did not err as a matter of law by determining that the dual persona doctrine’s exception to an employer’s immunity was inapposite to the assertion of immunity by Benton, LLC. View "Clark v. Benton, LLC" on Justia Law

The Supreme Judicial Court vacated the decision of the Appellate Division affirming the order of the Workers’ Compensation Board (Board) requiring Plaintiff’s former employer (Defendant) to pay for medical marijuana used to treat Plaintiff’s chronic back pain.Plaintiff was issued a certification to use medical marijuana to treat his pain after sustaining a work-related injury. Plaintiff filed a “petition for payment of medical and related services” with the Board seeking payment from Defendant for the cost of the medical marijuana. Defendant opposed the petition, arguing that an order requiring it to pay for Plaintiff’s medical marijuana was barred by the federal Controlled Substances Act (CSA) even if his use of medical marijuana were permitted by the Maine Medical Use of Marijuana Act (MMUMA). A hearing officer granted Plaintiff’s petition, and the Appellate Division affirmed. The Supreme Court vacated the decision of the Appellate Division, holding (1) in the narrow circumstances of this case, there was a positive conflict between federal and state law; and (2) consequently, the CSA preempts the MUUMA as applied here. View "Bourgoin v. Twin Rivers Paper Co., LLC" on Justia Law

Me. Rev. Stat. 39-A, 221 entitles an employer to a credit for workers’ compensation benefits previously paid for the same liability period when the employee was also receiving Social Security retirement benefits.Plaintiff was paid total incapacity workers’ compensation benefits by his employer, Interstate Brands International, after he sustained injuries in an initial workplace accident. For three years, Plaintiff collected Social Security retirement benefits while receiving the full amount of the workers’ compensation benefits. When Interstate learned that Plaintiff was receiving Social Security benefits, it sought a credit against the ongoing incapacity payments pursuant to section 221. A hearing officer determined that Interstate was entitled to a credit of nearly $25,000. The Workers’ Compensation Appellate Division vacated the decree, concluding that section 221 does not allow a reduction based on incapacity overpayments made in the past. The Supreme Judicial Court vacated the Appellate Division’s decision, holding that Interstate was entitled to a credit for incapacity benefit overpayments made to Plaintiff during the same period when he received Social Security retirement benefits. View "Urrutia v. Interstate Brands International" on Justia Law

The Supreme Judicial Court affirmed the decision of the Workers’ Compensation Board Appellate Division affirming the hearing officer’s decree denying Appellant’s petition for award. On appeal, Appellant claimed that he was an employee of Regional Transportation Program (RTP), and therefore, he was entitled to receive benefits for a work-related injury. The hearing officer determined that Appellant was not an RTP employee for purposes of the Workers’ Compensation Act. The Appellate Division affirmed. The Supreme Judicial Court affirmed, holding (1) it was not unreasonable for the Appellate Division to conclude that the reimbursement provided to Appellant did not constitute payment for his services; and (2) therefore, the Appellate Division properly found that Appellant was not an employee for purposes of the Act. View "Huff v. Regional Transportation Program" on Justia Law

Plaintiff, a registered nurse, filed a complaint alleging that Mercy Hospital discriminated against her in violation of the Maine Human Rights Act (MHRA) by terminating her employment because of her alleged disability and refusing to provide her with a reasonable accommodation. The superior court entered summary judgment for Mercy. The Supreme Court affirmed, holding that the district court properly granted summary judgment on Plaintiff’s disability discrimination claim because there was no genuine issue of material fact that Plaintiff was not a “qualified individual with a disability” as defined by the MHRA. View "Carnicella v. Mercy Hospital" on Justia Law

In 2004, Michael Bailey began to receive partial incapacity benefits stemming from a workplace injury. In 2007, a hearing officer found that Bailey had reached maximum medical improvement (MMI) and that he had sustained an injury that resulted in a permanent impairment level of thirty-two percent. In 2013, the City of Lewiston filed a petition seeking review of the level of Bailey’s incapacity and a petition seeking to determine the extent of his permanent impairment. The hearing officer concluded that there was a change of circumstances warranting a new permanent impairment finding and reduced Bailey’s permanent impairment level to zero percent. The decree thus terminated Bailey’s entitlement to further compensation. The Workers’ Compensation Board Appellate Division vacated the hearing officer’s decree, ruling that the 2007 determination of permanent impairment as of the date of MMI was final, and therefore, the doctrine of res judicata barred relitigation of that issue. The Supreme Court affirmed, holding that the Appellate Division did not err in concluding that relitigation of Bailey’s permanent impairment level was barred by res judicata principles. View "Bailey v. City of Lewiston" on Justia Law

Elizabeth Jalbert, a teacher, filed an application for disability retirement benefits with the Maine Public Employees Retirement System (MPERS) after she twice fell and slipped on ice, hitting her head each time. An Executive Director’s designee ultimately denied Jalbert’s application. Jalbert appealed to the MPERS Board of Trustees. The hearing officer issued a recommended final decision concluding that Jalbert had not satisfied her burden of proving that her conditions made it impossible to perform the duties of her employment position. The Board adopted the hearing officer’s decision in full. The superior court affirmed. The Supreme Judicial Court affirmed, holding that the record, when considered as a whole, did not compel the determination that Jalbert was disabled within the meaning of Me. Rev. Stat. 5, 17921(1), and therefore, the Board did not err in denying Jalbert’s application for disability retirement benefits. View "Jalbert v. Maine Public Employees Retirement System" on Justia Law

Plaintiffs were employed by Shaw’s Supermarkets, Inc. when their employment was terminated as part of a reduction in force. The reduction in force affected more older employees than younger employees. Plaintiffs filed complaints with the Maine Human Rights Commission alleging age discrimination in violation of the Maine Human Rights Act (MHRA). A Commission investor applied the “business necessity” framework to analyze Plaintiffs’ allegations before recommending that the Commission find reasonable grounds to believe that Shaw’s had impermissibly discriminated based on age pursuant to a disparate impact theory. The Commission voted unanimously to adopt the investigator’s analysis and recommendations. Plaintiffs then filed a complaint alleging unlawful employment discrimination based on age pursuant to the MHRA. The federal district court certified to the Supreme Court the question of what framework of proof applies to a claim of disparate impact age discrimination brought pursuant to the MHRA. The Supreme Court answered that a claim for disparate impact age discrimination pursuant to the MHRA is evaluated according to the “business necessity” standard, rather than the “reasonable factor other than age” standard or some other standard. View "Scamman v. Shaw's Supermarkets, Inc." on Justia Law

Susan Berube was terminated from her employment with the Department of Health and Human Services (DHHS) for having alcohol on her breath while meeting with a client. The Maine State Employees Association, SEIU Local 1989 (MSEA) initiated the grievance process, which included an arbitration proceeding, on Berube’s behalf. The arbitrator entered an award reinstating Berube to her employment position. The State and the DHHS filed a motion to vacate the arbitration award. The superior court denied the motion. On appeal, the Supreme Court vacated the judgment and remanded with instructions to vacate the arbitration award, holding that the arbitrator exceeded her powers by determining that the grievance was arbitrable because the arbitration request was filed after the deadline established in the collective bargaining agreement. View "State v. Maine State Employees Ass’n" on Justia Law

The Board of Trustees of the Maine Public Employees Retirement System affirmed an administrative determination that Appellant was ineligible for disability retirement benefits. Appellant later filed an incomplete petition for review of final agency action in the superior court. The complete petition was required to be filed on or before April 7. Appellant did not file a complete petition under April 15. The superior court dismissed as untimely Appellant’s petition for review of the Board’s decision. The Supreme Judicial Court affirmed, holding that the superior court did not err in dismissing the petition as untimely or in denying Appellant’s subsequent motion for reconsideration. View "Bastille v. Maine Pub. Employees Ret. Sys." on Justia Law