Justia Labor & Employment Law Opinion Summaries

Articles Posted in North Carolina Supreme Court
by
In this North Carolina Supreme Court case, the plaintiff, Robin Kluttz-Ellison, was an employee at Noah’s Playloft Preschool. She filed workers’ compensation claims for two separate workplace accidents – one where she fell off a ladder and another where she tripped over a cot. Before these incidents, Kluttz-Ellison had had knee surgery and had been diagnosed with obesity. After the accidents, her healthcare providers determined that she needed knee surgery again due to loosening of the hardware in her knee. However, they believed the surgery could only be performed if she lost a significant amount of weight. They recommended bariatric weight-loss surgery, believing it was the only treatment that could achieve the necessary weight loss quickly.The Supreme Court of North Carolina held that for an employee to receive workers' compensation for a medical treatment, the treatment must be directly related to the workplace injury. This means there must be a sufficiently strong causal relationship between the condition that requires treatment and the workplace injury. The court identified three criteria to meet this standard: 1) the workplace injury caused the condition that requires treatment, 2) the condition was aggravated by the workplace injury, or 3) the condition did not require medical treatment before the workplace injury but now requires treatment solely due to the workplace injury.In this case, the Court noted that neither the Industrial Commission nor the Court of Appeals applied this test. Instead, they focused on whether the bariatric surgery was medically necessary for the plaintiff to undergo knee surgery. Therefore, the Supreme Court reversed the decision of the Court of Appeals and remanded the matter to the Industrial Commission for further proceedings applying the correct legal standard. View "Kluttz-Ellison v. Noah's Playloft Preschool" on Justia Law

by
The Supreme Court reversed the decision of the court of appeals and reinstated the opinion and award filed by the North Carolina Industrial Commission in favor of Plaintiff following a tractor-trailer accident in which Plaintiff, an employee a trucking company, sustained injury, holding that the agency's decision should not have been disturbed by the lower appellate court.After the accident, Plaintiff provided notice to her employer and its insurance carrier of the accident and of the injury her husband received in the accident but did not report injury to herself. The Commission concluded that Plaintiff's injury was causally related to the accident, that Plaintiff had a reasonable excuse for not providing notice of her injury until two years later, that Defendants were not prejudiced, and that Plaintiff was totally disabled as a result of her injury. The court of appeals reversed. The Supreme Court reversed, holding that there was no error in either the Commission's findings of fact or in its conclusions of law. View "Sprouse v. Turner Trucking Co." on Justia Law

by
The Supreme Court affirmed in part and reversed in part an order of the court of appeals in this jurisdictional dispute, holding that the Corporate Defendants intentionally reached out to North Carolina to conduct business activities in the state, and the claims at issue in this case arose from or were related to those activities.After Plaintiff was officially terminated from his employment he brought an action against Individual and Corporate Defendants alleging, inter alia, fraud, misrepresentation, and breach of contract. Defendants moved to dismiss the action. The trial court denied the motions. The court of appeals reversed, holding that the Corporate Defendants' activities alone were not sufficient to establish specific jurisdiction and that Plaintiff's claims did not arise out of, or even relate to, the alleged contacts between Defendants and North Carolina. The Supreme Court reversed the court of appeals' decision as to Corporate Defendants, affirmed with respect to Individual Defendants, and remanded, holding that the trial court may exercise personal jurisdiction over Corporate Defendants pursuant to the Due Process Clause. View "Schaeffer v. SingleCare Holdings, LLC" on Justia Law

by
The Supreme Court reversed the order of the trial court granting Defendants' motion to dismiss this action brought against Troy University, an accredited, four-year state university with several campuses in Alabama and an office in Fayetteville, North Carolina, alleging various tort claims arising out of his employment and termination, holding that Troy University explicitly waived its sovereign immunity.Plaintiff brought this lawsuit against Troy University and two individual defendants asserting, among other things, claims for wrongful discharge from employment in violation of public policy and negligent retention or supervision of an employee. The trial court dismissed the complaint based on sovereign immunity, citing Franchise Tax Bd. of Cal. v. Hyatt, 139 S. Ct. 1485 (2019), which established that states are required to recognize sovereign immunity of other states as a matter of constitutional law. The Supreme Court reversed and remanded the case, holding (1) Troy University explicitly waived its sovereign immunity and consented to be sued in North Carolina; and (2) therefore, the doctrine of sovereign immunity did not bar Plaintiff's suit against Defendants. View "Farmer v. Troy University" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals reversing the opinion and award of the North Carolina Industrial Commission denying Plaintiff relief on her claim for disability compensation from Defendants, holding that there was no error.On appeal, the court of appeals held that Plaintiff's claim was not time-barred under N.C. Gen. Stat. 97-24 and thus reversed the Commission's dismissal of Plaintiff's claim based on a 2014 injury. The court remanded the case to the Commission for a determination as to whether Plaintiff suffered a compensable injury under the Workers' Compensation Act. The Supreme Court affirmed, holding that Plaintiff's claim was not barred by section 97-24. View "Cunningham v. Goodyear Tire & Rubber Co." on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals affirming the order of the superior court affirming the decision of the Board of Review for the North Carolina Department of Commerce adopting the decision of the appeals referee ruling that Frank Lennane was disqualified for unemployment benefits, holding that there was no error.At issue was whether Lennane's leaving work was attributable to his employer, as required by N.C. Gen. Stat. 96-14.5(a), to avoid disqualification for unemployment benefits. The lower courts affirmed the administrative decision that Lennane was disqualified for unemployment benefits because he failed to show good cause attributable to the employer for leaving. The Supreme Court affirmed, holding that while Lennane left work for good cause, he failed to satisfy his burden to show that his leaving work was "attributable to the employer" as a matter of law. View "In re Lennane" on Justia Law

by
The Supreme Court held that the court of appeals erred in concluding that more than 220,000 former State employees (the Retirees) possessed no vested rights within the meaning of the Contracts Clause to the benefit of lifetime enrollment in any particular premium-free health insurance plan, holding that the trial court correctly concluded that the Retirees had obtained a vested right protected under the Contracts Clause.After the General Assembly enacted a statute eliminating Retirees' option to remain enrolled in the plan of their choice, the Retirees argued that the State had undertaken a contractual obligation to provide them with the option to remain enrolled in the premium-free preferred provider organization health insurance plan that allocated eighty percent of the costs of health care services to the insurer and twenty percent to the insured for life. The trial court entered partial summary judgment for Retirees. The court of appeals reversed and remanded for summary judgment in favor of the State. The Supreme Court reversed, holding that the trial court correctly determined there were no genuine issues of material fact relating to whether Retirees possessed a vested right protected under the Contracts Clause. View "Lake v. State Health Plan for Teachers & State Employees" on Justia Law

by
The Supreme Court modified and affirmed the decision of the court of appeals holding that the decision of the North Carolina Industrial Commission should be reversed and this case remanded to the Commission for recalculation of Plaintiff's average weekly wage, holding that the court of appeals did not err.Plaintiff, an injured employee, received temporary disability benefits. Plaintiff later requested that his claim be assigned for a hearing, claiming that Defendant, his employer, had unilaterally lowered the amount of temporary total disability benefits that he had been receiving with respect to his back injury and that the parties could not agree with respect to the amount of benefits to which Plaintiff was entitled. The Commission determined that the fifth method for calculating Plaintiff's average weekly wage was appropriate for use in this case. The court of appeals reversed and remanded the case. The Supreme Court affirmed, holding that the findings and conclusions that the Commission made in support of its average weekly wages determination appeared to rest upon a misapplication of the applicable legal standard. View "Nay v. Cornerstone Staffing Solutions" on Justia Law

by
The Supreme Court reversed the court of appeals' decision affirming the North Carolina Industrial Commission's finding that the uninsured/underinsured motorist (UIM) proceeds that Plaintiff received on behalf of her husband's estate through the settlement of a wrongful death lawsuit were subject to Defendants' subrogation lien under N.C. Gen. Stat. 97-10.2, holding that the UIM proceeds recovered from the wrongful death lawsuit may not be used to satisfy Defendants' workers' compensation lien.The decedent, Plaintiff's husband and an employee of Employer, was involved in a fatal motor vehicle accident with a third party in South Carolina. The Commission ordered Defendants to pay workers' compensation benefits to Plaintiff. Plaintiff then filed a wrongful death case seeking damages from the third party driver. The parties reached a settlement agreement that included recovery in the form of UIM proceeds. The workers' compensation insurance carrier for Employer subsequently claimed a lien on the UIM proceeds that Plaintiff recovered from the wrongful death settlement. The Commission ordered the distribution of Plaintiff's entire recovery from the South Carolina wrongful death settlement, concluding that Defendants were entitled to subrogation under section 97-10.2. The Supreme Court reversed, holding that Defendants may not satisfy their workers' compensation lien by collecting from Plaintiff's recovery of UIM proceeds in her South Carolina wrongful death settlement. View "Walker v. K&W Cafeterias" on Justia Law

by
In this dispute concerning the manner in which the cost of pensions for certain retirees should be funded, the Supreme Court held that the Administrative Procedure Act's (APA) rulemaking procedures bind how the Retirement System's Board of Trustees adopt "cap factors" under the anti-pension spiking provision at issue in this case.In order to calculate the retirement benefit cap applicable to each retiree, the Act to Enact Anti-Pension-Spiking Legislation by Establishing a Contribution-Based Benefit Cap directs the Retirement System's Board of Trustees to adopt a contribution-based benefit cap factor recommended by an actuary, which the Board had traditionally adopted by resolution. Here, the Retirement System determined that Dr. Barry Shepherd's pension benefits were subject the contribution-based benefit cap. The trial court concluded that the Board of Trustees' adoption of the cap factor was void because the action was subject to rulemaking under the APA. The Supreme Court affirmed, holding (1) the Board of Trustees was required to adopt the statutorily mandated cap factor utilizing the rulemaking procedures required by the APA; and (2) the Retirement System erred by billing the Board of Education an additional amount relating to Dr. Shepherd's pension, in light of the Board of Trustees' failure to adopt the necessary cap factor in an appropriate manner. View "Cabarrus County Board of Education v. Department of State Treasurer" on Justia Law