Justia Labor & Employment Law Opinion Summaries

Plaintiff filed suit under the Family Medical Leave Act, 29 U.S.C. 2601, against defendants, alleging that defendants demoted her from a ninety-day temporary assignment in retaliation for leaving work to care for an ailing uncle. On appeal, plaintiff contended that defendants were equitably estopped under federal common law from disputing her FMLA eligibility because her manager approved her FMLA leave. The court concluded that plaintiff failed to provide evidence or even assert that she relied on any misrepresentation. Assuming that federal common law equitable estoppel applied to the FMLA, plaintiff failed to assert a prima facie case of estoppel. Accordingly, the court affirmed the district court's grant of summary judgment for defendants. View "Dawkins v. Fulton County, et al." on Justia Law

Plaintiff filed suit against her employer for gender discrimination, racial discrimination, and national origin discrimination under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000 et seq., as well as hostile work environment, unlawful retaliation claims, and state law claims. On appeal, plaintiff challenged the district court's grant of summary judgment in the employer's favor. The court concluded that plaintiff has made out a prima facie case of employment discrimination, but it remained unclear as to whether she created a dispute of material fact regarding whether the reason the employer offered for hiring another employee over her was a pretext for discriminatory animus. Accordingly, the court vacated the district court's grant of summary judgment in favor of the employer regarding plaintiff's employment discrimination claim, remanding for further proceedings. The court affirmed in all other respects. View "Kidd v. Mando American Corp." on Justia Law

Plaintiff filed suit under 42 U.S.C. 1983 against the City and others after he was fired from the police department for violating department policies. On appeal, plaintiff challenged the district court's grant of summary judgment in favor of defendants. The court concluded that the district court correctly concluded that plaintiff failed to establish that any of the personnel, internal affairs, or disciplinary decisions about which he complained was made by a final policy maker for the City such that municipal liability attached; plaintiff's First Amendment claims failed because he could not establish that his speech played a substantial part in the police department's decision to conduct internal affairs investigations or terminate him; and plaintiff's false arrest, imprisonment, and malicious prosecution claims also failed because he has not presented any evidence that he was arrested without probable cause and the evidence could not be read to establish that there was a causal connection between either of the individual defendants' actions and plaintiff's arrest, imprisonment, and prosecution. Accordingly, the court affirmed the grant of summary judgment to all defendants. View "Carter, Jr. v. City of Melbourne, FL, et al." on Justia Law

This case arose when three former employees of ASU alleged that they were subjected to a hostile work environment and retaliation during their employment. ASU appealed the district court's judgment. The court concluded that the district court did not err in denying ASU's motion to sever where the district court had broad discretion to deny the severance in the interest of judicial economy; the court did not have jurisdiction to hear ASU's appeal of the district court's denial of its Rule 50(b) and 59(b) motion where ASU had not filed a notice of appeal with the district court clerk; and the district court did not abuse its discretion in awarding front pay. Accordingly, the court affirmed in part and dismissed in part. View "Weatherly, et al. v. Alabama State University" on Justia Law

Employees of MCGP filed suit under the Worker Adjustment and Retraining Act of 1988 (WARN Act), 29 U.S.C. 2101-2109, alleging that MCGP thrice violated the WARN Act's requirement that an employer provide employees 60-days' notice prior to a plant closing or mass layoff. The court affirmed the district court's classification of the February and August layoffs as plant closings; affirmed the district court's determination that MCGP was not entitled to invoke the unforeseeable business circumstances defense; and reversed in part and remanded so that the district court could properly determine whether the employees that MCGP laid off in January were "affected employees" as a result of the February plant closing under the WARN Act, and were thus entitled to notice. View "Weekes-Walker, et al. v. Macon County Greyhound Park, Inc." on Justia Law

Plaintiff filed suit under the Fair Labor Standards Act (FLSA), 29 U.S.C. 207(a)(1), against her employer and subsequently settled the action without an attorney. Applying Lynn's Food Stores, Inc. v. United States, the court concluded that the agreement between the parties was not made under the supervision of the Secretary of Labor, so it was valid only if the district court entered a "stipulated judgment" approving it. In this case, the district court did enter a judgment but it was not a stipulated one. Accordingly, the district court should not have granted the opposed motion to approve and enforce the settlement agreement and dismissed the complaint. Accordingly, the court vacated and remanded for further proceedings. View "Nall v. Mal-Motels, Inc., et al." on Justia Law

ComTran petitioned for review of the Commission's final decision holding that ComTran violated standards under the Occupational Safety and Health Act (OSHA), 29 U.S.C. 651 et seq., when one of its supervisors was caught digging in a six-feet deep trench with an unprotected five-feet high "spoil pile" at the edge of the excavation. The court concluded that it was not appropriate to impute a supervisor's knowledge of his own violative conduct to his employer under the Act, thereby relieving the Secretary of her burden to prove the "knowledge" element of her prima facie case. Therefore, the Commission acted arbitrarily, capriciously, and otherwise not in accordance with the law. Accordingly, the court granted the petition, reversed the decision, and remanded for further proceedings. View "ComTran Group, Inc. v. U.S. Dept. of Labor" on Justia Law

Plaintiff sued her employer, the Alabama Board of Pardons and Paroles, originally alleging federal civil rights and state age discrimination claims. The Board then removed the case to federal court, invoking the district court's subject-matter jurisdiction under 28 U.S.C. 1331. After removal, plaintiff amended her complaint alleging various federal and state law claims. The district court dismissed all of plaintiff's federal claims other than the Age Discrimination in Employment Act, 29 U.S.C. 621-634, claim for failure to state a claim. The court concluded that the Board waived its defense of immunity from litigation in federal court when it removed to federal court, but the Board did not waive its immunity from ADEA liability. Accordingly, the court affirmed the district court's judgment. View "Stroud v. McIntosh, et al." on Justia Law

Plaintiffs appealed the district court's order on summary judgment holding that they were "independent contractors," instead of "employees," and were not entitled to overtime and minimum wage protections under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq. The court concluded that, viewing the facts most favorably towards plaintiffs and with all justifiable inferences drawn in their favor, plaintiffs were "employees" under the FLSA. Because there were genuine issues of material fact, and because plaintiffs were "employees," the district court erred in granting summary judgment to Knight. Accordingly, the court reversed the district court's summary judgment order and remanded for further proceedings. The court affirmed, however, the district court's denial of plaintiffs' motions to reopen the opt-in period, for protective order, for corrective notice, and for sanctions. View "Scantland, et al. v. Knight, Inc., et al." on Justia Law

Plaintiffs, the superintendent of education and her assistant superintendent, filed suit claiming that the board and its members in both their official and individual capacities terminated the superintendent and demoted the assistant superintendent in retaliation for public comments plaintiffs made about local tax policy. The court concluded that it had jurisdiction over the appeal of the denial of qualified immunity, but lacked jurisdiction over the appeal of the board and its officials. Accordingly, the court dismissed the appeal of the board and its officials for lack of jurisdiction and reversed the denial of qualified immunity for the individual members of the board. View "Leslie, et al. v. Hancock County Board of Education, et al." on Justia Law