Justia Labor & Employment Law Opinion Summaries

After they were fired from their jobs, Appellants filed suit in federal district court against their former employer (Employer) and against the severance plan (Plan) established by Employer pursuant to ERISA. The complaint asserted federal claims under ERISA, ADEA, ADA, and other federal laws, and also asserted a breach of contract claim, an employment discrimination claim, and an unjustified dismissal claim under Puerto Rico law. The district court granted Appellees' motion for summary judgment. Appellants challenged that ruling as well as a number of the district court's other orders. The First Circuit Court of Appeals affirmed, holding that there was no error in the management of this case or the grant of Appellees' motion for summary judgment. View "Cruz v. Bristol-Myers Squibb Co., PR, Inc." on Justia Law

In an effort to reduce costs and achieve greater efficiency, Employer consolidated two lab operations into one, which resulted in a reduction in positions and in a Union losing jurisdiction over lab testing work that its members had previously performed. At issue in this appeal was Employer's obligations under national labor law to bargain with the union representing the affected employees. The National Labor Relations Board found (1) the lab work transfer decision involved a mandatory subject of bargaining so that Employer's refusal to bargain violated the National Labor Relations Act, and (2) the collective bargaining agreement between Employer and Union did not prohibit the work transfer without the Union's consent. The First Circuit Court of Appeals affirmed, (1) holding that the Board made no error of law in reaching its decision; and (2) granting the Board's petition for enforcement of its order requiring Employer to return to the Union certain work that Employer had transferred. View "Nat'l Labor Relations Bd. v. Solutia, Inc." on Justia Law

Plaintiff was severely injured in a workplace accident and sued Trail King, the custom manufacturer of the trailer involved in the accident. The First Circuit Court of Appeals affirmed a jury's finding that Defendant had not been negligent nor in breach of any warranty. In the trial court in that diversity case, Plaintiffs belatedly attempted to amend their complaint to add another claim, one under Mass. Gen. Laws ch. 93A for unfair and deceptive trade practices. The trial judge denied the motion, finding the effort to amend untimely. Plaintiffs did not appeal this denial in their earlier appeal. This case concerned whether Plaintiffs may now maintain an independent suit for the ch. 93A claims against Trail King. The district court dismissed the claims with prejudice, finding that the doctrine of claim preclusion applied. Plaintiffs appealed, arguing that ch. 93A, 9(8) provides an exception to the normal rules of res judicata. The First Circuit affirmed, holding that under the facts of this case, Plaintiffs may not now bring this ch. 93A claim because of the failure to appeal from the denial of the motion to amend. View "Hatch v. Trail King Indus., Inc." on Justia Law

In this case a corporation abruptly cashiered a member of senior management, which prompted the employee to file suit for age discrimination and retaliation. After a protracted trial, the jury found the employer guilty of retaliation and returned a seven-figure verdict in the employee's favor. The district court allowed the liability finding to stand, trimmed the damages but doubled what remained, refused to grant either judgment notwithstanding the verdict or an unconditional new trial, and awarded the prevailing plaintiff attorneys' fees and an equitable remedy. The First Circuit Court of Appeals affirmed the judgment below except vacated the previously remitted award of emotional distress damages and directed the district court to order the plaintiff either to remit all of that award in excess of $200,000 or else undergo a new trial on that issue. The Court also directed the district court to adjust its award of multiplied damages to reflect the plaintiff's response to this remittitur. View "Trainor v. HEI Hospitality, LLC" on Justia Law

In this appeal from the denial of a preliminary inunction, plaintiff labor unions claimed that sections 6.007-.010 of Law 222, Puerto Rico's campaign finance law, placed an unconstitutional burden on the union's First Amendment right to engage in political speech. Both the district court and the government declined to address the merits of Plaintiffs' claims. The First Circuit Court of Appeals issued an appellate injunction enjoining enforcement of the challenged provisions of Law 222 pending the final disposition of this appeal. In this opinion the First Circuit outlined the reasons it ordered entry of the appellate injunction, holding, among other things, that it was incumbent upon the district court to engage with the merits of Plaintiffs' claims. The Court also ordered the district court to enter a preliminary injunction enjoining the enforcement of certain sections of the law. View "Puertorriqueno v. Fortuno" on Justia Law

In this adverse employment action, Plaintiff appealed the district court's award of summary judgment to his former employer ("the Company") on his claims of age discrimination in violation of the Age Discrimination in Employment Act. On appeal, the First Circuit Court of Appeals noted inconsistencies between the Company's stated reasons for dismissal and Plaintiff's performance record at the Company, the lack of credibility that could be ascribed by a jury to certain of the Company's justifications for dismissal, and the fact that in response to arguably similar conduct by Plaintiff's younger replacement, the Company took no disciplinary action. The First Circuit reversed the district court's grant of summary judgment, holding that there was sufficient evidence presented on summary judgment from which a jury could draw the permissible inference that the Company's claimed reasons for terminating Plaintiff were pretextual and that the decision was the result of discriminatory animus. View "Acevedo-Parrilla v. Novartis Ex-Lax, Inc." on Justia Law

After Mark Jones repeatedly failed to pass an examination to receive a license required by his employer of all persons in that position, by a date of which he had many months' notice, he requested for the first time that the date be extended due to his medical condition. When his employer declined, and Jones declined to pursue an open alternate position at lesser pay, his employment ended. He then sued under both federal and state disability laws. The district court entered summary judgment for the employer. The First Circuit Court of Appeals affirmed, bypassing the question of whether Jones met the definition of "disability" and holding that the reasonable accommodation provisions of both statutes did not save his case. View "Jones v. Nationwide Life Ins. Co." on Justia Law

The issue in this case concerned a procedural requirement that must be satisfied in order to file suit under Title I of the Americans with Disabilities Act of 1990 (ADA). Pursuant to this requirement, a claimant must exhaust administrative remedies and file her Title I suit within ninety days after receiving a right-to-sue notice from the EEOC. The district court, citing this requirement, concluded that Plaintiff's Title I suit, which was filed 144 days after the EEOC sent the notice, was brought too late. To explain the delay, Plaintiff suggested that she did not receive the right-to-sue notice until nineteen days before she filed suit. The district court concluded that there is a presumption of timely receipt of a mailed notice and that Plaintiff did not furnish sufficient record evidence to rebut this presumption. The Supreme Court affirmed but on other grounds, holding that the action was time-barred, as Plaintiff had constructive notice of the ninety-day filing requirement, and yet her suit was commenced well after the expiration of that filing period. View "Loubriel v. Fondo del Seguro del Estado" on Justia Law

Defendant entered into a collective bargaining agreement (CBA) with a Union under which Defendant remitted contributions to an array of Union-affiliated benefit funds (the Funds). After the Funds commissioned audits of Defendant's books, the Funds demanded additional remittances for previously unreported work allegedly covered by the CBA. Defendant demurred, and the Funds sued Defendant. The district court awarded Plaintiffs $26,897 referable to covered work performed by a specific employee but denied recovery for other work. In a separate judgment, the court awarded Plaintiffs $34,688 in attorneys' fees. The First Circuit Court of Appeals vacated the judgment of the First Circuit, holding (1) the appeal was timely as to all issues, and the judgment on the benefits-remittance claim and the judgment awarding attorneys' fees were open to appellate review; (2) Defendant's failure to keep appropriate records concerning work covered by the benefit-remittance provisions of the CBA triggered a burden-shifting paradigm under which Defendant had to show which hours represented covered work and which did not, and here Defendant did not rebut the presumption; and (3) because the district court's fee calculation rested appreciably on the plaintiffs' lack of success in recovering remittances referable to unidentified employees, the fee award required recalculation. View "Int'l Union v. Ray Haluch Gravel Co." on Justia Law

This appeal involved an award of $59,787 in attorney's fees against unsuccessful plaintiffs in a civil rights action against the Municipality of Adjuntas, its mayor, and Plaintiffs' direct supervisors. Plaintiffs argued that their lawsuit was not so frivolous or unreasonable as to justify an award of fees to Defendants. The First Circuit Court of Appeals agreed, except for one plaintiff's inferior working conditions claim and another plaintiff's claim against a supervisory defendant, as there was no reasonable basis for those claims. The Court vacated the fee award and remanded for further proceedings relating to any attorney's fees incurred by the Municipality of Adjuntas in relation to those claims only. View "Torres-Santiago v. Municipality of Adjuntas" on Justia Law