Justia Labor & Employment Law Opinion Summaries

U.S. Steel appealed the award of benefits to plaintiff, the widow of a deceased miner, under the black lung benefits program. The Benefits Review Board affirmed the award, concluding that plaintiff did not need to show the cause of her husband's death. The court concluded that 30 U.S.C. 932(l), as amended by section 1556(b) of the Patient Protection and Affordable Care Act, Pub. L. No. 111-148, 1556(b), 124 Stat. 119, 260, eliminated the need for survivors who could meet its requirements to prove that their associated miners died due to black lung disease; it applied retroactively to survivors' claims filed in the specified period; and this retroactive application did not violate the Due Process Clause of the Fifth Amendment. Accordingly, the court denied U.S. Steel's petition to review the Board's ruling. View "U.S. Steel Mining Co., LLC v. Director, OWCP, et al." on Justia Law

Plaintiff claimed that defendants failed to pay her the minimum wage under federal and state law while she worked as a nanny for them. On appeal, plaintiff challenged the district court's judgment concluding that defendants did not willfully violate federal minimum wage laws, 28 U.S.C. 206(a), and the minimum wage laws of Florida, Fla. Const. Art. 10, section 24(e), and that plaintiff was not entitled to liquidated damages under the Fair Labor Standards Act, 29 U.S.C. 216. The court vacated and remanded, concluding that plaintiff introduced sufficient evidence for a reasonable jury to find that defendants willfully violated the minimum wage laws and the district court could not rule on plaintiff's motion for liquidated damages before the jury decided whether defendants willfully violated the minimum wage laws. View "Davila v. Menendez, et al." on Justia Law

This case involved Executive Order 11-58 (EO), which mandated two types of suspicionless drug testing: random testing of all employees at state agencies within the Governor of Florida's control, and pre-employment testing of all applicants to those agencies. In this case, the district court declared the EO unconstitutional as to all current state employees. This relief swept too broadly, enjoined both constitutional and unconstitutional applications of the EO, and did so without examining the specific job categories to be tested. What the Supreme Court's case law required, in contrast, was that the trial court balance the governmental interests in a suspicionless search against each particular job category's expectation of privacy. Accordingly, the court vacated the district court's order granting summary judgment to the Union and denying summary judgment to the State. On remand, the State must meet its burden of demonstrating important special needs on a job-category-by-category basis. View "American Federation of State, County, and Municipal Emp'ees Council 79 v. Scott" on Justia Law

Plaintiff sued Coca-Cola, his employer, alleging that the psychiatric/psychological fitness-for-duty evaluation he was required to undergo violated 42 U.S.C. 12112(d)(4)(A), a provision of the Americans with Disabilities Act (ADA). The court affirmed the district court's grant of summary judgment for Coca-Cola, concluding that the evaluation was both job-related and consistent with business necessity and, therefore, permissible under the ADA. View "Owusu-Ansah v. The Coca-Cola Co." on Justia Law

This case stemmed from a dispute involving an administrative complaint filed by the Board against Mardi Gras, claiming that Mardi Gras unlawfully discharged employees who were involved in a union organizing campaign on behalf of the Union. The Board appealed from the district court's decision to deny the Board temporary injunctive relief pending a final order from the Board in administrative proceedings. The court held that the district court did not abuse its discretion in concluding that the temporary reinstatement of six discharged employees was not a "just and proper" form of relief requested by the Board under section 10(j) of the National Labor Relations Act, 29 U.S.C. 160(j). Accordingly, the court affirmed the judgment. View "National Labor Relations Board v. Hartman and Tyner, Inc., et al" on Justia Law

Plaintiff, on behalf of herself and the Estate, challenged the district court's grant of summary judgment to Zenith on the Estate's breach of the insurance contract claim. After review and oral argument, the court certified questions to the Florida Supreme Court: (1) Does the estate have standing to bring its breach of contract claim against Zenith under the employer liability policy? (2) If so, does the provision in the employer liability policy which excludes from coverage "any obligation imposed by workers' compensation . . . law" operate to exclude coverage of the estate's claim against Zenith for the tort judgment? (3) If the estate's claim was not barred by the workers' compensation exclusion, does the release in the workers' compensation settlement agreement otherwise prohibit the estate's collection of the tort judgment? View "Morales v. Zenith Ins. Co." on Justia Law

Plaintiff filed a complaint that her former employer discriminated against her after she became pregnant. At issue was whether direct estoppel barred a claim of pregnancy discrimination under state law when a jury found at trial that plaintiff suffered no adverse employment action regarding her claim of retaliation for exercising her right to maternity leave under federal law. The court concluded that the jury verdict against plaintiff's claim of retaliation estopped plaintiff from relitigating the common issue of whether she suffered an adverse employment action. Accordingly, the court affirmed the grant of summary judgment against plaintiff's claim of pregnancy discrimination. View "DuChateau v. Camp, Dresser & McKee, Inc." on Justia Law

Koch Foods appealed the final decision and order issued by the Administrative Review Board (ARB) of the Department of Labor (DOL), in which the ARB determined that Koch Foods had violated the whistleblower protection provision of the Surface Transportation Assistance Act (STAA), 49 U.S.C. 31105(a)(1)(B)(i), by firing its employee, respondent Timothy Bailey. Bailey argued that he was fired for refusing to drive a vehicle he believed was overweight in violation of state and federal law. After reviewing the plain language of the provision and its statutory context, as well as the relevant statutory history, the court held that the phrase "refuses to operate a vehicle because ... the operation violates a regulation, standard, or order," as used in section 31105(a)(1)(B)(i), referred only to circumstances in which operation would result in an actual violation of law. Accordingly, the court vacated the ARB's decision and remanded so that the ARB could evaluate whether the operation of Bailey's assigned vehicle would have resulted in an actual violation of a regulation, standard, or order related to commercial motor vehicle safety, health, or security. View "Koch Foods, LLC v. Secretary, U.S. Dept. of Labor, et al" on Justia Law

Plaintiffs brought this action under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., to recover unpaid overtime wages. The jury found in favor of plaintiffs and the district court determined that plaintiffs were entitled to liquidated damages in an amount equal to their actual damages. Defendants subsequently appealed the district court's denial of their motion for judgment as a matter of law and motion for new trial. The court held that the district court was correct to deny defendants' motion for judgment as a matter of law based on the in pari delicto doctrine; the district court did not err in giving the jury instructions; the district court did not commit evidentiary errors; the evidence of plaintiffs' overtime hours was sufficient to support the jury's verdict and the district court did not err in denying defendants' Rule 50 motion; defendants failed to satisfy their burden of showing that a certain employee was unavailable as a witness and the district court did not err by excluding the CEO's testimony as hearsay; and the district court did not abuse its discretion regarding the amounts defendants were required to withhold for payroll taxes. Accordingly, the court affirmed the judgment. View "Lamonica, et al v. Safe Hurricane Shutters, Inc., et al" on Justia Law

Plaintiffs filed suit against defendants, Appliance Direct and its CEO, alleging that defendants retaliated against them for filing an overtime lawsuit, in violation of the Fair Labor Standards Act (FLSA), 29 U.S.C. 201-219. Both parties subsequently appealed from the district court's judgment. The court held that reasonable jurors could differ as to whether the CEO was an employer under the requirements of the FLSA, but considering the evidence in the light most favorable to plaintiffs, the district court properly denied his motions for judgment as a matter of law; the evidence was sufficient for a jury to award plaintiffs compensatory damages in the amount of $30,000 each, and the district court did not abuse its discretion in denying the CEO's motions on this ground; and the district court did not abuse its discretion in declining to award liquidated damages. Accordingly, the court affirmed the judgment. View "Moore, et al v. Pak" on Justia Law