Justia Labor & Employment Law Opinion Summaries

In 2009, Carlton Curry was appointed as superintendent of Lawrence Utilities, the City of Lawrence’s municipally owned water and sewer utility. Just over two years later, Dean Jessup was elected as mayor of the City in the general election. Mayor Jessup terminated Curry after their differences in policy became apparent. Curry filed a complaint against the City, claiming he was wrongfully discharged under the utility superintendent statute, he was owned unpaid wages under the Wage Payment Statute, and the mayor tortiously interfered with his employment contract. The trial court (1) granted summary judgment in favor of Curry on the wrongful discharge claim, (2) granted summary judgment in favor of the City on the Wage Payment Statute claim, and (3) denied summary judgment on the tortious interference claim. The Supreme Court affirmed the trial court in all respects, holding (1) Mayor Jessup lacked authority to remove Curry as the utility service board superintendent; (2) Curry was not entitled to wages under the Wage Payment Statute; and (3) a genuine issue of material fact existed regarding Curry’s claim for intentional interference with an employment relationship. View "City of Lawrence Utilites Service Board v. Curry" on Justia Law

Pursuant to 2011 amendments to statutes addressing collective bargaining for teachers and their employees, when parties failed to reach a collective bargaining agreement (CBA) regarding salaries and wages, the Indiana Education Employment Relations Board (IEERB) appoints a mediator. If the mediation fails, the parties must exchange their last best offers (LBOs). A factfinder appointed by the IEERB then selects which side’s LBO to adopt as the CBA. In this case, a teachers association appealed a factfinder’s decision to adopt a school’s LBO. The IEERB affirmed the factfinder’s decision. The Supreme Court affirmed, holding that the adopted LBO was collectively bargained and lawful. View "Jay Classroom Teachers Ass’n v. Jay School Corp." on Justia Law

In this employment termination discrimination case, Plaintiff claimed, inter alia, that he had been harassed, discriminated, and retaliated against on the basis of his sex. The trial court granted summary judgment to Plaintiff’s former employer as to Plaintiff’s federal and state constitutional claims and as to Plaintiff’s retaliation claim under Title VII of the Civil Rights Act. The Court of Appeals affirmed. The Supreme Court granted transfer and summarily affirmed the decision of the Court of Appeals with respect to the federal and state constitutional claims. As to the retaliation claim, the Supreme Court held (1) to prevail on summary judgment on a claim for retaliation under Indiana procedural law, it is an employer’s burden to affirmatively negate the plaintiff’s claim, not the plaintiff’s burden to make a prima facie case of Title VII retaliation; and (2) the employer in this case satisfied its burden on summary judgment to affirmatively negate Plaintiff’s retaliation claim under Title VII of the Civil Rights Act. View "Gaff v. Indiana-Purdue Univ. of Fort Wayne" on Justia Law

James Armour’s employment contract with AM General LLC entitled him to payment of a long-term incentive plan (LTIP). When Armour retired, he was to receive a lump sum LTIP payment, but instead he started receiving quarterly installment payments in the form of checks. AM General attempted to make the final installment payment with a subordinate promissory note. Armour rejected the Note and requested full payment. Thereafter, AM General filed a complaint seeking a declaratory judgment that it had not breached the LTIP portion of its agreement with Armour. Armour counterclaimed, asserting that AM General breached the employment agreement by failing to pay Armour the full LTIP payment when it was due and claiming that, by attempting to pay the remaining portion of the LTIP payment with a promissory note, AM General breached the duty of good faith and fair dealing. The trial court entered summary judgment in favor of Armour. The Court of Appeals reversed, finding a genuine issue of material fact with regard to how “payment” could be made under the LTIP provision of the agreement. The Supreme Court granted transfer and affirmed the grant of summary judgment, holding that AM General breached its employment agreement with Armour because the Note did not constitute payment under the employment agreement. View "AM General LLC v. Armour" on Justia Law

Plaintiff, an elementary school principal, was terminated after the school board learned that he had been involved in a sexual relationship with a teacher. Plaintiff filed a complaint against school defendants, alleging breach of contract and that the notice and procedure utilized by the school board in terminating his administrator’s contract denied him due process. The superior court granted summary judgment for the School. The Supreme Court affirmed, holding (1) the hearing process described in the teacher’s termination statute does not apply to termination of an administrator when his underlying teaching contract is not being terminated; (2) the language in Plaintiff’s form teacher’s contract referring to a hearing with the benefit of counsel and a just cause determination applies only to Plaintiff’s underlying teacher’s contract and not his administrator’s contract; and (3) under the circumstances of this case, Plaintiff received constitutional due process. View "Hewitt v. Westfield Washington Sch. Corp." on Justia Law