Justia Labor & Employment Law Opinion Summaries

Plaintiff, a member of the Seventh-day Adventist faith, appealed from the district court's ruling on summary judgment that plaintiff's employer, First Student, reasonably accommodated his religion. Seventh-day Adventists observe the Sabbath from sundown Friday to sundown Saturday, and they emphasize the importance of refraining from secular work during this time. First Student terminated plaintiff for excessive absenteeism when he did not show up to work on Fridays. The court concluded that summary judgment was not appropriate at this stage of the litigation because there were genuine disputes of material fact regarding whether First Student reasonably accommodated plaintiff and whether accommodating plaintiff constituted an undue hardship on First Student. View "Antoine v. First Student, Inc." on Justia Law

Plaintiff sued Luminant, his employer, alleging several unlawful employment practices. The jury agreed with plaintiff that plaintiff's complaints motivated Luminant's decision to discipline him. The jury also found, however, that Luminant proved, by a preponderance of the evidence, that it would have made the "same decision" irrespective of his complaints. The district court entered judgment in Luminant's favor and taxed all costs against plaintiff. Plaintiff moved to retax costs and sought an award of attorney's fees. The court held that 42 U.S.C. 2000e-5(g)(2)(B)(i) authorized cost-and-fee-shifting only for violations of section 2000e-2(m). Retaliation did not violate section 2000e-2(m). Consequently, the district court correctly decided that section 2000e-5(g)(2)(B)(i) did not authorize cost-and-fee-shifting. Accordingly, the court affirmed the judgment of the district court. View "Carter v. Luminant Power Services Co." on Justia Law

Appellant, a former TWL employee, commenced a class action adversary proceeding within TWL's bankruptcy suit, alleging violations of the Worker Adjustment and Retraining Notification Act, 29 U.S.C. 2101-2109. The district court affirmed the bankruptcy court's order denying appellant's related motion for class certification and dismissed the adversary proceeding. Because the reasons for the bankruptcy court's order were unclear, the court vacated in toto the orders and remanded to the district court to remand to the bankruptcy court for reconsideration. The court expressed no view as to the outcome the bankruptcy court should reach on remand in reconsidering appellant's motion for reclassification and the Trustee's motion to dismiss the adversary proceeding. View "Teta v. TWL Corp., et al" on Justia Law

While serving time in the county jail, plaintiff labored in a county work program under the sheriff's supervision. At issue was whether plaintiff was covered under the Mississippi Workers' Compensation Act (MWCA), Mississippi Code 47-5-417, -567, and thus was entitled to compensation benefits for injuries sustained while he was on work detail. The county and the medical corporation that treated plaintiff sought reimbursement of medical expenses from the Mississippi Public Entities Workers' Compensation Trust (MPE), the provider of workers' compensation insurance from the county. The court concluded as a matter of law that the county had no enforceable contract to hire plaintiff, a prerequisite of coverage, and therefore, the court affirmed the district court's summary judgment in favor of MPE. View "Vuncannon, et al v. United States" on Justia Law

Plaintiff sued Transocean to recover maintenance and cure for a back injury allegedly sustained on the job. The district court awarded summary judgment to Transocean on its counterclaim to recover benefits it already paid to plaintiff, concluding that Transocean's successful McCorpen v. Central Gulf Steamship Corp. defense automatically established its right to restitution - a right of action never before recognized in maritime law. The court concluded that, though most courts have accepted McCorpen, Transocean's attempt to invoke the case as an affirmative right of recovery finds virtually no support, and the court was not inclined to accede. Accordingly, the court rejected Transocean's claim, and reversed and remanded the district court's judgment. View "Boudreaux v. Transocean Deepwater, Inc." on Justia Law

The Board applied for enforcement of its order upholding a decision of an ALJ invalidating a decertification election based on findings that, inter alia, Arkema violated the National Labor Relations Act (NLRA), 29 U.S.C. 158(a)(1), before an election by disciplining an employee for alleged harassment and sending an anti-harassment policy to employees. The court held that there was no substantial evidence to support the Board's finding that Arkema violated Section 8(a)(1). Because the court found no grounds for invalidating the decertification election, Arkema's reliance on the election results before their formal validation did not violate Section 8(a)(5). The court held that there was substantial evidence to support the Board's finding that a September 5 letter was a disciplinary action. However, there was no substantial evidence to support a finding either that Arkema demonstrated anti-union animus or that such animus was the motivating factor in providing the employee with a written confirmation of the meeting. Accordingly, the court denied the application for enforcement. View "NLRB v. Arkema, Inc." on Justia Law

Nabors appealed the district court's denial of its motion to compel the arbitration of plaintiff's age discrimination claim. When plaintiff began working for Nabors, plaintiff signed an Employee Acknowledgment Form indicating his agreement to resolve disputes through the Nabors Dispute Resolution Program. The court reversed the district court's order and remanded for entry of an order compelling arbitration because the court found that plaintiff agreed to conclusively resolve this dispute through arbitration. View "Klein v. Nabors Drilling USA, L.P." on Justia Law

Plaintiff appealed from the district court's dismissal of his suit alleging claims of equitable estoppel and breach of fiduciary duties pursuant to the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. The district court dismissed the complaint for failure to state a claim. The court held that plaintiff stated a claim for relief that was cognizable under ERISA, in light of CIGNA Corp. v. Amara. Because relief was available under the surcharge doctrine under Amara, the court did not address the equitable estoppel claim and the district court was free to consider that claim on remand. Finally, the district court did not err in dismissing Defendant Entergy Mississippi where plaintiff failed to allege that Entergy Mississippi sponsored or administered the plan or made any decisions with respect to his benefits. View "Gearlds, Jr. v. Entergy Services, Inc., et al" on Justia Law

Plaintiff, a former TDCJ employee, appealed the district court's grant of summary judgment for TDCJ on her Americans with Disabilities Act (ADA), 42 U.S.C. 12112(a), and Family Medical Leave Act (FMLA), 29 U.S.C. 2612(a)(1)(D), claims. Plaintiff's allergic reaction to the use of scented candles and wall plug-ins around her work area was the basis of her ADA claim. The court held that plaintiff did not suffer from a disability within the meaning and coverage of the ADA. Further, there was no dispute that TDCJ did not receive plaintiff's FMLA certification before the deadline. Accordingly, the court affirmed the judgment. View "Milton v. Texas Dept. of Criminal Justice" on Justia Law

Plaintiff sued the school district alleging that the district's decision to hire a Caucasian woman in lieu of promoting him amounted to race discrimination in violation of Title VII. The district court granted summary judgment to the district and ordered plaintiff to pay attorneys' fees. The court found no competent evidence from which a reasonable juror could infer that the district's decision to hire the woman in lieu of promoting plaintiff was motivated by impermissible racial considerations. The court held, however, that the district court's fee award constituted an abuse of discretion where the court did not agree that plaintiff's claim was frivolous, unreasonable, or without foundation. View "Autry v. Fort Bend Independent Sch. Dist." on Justia Law