Justia Labor & Employment Law Opinion Summaries

This appeal arose from an unsuccessful Title VII action brought by the Equal Employment Opportunity Commission (EEOC) against Great Steaks, Inc. The EEOC accused Great Steaks of subjecting female employees to a sexually hostile work environment. Although at the start of the case the EEOC asserted its claim on behalf of multiple claimants, that number diminished to one by trial. After a three-day trial, the jury rendered a verdict in Great Steaks' favor. Great Steaks subsequently moved for an award of attorneys' fees, maintaining it was entitled to such an award under three statutory provisions. The district court denied the motion for attorneys' fees in its entirety. On appeal, Great Steaks contended that the district court erred in doing so. Upon review of Great Steaks' claims of error and the laws it cited as grounds for relief, the Fourth Circuit found no abuse of discretion in the district court's decision. The Court affirmed the district court's decision.

This case arose when Union entered into a limited job-preference agreement with Peabody Coal where the agreement included an arbitration clause. The district court subsequently entered judgment in favor of Union, ruling that the arbitrator properly determined the arbitrability of the dispute. In the alternative, the district court concluded that the dispute was arbitrable, even if the arbitrator lacked authority to decide the arbitrability question. Peabody Coal appealed. The court held, as an initial matter, that the court, not the arbitrator must decide whether the dispute was arbitrable. The parties' agreement lacked the requisite "clear and unmistakable" language evincing an intent to arbitrate arbitrability. Exercising the court's independent judgment on the arbitrability question, the court concluded that Peabody Coal had not rebutted the ordinary presumption in favor of arbitrability. Accordingly, the court affirmed the judgment and the parties must proceed to arbitration.

Plaintiff brought suit against her former employer, alleging that the employer violated Maryland law when at the time of her termination, it failed to pay her for unvested shares earned through the employer's long-term profit sharing plan. The district court granted the employer's motion to dismiss under Rule 12(b)(6). The court affirmed the district court's holding that New Jersey law applied to the contract because the Maryland statute was not a fundamental public policy of Maryland and that the unvested shares were not wages under New Jersey law. Even if Maryland law applied, the unvested shares were not wages under the Maryland statute and thus were never owed to plaintiff.

The former trustees of the Plasterers' Local Union No. 96 Pension Plan appealed from the judgment of the district court in favor of the current trustees of the Plan. The district court's judgment was based on its finding that the former trustees breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., regarding the investment Plan assets set forth under 29 U.S.C. 1104(a)(1)(B) and (C). On appeal, the former trustees challenged the district court's determination as to liability, its method of calculating damages, and the award of attorney fees. The court concluded that the district court erred as to each of these issues and therefore vacated the judgment and remanded the case for further proceedings.

Plaintiff filed a complaint under Title VII against her former employer, alleging that it engaged in religious discrimination and retaliation against her. After the district court denied the employer's motion for summary judgment, the employer filed an interlocutory appeal, contending that the plain language of 42 U.S.C. 2000e-1(a), the religious organization exemption, barred plaintiff's claims. The court held that because the plain language of section 2000e-1(a) exempted religious organizations like the employer from plaintiff's claims of religious discrimination, the district court erred in denying the employer's motion for summary judgment. Therefore, the court reversed the district court's order and remanded with instructions to enter judgment in favor of the employer.

Petitioner appealed the decision of the U.S. Department of Labor's Benefits Review Board (BRB) affirming an ALJ's award of disability benefits, two hearing aids, and attorney's fees to respondent pursuant to the Longshore and Harbor Workers' Compensation Act (LHWCA), 33 U.S.C. 901-950. Plaintiff contended that the ALJ contravened Supreme Court precedent by failing to adhere to the burden of proof as established in Director, OWCP v. Greenwich Collieries. The court agreed with plaintiff and reversed the BRB's decision, holding that the BRB committed a clear error of law when it affirmed the ALJ's decision and order, relying on its own precedent rather than the controlling law set forth in Greenwich Collieries.

In this appeal, accounting firm Bryan Brothers sought coverage under a professional liability insurance policy issued by Continental Casualty Company for liability arising from illegal acts of a former Bryan Brother's employee. Under the policy, it was a condition precedent to coverage that no insured had knowledge, prior to the inception of the policy, of an act that was reasonably likely to become the basis for a claim. The court held that because Bryan Brothers had such knowledge, the claims at issue were not covered. Therefore, the court affirmed the district court's grant of summary judgment to Continental Casualty Company.

Retirees filed suit in district court contending that their retiree health benefits were vested and that defendant's intended modification would violate both the Labor Management Relations Act, 29 U.S.C. 185, and the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B). Retirees subsequently appealed the denial of their motion for a preliminary injunction seeking continuation of certain healthcare benefits. The court held that the district court issued a thorough and well-reasoned opinion explaining in detail that the retirees failed to establish a likelihood of success on the merits. Accordingly, the court affirmed the district court's denial of the motion for preliminary injunction.

Plaintiff commenced this action under the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. 215(a)(3), against defendant, alleging that defendant retaliated against her by refusing to hire her after learning that she had sued her former employer under the FLSA. At issue was whether an applicant for employment was an "employee" authorized to sue and obtain relief for retaliation under section 216(b) of the FLSA. The court held that, based on the statutory text, the FLSA gave an employee the right to sue only his or her current or former employer and that a prospective employee could not sue a prospective employer for retaliation. Therefore, the court affirmed the judgment of the district court.

Appellant challenged the grant of summary judgment for her employer when her boss forcibly kissed her, fondled her leg, propositioned her, asked sexually explicit questions, described sexual activities he wished to perform, and then, after she spurned the advances and filed a harassment complaint, fired her. The court held that because those allegations were sufficient to make out claims of hostile work environment, quid pro quo harassment, and retaliation, the court vacated and remanded for further proceedings.