Justia Labor & Employment Law Opinion Summaries

Plaintiff, a former high school instructor, was terminated from her employment for insubordination. Plaintiff appealed her termination to binding arbitration pursuant to the terms of a collective bargaining agreement. The arbitrator denied Plaintiff's grievance. The district court upheld the arbitration award, concluding that the arbitrator had not exceeded his powers and that Plaintiff had failed to meet her burden of proving that a ground for vacating, correcting, or modifying the award existed. The Supreme Court affirmed, holding that the district court did not abuse its discretion in refusing to vacate, modify, or correct the arbitration award. View "Roberts v. Lame Deer Sch. Dist. No. 6" on Justia Law

Five City employees were disciplined by the City for accessing pornography on their government computers. The local newspaper requested access to documents detailing the investigation of the misconduct and the employees' punishment. The City disclosed some documents, refused to release the disciplinary corrective action forms, and redacted all information that could be used to identify the disciplined employees or uninvolved third parties. The newspaper filed a petition for declaratory relief and writ of mandamus. The district court ordered that the City release copies of the investigative documents and disciplinary forms without redactions. The Supreme Court reversed, holding that the district court erred by ordering that identifying information for the five City employees be released to the newspaper, as the employees' reasonable expectation of privacy in their identities with regards to internal disciplinary proceedings clearly outweighed the limited merits of public disclosure. View "Billings Gazette v. City of Billings" on Justia Law

Appellant, a vocational agricultural teacher at a high school, served as faculty advisor for the school's chapter of the National FFA Organization. Appellant obtained a loan on behalf of the school FFA and opened a checking account into which she deposited the loan proceeds. Because Appellant did not deposit the funds in an account maintained by the school district, Appellant violated the school district financial policy and was suspended. Appellant then made out a check to herself to purportedly reimburse herself for expenses incurred in setting up a hay cutting business. The Board of Trustees subsequently terminated Appellant's employment. The Montana Department of Labor and Industry determined that Appellant was eligible to receive benefits, but a hearing officer concluded that Appellant had been discharged for misconduct and was ineligible to receive unemployment insurance benefits. The Board of Labor Appeals affirmed the determination. The Supreme Court affirmed, holding that Appellant's actions constituted misconduct, and she was therefore ineligible to receive unemployment insurance benefits. View "Roberts v. State Bd. of Labor Appeals" on Justia Law

After leaving her job as a bus driver, Plaintiff applied for unemployment benefits with the Montana Department of Labor and Industry. The Department determined that Plaintiff was not qualified to receive unemployment benefits. The Boar of Labor Appeals affirmed. Plaintiff subsequently filed a petition for review in the district court. The district court denied Plaintiff's petition for failure to comply with Rule 2 of the Montana Uniform District Court Rules because Plaintiff had not filed a supporting brief or stated issues of law for review. The Supreme Court reversed, holding that the district court erred when it denied Plaintiff's petition for failure to include a supplemental brief because the provisions of Rule 2 do not apply to a petition for judicial review. View "Jacky v. Avitus Group" on Justia Law

Plaintiff worked for Union Pacific Railroad Company as a locomotive engineer until his retirement in 2008. After an MRI showed evidence that Plaintiff suffered from a degenerative disc disease, Plaintiff filed a report of personal injury with Union Pacific. Three years later, Plaintiff filed a complaint against Union Pacific under the Federal Employers' Liability act (FELA) for the back and leg injuries he allegedly sustained during his employment. Union Pacific filed a motion for summary judgment arguing that Plaintiff's claim was time-barred under FELA's three-year statute of limitations because Plaintiff sought medical help as early as 2000. The district court granted Union Pacific's motion. The Supreme Court affirmed, holding that Plaintiff's claim was time-barred, and Union Pacific was entitled to judgment as a matter of law. View "Bridgman v. Union Pac. R.R. Co" on Justia Law

Appellant worked at Pine Hills Youth Correctional Facility as a correctional officer for approximately three years. Appellant worked in the sex offender unit during the majority of her employment with Pine Hills. After quitting her job, Appellant filed an action against Pine Hills for sexual harassment, hostile work environment, and retaliation. After a bench trial, the district court entered judgment for Pine Hills on all claims. The Supreme Court affirmed, holding (1) substantial credible evidence supported the district court's determination that Pine Hills held open an offer for Appellant to transfer units for one year until Appellant quit; (2) the district court correctly determined that Pine Hills reasonably and promptly offered a solution to end one inmate's harassment of Appellant; and (3) the district court correctly dismissed Appellant's retaliation claim against Pine Hills. View "Puskas v. Pine Hills Youth Corr. Facility" on Justia Law

Employee contracted an occupational disease arising out of her employment with Employer. In 2006, Employee began seeking medical treatment. Employee received treatment periodically until 2011 when her doctor informed her that she had an occupational disease. Employee subsequently initiated a workers' compensation claim. Montana State Fund denied Employee's claim, asserting that the claim was not timely filed under the twelve-month statute of limitations. Employee appealed. The Workers' Compensation Court granted summary judgment for State Fund, concluding that the undisputed facts demonstrated that Employee knew or should have known that she was suffering from occupational disease as early as 2006. The Supreme Court reversed, holding that a material question of fact existed as to when Employee should have known she was suffering from an occupational disease. Remanded for a trial to determine when Employee knew or should have known she was suffering from an occupational disease. View "Dvorak v. State Fund" on Justia Law

Plaintiff injured his shoulder while working for his employer, who was insured by the Montana State Fund. The State Fund paid for Plaintiff's two shoulder injuries and paid temporary total disability (TTD) benefits after informing Plaintiff that if he returned to gainful employment without the State Fund's knowledge and continued to receive benefits, he would be subject to legal action or criminal prosecution. After the State Fund discovered that Plaintiff had built and sold furniture and worked at a vacuum cleaner store while receiving TTD benefits, the assistant attorney general charged Plaintiff with theft, a felony. The State Fund subsequently terminated Plaintiff's TTD benefits. Plaintiff filed suit against the State fund and its private investigators, alleging that Defendants violated Montana's Insurance Code regarding unfair claim settlement practices and pleaded a variety of common law causes of action. The district court ruled in favor of Defendants. The Supreme Court affirmed the district court's entry of judgment in favor of the State Fund, holding that the district court did not err in (1) granting the State Fund's motion to dismiss Defendant's claims under the Insurance Code; and (2) granting the State Fund's motion for summary judgment regarding Plaintiff's common law claims. View "White v. State ex rel. Mont. State Fund" on Justia Law

Employee was fired by employer after allegations that Employee had a sexual relationship with a co-worker. Employee was found eligible to receive unemployment benefits. The Board of Labor Appeals affirmed. Employee subsequently filed this suit, alleging that Employer discharged him in violation of the Wrongful Discharge From Employment Act. After a trial, the jury found Employer did not wrongfully terminate Employee. The Supreme Court affirmed, holding that the district court did not err in (1) failing to grant summary judgment to Employee on liability and allowing Employer to proceed to trial on the question of whether it had good cause to discharge Employee; (2) failing to sanction Employer for discovery abuse and destruction of evidence; (3) denying Employee's motion to amend the pleadings to add a claim for punitive damages; (4) allowing Employer's expert witness to testify, as she did not testify as to ultimate issues of fact and law; and (5) allowing witnesses to testify to rumors heard at the workplace about Employee. View "Cartwright v. Scheels All Sports, Inc." on Justia Law

Plaintiff worked for Employer as a construction site supervisor. When Plaintiff left Montana for a vacation, a group of employees complained about Plaintiff as their supervisor. After an investigation, Employer terminated Plaintiff's employment. Plaintiff filed an action alleging that Employer violated the Montana Wrongful Discharge from Employment Act. The district court granted summary judgment for Employer. The Supreme Court affirmed, holding (1) the district court properly concluded that Employer had good cause to terminate Plaintiff's employment; (2) Employer properly considered hearsay evidence in deciding to terminate Plaintiff's employment; (3) the district court properly considered employee statements contained in reports in concluding that Employer had good cause to terminate Plaintiff's employment; and (4) the district court properly concluded that Employer did not violate the provisions of its employee handbook when it terminated Plaintiff's employment. View "Sullivan v. Continental Constr. of Mont., LLC " on Justia Law