Justia Labor & Employment Law Opinion SummariesArticles Posted in U.S. 11th Circuit Court of Appeals
Skye v. Maersk Line
Plaintiff, chief mate of the "Sealand Pride," filed suit under the Jones Act, 46 U.S.C. 30104, alleging that his employer, Maersk, negligently saddled him with excessive duties and duty time such that he was overworked to the point of fatigue. The court concluded that the Jones Act does not allow seaman to recover for injuries caused by work-related stress because work-related stress is not a physical peril. Therefore, the district court erred when it denied the motion of Maersk for a judgment in its favor as a matter of law. Under Consolidated Rail Corp. v. Gottshall, plaintiff's complaint of an injury induced by overwork was not cognizable under the Jones Act. Accordingly, the court vacated the judgment awarding plaintiff damages. The court reversed the denial of the motion of Maersk for a judgment as a matter of law and rendered the judgment in favor of Maersk. View "Skye v. Maersk Line" on Justia Law
Paylor v. Hartford Fire Ins. Co.
Plaintiff filed suit against her former employer, Hartford, alleging claims of interference and retaliation under the Family Medical Leave Act of 1993 (FMLA), 29 U.S.C. 2601, et seq. The court rejected plaintiff's interpretation of "prospective" FMLA rights and concluded that section 825.220(d)'s prohibition of "prospective" waiver means only that an employee may not waive FMLA rights, in advance, for violations of the statute that have yet to occur. Here, the conduct plaintiff complained about all happened before she signed the Severance Agreement. In signing the agreement and accepting her severance benefits, plaintiff settled claims based on past employer conduct, and so the district court did not err in concluding that the agreement was valid and that it entitled Hartford to judgment as a matter of law. The court also concluded that the district court did not err in concluding that plaintiff executed the Severance Agreement knowingly and voluntarily. Accordingly, the court affirmed the judgment of the district court. View "Paylor v. Hartford Fire Ins. Co." on Justia Law
Mazzeo v. Color Resolutions Int’l, LLC
Plaintiff filed suit against his former employer, CRI, claiming discrimination under the Americans with Disabilities Act of 1990 (ADA), 42 U.S.C. 12101 et seq., the Age Discrimination and Employment Act of 1967 (ADEA), 29 U.S.C. 621, and the Florida Civil Rights Act (FCRA), Fla. Stat. 760.10. Congress made significant changes to the ADA by enacting the ADA Amendments Act of 2008, Pub. L. No. 110-325, 122 Stat. 3553. The court concluded that, in light of these recent amendments to the ADA, plaintiff submitted sufficient evidence on his ADA and FCRA disability claims to make out a prima facie case; the district court erroneously applied the prima facie standard created for reduction-in-force cases to plaintiff's age discrimination claims; and, therefore, the court vacated the district court's grant of summary judgment in favor of CRI, remanding for further proceedings. View "Mazzeo v. Color Resolutions Int'l, LLC" on Justia Law
Samson v. Federal Express Corp.
Plaintiff appealed the district court's grant of summary judgment in favor of FedEx on his disability discrimination claims under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and the Florida Civil Rights Act (FCRA), Fla. Stat. 760.01 et seq. When plaintiff failed his Department of Transportation (DOT) medical examination due to his diabetes, FedEx withdrew plaintiff's job offer since he did not qualify for a Technician position. FedEx claimed that the Federal Motor Carrier Safety Regulations (FMCSRs) required it to do so. Plaintiff argued that by imposing a requirement that he must obtain a DOT medical card even though he would be a mechanic and not a commercial truck driver, FedEx violated the ADA and the FCRA, which prohibited an employer from using qualification standards that screen out people with disabilities. The court concluded that reasonable jurors could differ as to whether test-driving FedEx trucks was an essential function of the Technician position. The court also concluded that, the occasional test-driving of empty FedEx trucks in the Fort Myers area did not constitute transporting property or passengers in interstate commerce. Therefore, the FMCRs did not oblige FedEx to require plaintiff to obtain DOT medical certification to be "qualified" for the Technician position. The FMCRs did not afford FedEx a defense to plaintiff's disability discrimination claims. Accordingly, the court reversed and remanded for further proceedings. View "Samson v. Federal Express Corp." on Justia Law
Walthour, et al. v. Chipio Windshield Repair, LLC, et al.
Plaintiffs appealed the district court's order compelling arbitration and dismissing their complaint filed against defendants. At issue was whether the arbitration agreement, which waived an employee's ability to bring a collective action under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., was enforceable under the Federal Arbitration Act, 9 U.S.C. 1 et seq. The court concluded that, after examining the FLSA's text, legislative history, purposes, and Supreme Court precedent, it discerned no "contrary congressional command" that precluded the enforcement of plaintiffs' Arbitration Agreements and their collective action waivers. The court concluded that plaintiffs' reliance on the Supreme Court's 1945 decision in Brooklyn Savings Bank v. O'Neil was materially distinguishable from this case. Accordingly, the court affirmed the judgment of the district court. View "Walthour, et al. v. Chipio Windshield Repair, LLC, et al." on Justia Law
Hurley v. Kent of Naples, Inc., et al.
Plaintiff filed suit against defendants under the Family Medical Leave Act (FMLA), 29 U.S.C. 2615, alleging that defendants wrongfully denied his request for eleven weeks of vacation time and terminated his employment. At trial, the jury found that plaintiff was not terminated because he requested leave, but nevertheless awarded him $200,000 in damages. The court concluded that the district court erred by denying defendants' motion for judgment as a matter of law on both plaintiff's claims because plaintiff was not eligible for leave under the FMLA where plaintiff admitted that his leave was not for a period of incapacity. Accordingly, the court reversed and remanded with instructions for the district court to vacate its order awarding attorney fees and to enter judgment in favor of defendants. View "Hurley v. Kent of Naples, Inc., et al." on Justia Law
Simpson, et al. v. Sanderson Farms, Inc., et al.
Plaintiffs filed a putative class action under the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961-68, alleging, inter alia, that Sanderson payed depressed wages to all genuinely work-authorized employees at its chicken processing plant. The court concluded that plaintiffs have failed to plausibly establish two of the elements of a civil RICO cause of action - that they suffered an injury in the form of wage depression, or that, even if the court were to assume that they had plausibly shown injury and but-for cause, their injury was directly and proximately caused by Sanderson's pattern of 18 U.S.C. 1546 violations. Accordingly, the court affirmed the judgment of the district court. View "Simpson, et al. v. Sanderson Farms, Inc., et al." on Justia Law
Martinez v. Carnival Corp.
Plaintiff, a Honduran citizen who suffered a back injury while employed as a mason aboard one of Carnival's ships, filed suit against Carnival in state court asserting claims of Jones Act, 46 U.S.C. 30104, negligence, unseaworthiness, and failure to provide adequate maintenance and cure. Plaintiff alleged that the physician chosen and paid by Carnival negligently performed his back surgery. Carnival removed to federal court. On appeal, plaintiff appealed the district court's order compelling arbitration of his claims under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (CREFAA), 9 U.S.C. 201-208. Plaintiff argued that his Jones Act claim did not fall within his employment contract ("Seafarer's Agreement") with Carnival and, therefore, was not within the scope of the contract's arbitration clause. The court concluded that the order compelling plaintiff to arbitrate his claims was "a final decision with respect to arbitration," and the court had appellate jurisdiction. The court also concluded that plaintiff's dispute with Carnival clearly arose out of or in connection with the Seafarer's Agreement and was subject to arbitration. Accordingly, the court affirmed the district court's order. View "Martinez v. Carnival Corp." on Justia Law
Franklin v. Curry, et al.
Plaintiff filed suit alleging that a corrections officer at the county jail sexually assaulted her. Officers other than the accused moved for dismissal on the basis of qualified immunity. The district court denied the motion. The court concluded that, in determining whether plaintiff alleged a constitutional violation, the district court made two related errors: it applied an incorrect legal standard and it allowed plaintiff to satisfy the standard it applied with conclusory allegations. Accordingly, the court held that plaintiff had failed to plead a constitutional violation and that the officers were therefore entitled to qualified immunity. View "Franklin v. Curry, et al." on Justia Law
Wallace, et al. v. NCL (Bahamas) Ltd.
Plaintiffs, seafarers who worked aboard cruise ships operated by NCL, filed suit under the Seaman's Wage Act, 46 U.S.C. 10313 et seq. Plaintiffs alleged that NCL did not pay them their full wages because their compensation did not take into account the amounts they were required to pay their helpers to complete their work on embarkation days. On appeal, plaintiffs argued that the district court erred in not awarding penalty wages under the Act. The court concluded that the district court made findings of fact which were supported by the record and the district court did not err by failing to award penalty wages based upon these findings. There was simply no evidence of willful, arbitrary, or willful misconduct on the part of NCL. Accordingly, the court affirmed the judgment of the district court. View "Wallace, et al. v. NCL (Bahamas) Ltd." on Justia Law