Justia Labor & Employment Law Opinion Summaries

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

After Robert Rossignol was notified that his teaching contract would not be renewed, Rossignol applied to the Maine Public Employees Retirement System (MPERS) for disability retirement benefits. Rossignol alleged that he suffered from depression, anxiety, and panic attacks, which made it impossible for him to perform the duties of his position. The Executive Director’s designee denied Rossignol’s application. The MPERS Board of Trustees affirmed the denial of disability retirement benefits. The Supreme Court affirmed, holding that Rossignol failed to demonstrate that, under the governing statutory standard, he was entitled to disability retirement benefits. View "Rossignol v. Maine Pub. Employees Ret. Sys." on Justia Law

After taking maternity leave, Plaintiff returned to work. She quit, however, after disputes between her and Employer arose over a change to her schedule that made her childcare situation more difficult, and over an appropriate place for her to pump breast milk at work. The Bureau of Unemployment Compensation denied Plaintiff’s claim for unemployment benefits. The Department of Labor’s Division of Administrative Hearings affirmed. The Unemployment Insurance Commission affirmed, concluding that Plaintiff “was not able and available for full-time work” within the meaning of Me. Rev. Stat. 26, 1192(3). The superior court affirmed. The Supreme Judicial Court affirmed, holding that the Commission did not err in its construction of the statute and that its decision was not contrary to public policy. View "Cheney v. Unemployment Ins. Comm’n" on Justia Law

After resigning from her job as director of nursing at St. Joseph’s Rehabilitation and Residence, Plaintiff sued St. Joseph’s under the Whistleblowers’ Protection Act, alleging retaliation and constructive discharge. The trial court granted summary judgment for St. Joseph’s on Plaintiff’s constructive discharge claim and, after a trial, the jury rendered a verdict for St. Joseph’s on the retaliation claim. Plaintiff appealed, challenging the entry of summary judgment on her constructive discharge claim. The Supreme Judicial Court affirmed, holding (1) the trial court did not err in addressing the constructive discharge claim separately on the motion for summary judgment; and (2) the court properly entered summary judgment for St. Joseph’s on the constructive discharge claim. View "Sullivan v. St. Joseph's Rehab. & Residence" on Justia Law

In 2011, Dennis Kay was driving a van owned by Budget Truck Rental when the van slid off an icy road. Kay was ejected from the vehicle and died as a result of the accident. Kay was driving the vehicle during the course of his employment with Douglas Wiggins, who died in 2013 of unrelated causes. Kay’s estate brought a wrongful death action against Wiggins’s estate and Budget Truck. The lower court granted summary judgment in favor of Wiggins and Budget Truck, concluding (1) Kay’s claim was barred by the exclusivity provisions of the Workers’ Compensation Act (Act), and (2) Budget Truck did not proximately cause Kay’s injuries. The Supreme Judicial Court affirmed, holding (1) the court did not err in granting summary judgment for Wiggins on the ground that Kay’s claim was barred by the Act; and (2) the court did not err in granting summary judgment for Budget Truck. View "Estate of Kay v. Estate of Wiggins" on Justia Law

Plaintiff filed an application for disability retirement benefits alleging that she was unable to perform her job with the Maine Department of Transportation because of her numerous disabilities. The Maine Public Employees Retirement System Board of Trustees denied benefits after considering Plaintiff’s medical records. Plaintiff appealed, challenging only the denial of benefits as to her fibromyalgia. The Supreme Judicial Court affirmed, holding (1) the medical board’s reports were a proper part of the evidentiary record; and (2) the record did not compel a finding that Plaintiff met her burden of proving that her fibromyalgia caused functional limitations that made it impossible for her to do her job. View "Behr v. Maine Pub. Employees Ret. Sys." on Justia Law

Brenda Freeman was injured in a work-related accident in 2007. Freeman returned to work but in a lower-paying position. Because of the decrease in her wages, Freeman received partial incapacity benefit payments. In 2011, Freeman suffered a second work-related injury. During Freeman’s period of incapacity, her employer paid 100 percent partial incapacity benefits based on the 2007 injury. Freeman filed a petition for award of compensation claiming that although she was already receiving benefits that equaled the maximum compensation rate as a result of her 2007 injury, she was eligible for additional compensation for the same period as a result of her 2011 injury. The hearing officer concluded that Freeman was ineligible for compensation beyond the statutory maximum benefit, regardless of the number of injuries. The Workers’ Compensation Board Appellate Division affirmed. The Supreme Judicial Court affirmed, holding that the hearing officer correctly construed the statutory maximum benefit provision of the Workers Compensation Act as a total ceiling on the potential benefits available to an injured employee, regardless of the number of injuries the employee suffers. View "Freeman v. NewPage Corp." on Justia Law

A Deputy of the Department of Labor, Bureau of Unemployment Compensation determined that Plaintiff had been overpaid $13,157 in unemployment insurance benefits and was required to reimburse the Bureau in that amount. Nearly one year after the expiration of the appeal period Plaintiff appealed the Department’s decision. The Department of Labor, Division of Administrative Hearings dismissed the appeal as untimely. On appeal, the Unemployment Insurance Commission remanded the matter to the Division to develop an evidentiary record on the timeliness of Plaintiff’s appeal and the merits of her appeal. On remand, the Division developed the record and submitted the record to the Commission for decision. The Commission concluded that Plaintiff’s appeal to the Division was untimely. The superior court affirmed. The Supreme Judicial Court affirmed, holding that the Commissioner correctly concluded that the Deputy’s decision had become final and that it was without jurisdiction to address the merits of her untimely appeal. View "Ramelli v. Unemployment Ins. Comm’n" on Justia Law