Justia Labor & Employment Law Opinion Summaries

Teruggi worked for CIT from 1997 until his 2009 discharge, as vice president. In 2002, Teruggi suffered a workplace injury to his right hand. In 2006, doctors amputated the little finger on his right hand and removed the connecting bones to his wrist. Teruggi filed a workers’ compensation claim and requested reasonable accommodation with respect to computer use. After other incidents involving sharing email, Terruggi, then 59 years old, was discharged for failure to protect confidential information. He sued, alleging retaliation and discrimination under the Age Discrimination in Employment Act, 29 U.S.C. 621, and the Americans with Disabilities Act, 42 U.S.C. 12101. The district court granted summary judgment in CIT’s favor, finding that Teruggi’s “mosaic of circumstantial evidence” less than convincing. The Seventh Circuit affirmed. The bits of evidence Teruggi offered were essentially isolated events or comments with no apparent connection to the termination decision and did not support a reasonable inference of discrimination or retaliatory discharge, either individually or collectively. View "Teruggi v. CIT Group/Capital Fin., Inc" on Justia Law

A new owner informed paper mill employees that it was closing the mill with a likely shut-down date in late April. In March, plaintiffs received letters stating that their employment was being terminated effective May 2 and that, in exchange for a release, they would receive a severance package. Before plaintiffs submitted their executed release forms, the company indicated that it was no longer accepting release agreements and that it had decided to keep the plant open until October. Plaintiffs nonetheless signed and submitted the release and separation agreements they had received two weeks earlier. The company later stated that it would be extending a new severance offer and a bonus as an incentive to stay with the mill until October. Plaintiffs both stopped working at the mill on May 2 and started new jobs. The mill continued to operate. After leaving the mill and not receiving severance, plaintiffs requested it from the company’s severance plan. The plan administrator concluded that the two had voluntarily terminated their employment and denied their requests. Plaintiffs sued under the Employee Retirement Income Security Act, 29 U.S.C. 1132(a)(1)(B).. The district court granted the plan summary judgment. The Seventh Circuit affirmed. View "Reddinger v. SENA Severance Pay Plan" on Justia Law

The Equal Employment Opportunity Commission filed this employment discrimination case on behalf of Shepherd, a former sales clerk at AutoZone, alleging that AutoZone had violated the Americans with Disabilities Act. Shepherd had a back injury that was aggravated by mopping floors, and he claimed that AutoZone required him to mop floors despite his requests for relief. The EEOC alleged that AutoZone had failed to accommodate Shepherd’s disability. The magistrate judge initially granted AutoZone summary judgment on the accommodation claim. The Seventh Circuit reversed. On remand, a jury returned a verdict in Shepherd’s favor. The judge then approved $100,000 in compensatory damages, $200,000 in punitive damages, $115,000 in back pay, an injunction on AutoZone’s anti-discrimination practices, and the EEOC’s motion to vacate a prior award of costs to AutoZone from the first trial. The Seventh Circuit affirmed, but remanded the injunction for imposition of a reasonable time limit. The award of compensatory damages was not excessive when compared to Shepherd’s pain and suffering; the jury heard sufficient evidence of AutoZone’s reckless indifference to Shepherd’s federal employment rights and because the punitive damages award was not grossly excessive under the Due Process Clause. View "Equal Emp't Opportunity Comm'n v. Autozone, Inc." on Justia Law

The railroad fired a locomotive engineer, Narron. The union filed a grievance, which eventually came before the National Railroad Adjustment Board, which ordered the railroad to reinstate Narron with back pay but authorized the railroad to offset the back pay by any earnings that he had obtained between his firing and his reinstatement. The union filed a petition in the district court challenging that part of the award. The district judge remanded for determination of whether Narron had had any such earnings and ordered the earnings-offset provision vacated. The Seventh Circuit vacated the order, holding that the district court exceeded its authority. A district court may set aside a Board order only “for failure of the division to comply with the requirements of [the Railway Labor Act]” or “to conform, or confine itself, to matters within the scope of the division’s jurisdiction,” or “for fraud or corruption by a member of the division,” 45 U.S.C. 153. View "Bhd of Locomotive Eng'rs & Trainment v. Union Pac. R.R. Co." on Justia Law

James has been an employee of Hyatt Regency Chicago since 1985. In 2007, James took a leave of absence due to an eye injury that occurred outside of work. James filed suit in 2009 claiming that Hyatt violated his rights under the Family Medical Leave Act, 29 U.S.C. 2601 and the Americans with Disabilities Act, 42 U.S.C.12101. During discovery, the district court denied James’ motions to compel and awarded Hyatt a portion of attorney’s fees it expended responding to motions. The court subsequently granted Hyatt summary judgment. The Seventh Circuit affirmed. In light of the limitations imposed by his doctors, Hyatt did not violate the FMLA or the ADA in refusing to allow James to return to work for “light duty” before doctors released him to perform functions essential to his position. James used discovery as a weapon, rather than as a tool to gather evidence. View "James v. Hyatt Regency Chicago" on Justia Law

When an employer participating in a multi-employer pension plan withdraws from the plan with unpaid liabilities, federal law can pierce corporate veils and impose liability on owners and related businesses. The Fund is a multi-employer pension plan under the Employee Retirement Income Security Act/Multiemployer Pension Plan Amendments Act, 29 U.S.C. 1381-1461. Messina Trucking was subject to a collective bargaining agreement that required it to contribute to the Fund for retirement benefits. Messina Trucking permanently ceased to have an obligation to contribute to the Fund, triggering a “complete withdrawal” and incurring nearly $3.1 million in potential withdrawal liability. The Fund sought a declaratory judgment that defendants were jointly and severally liable for the withdrawal liability as “trades or businesses” under “common control” with Messina Trucking. The district court held that Mr. and Mrs. Messina, who owned and leased several residential properties as well as the property from which Messina Trucking operated, were not engaged in a “trade or business” and could not be held liable for the withdrawal liability, but that Messina Products, as a formal business organization could be held liable for Messina. The Seventh Circuit ruled in favor of the Fund, holding that both can be held liable. View "Cent. States Se & Sw Areas Pension Fund v. Messina" on Justia Law

Eight members of the Teamsters’ Union sued their former employer under the Labor-Management Relations Act, for terminating their employment on grounds forbidden by a collective bargaining agreement and sued their union, Local 705, for settling their grievances for an unsatisfactory sum, allegedly violating its duty of fair representation. The district dismissed. The Seventh Circuit affirmed, holding that it lacked jurisdiction over the claim against Local 705. “Hybrid” claims for violations of a collective bargaining agreement pursuant to 29 U.S.C. 185(a) may be asserted against an employer and a union when the employee needs the union to litigate a grievance. But the employees in this case did not need Local 705 to litigate their grievance, because as soon as the employer repudiated the arbitration procedure mandated by the contract, the employees could have gone straight to federal court with a claim solely against the employer. The claim against the union is not part of a “hybrid” and fails on the merits because the collective bargaining agreement expired before the plaintiffs were terminated, so no agreement was violated. The union had provided an unambiguous, timely notice to terminate the collective bargaining agreement. View "Rutherford v. Judge & Dolph, Ltd." on Justia Law

McArdle was hired as principal of Lindbergh School in 2008 with a two-year contract that allowed termination after one year with payment of severance. Lindbergh’s prior principal, Davis, was McArdle’s superior. McArdle claims that she discovered irregularities, including Davis’ use of school funds for personal purposes; improper payment to a student teacher; and circumvention of rules regarding admission of nonresidents. McArdle alleges that she received evasive responses from Davis. Davis put McArdle on a performance improvement plan in 2009, asserting parental complaints, but refusing to identify complainants. McArdle was told that the board would consider termination of her contract. McArdle consulted an attorney and filed a police report, accusing Davis of theft of school funds. She sent letters to the board, listing improprieties. Davis was excused from the meeting; the board discussed McArdle’s allegations, then voted to terminate McArdle’s contract at the end of the school year. Davis was prosecuted for theft of school funds. The district court granted defendants summary judgment on claims under the First Amendment and of breach and interference with contract. The Seventh Circuit affirmed. McArdle’s reporting of misconduct was speech as a public employee, not shielded from her employer’s response; defendants’ motives are immaterial. View "McArdle v. Peoria Sch. Dist. 150" on Justia Law

In consolidated cases, business owners appealed the district court’s denial of a preliminary injunction against enforcement of provisions of the Patient Protection and Affordable Care Act and related regulations requiring group health insurance coverage for contraception and sterilization procedures, 42 U.S.C. 300gg‐13(a)(4). Employers who do not comply face a penalty of $100 per day per employee and an annual tax surcharge of $2,000 per employee, 29 U.S.C. 1132(a). The Seventh Circuit granted an injunction, pending appeal, concluding that the businesses had established a reasonable likelihood of success on their claims, that the equitable balance favored granting the injunction; and that harm to religious‐liberty rights outweighed the temporary harm to the government’s interest in providing greater access to cost‐free contraception and related services. The court rejected arguments that a secular, for‐profit corporation cannot assert a claim under Religious Freedom Restoration Act, 42 U.S.C. 2000 bb; that the free‐exercise rights of the individual plaintiffs are not affected because their corporation is a separate legal entity; and that the mandate’s burden on free‐exercise rights is too remote and attenuated to qualify as “substantial” because the decision to use contraception benefits is made by third parties, individual employees, in consultation with their medical providers. View "Grote v. Sebelius" on Justia Law

Pharmaceutical company (Baxter) offered Dr. Rapold, who is Swiss and was living in Europe, the position of Medical Director of Cellular Therapy at its Illinois headquarters. The position was described as “at will.” Unable to wait while Rapold obtained a visa, Baxter entered into a consulting agreement with Rapold to enable him to begin work immediately from Europe. During the six-month consultancy, there were reports of problematic behavior involving rudeness and fits of anger. Baxter revoked the offer. The district court rejected his nationality discrimination claim under Title VII, 42 U.S.C. 2000e. The Seventh Circuit affirmed, rejecting an argument that the district court erred by refusing to tender his proffered mixed-motive jury instruction. View "Rapold v. Baxter Int'l, Inc." on Justia Law