Justia Labor & Employment Law Opinion Summaries

Plaintiff sued her former employer alleging violations of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The district court found in favor of plaintiff and awarded back pay, front pay, and liquidated damages. The court rejected defendant's challenges to the district court's finding of liability. Even if defendants did not waive the affirmative defense of failure to mitigate damages, the court agreed with the district court's alternative holding that plaintiff's efforts to secure other employment were reasonable. The court vacated the award of front pay as overly speculative but affirmed the district court's judgment in all other respects. View "Dollar v. Smithway Motor Xpress, et al" on Justia Law

Plaintiff appealed the district court's dismissal of his complaint, filed in forma pauperis (IFP), for untimely service of process and failure to state a claim. Plaintiff claimed that First Student fired him from his position as a bus driver based on his race, age, disability, seniority rights, and eligiblity for a pay raise. The court vacated the district court's order, remanding for further proceedings, because the court concluded that the complaint stated a claim and because the court could not determine from the record whether the delay in service of process was plaintiff's fault or was attributable to delays by district court staff and the USMS. View "Wright v. First Student, Inc." on Justia Law

Debtor appealed from the judgment of the bankruptcy court. At issue was whether the bonuses debtor received from her employer were considered property of debtor's estate. Because the bankruptcy appellate panel (BAP) held that the bonus payments were not property of debtor's bankruptcy estate because she had no cognizable interest in the payments on the date the petition was filed, the court must reverse the bankruptcy court's revocation of debtor's discharge pursuant to 11 U.S.C. 727(d)(2); avoidance of the transfer under 11 U.S.C. 549 of bonus funds she received postpetition from her employer and entering judgment for recovery of those funds by the Chapter 7 trustee, pursuant to 11 U.S.C. 550; and granting the trustee's motion for costs filed by the trustee pursuant to Federal Rule of Bankruptcy Procedure 7054(b). View "Seaver v. Klein-Swanson" on Justia Law

Gear Automotive appealed from the district court's grant of summary judgment in favor of its insurer. Gear Automotive's sole owner suffered an injury that resulted in substantial medical and disability loss. Gear Automotive subsequently sought coverage from its insurer for the owner's injuries. The court concluded that the owner was an employee for purposes of employing the Employee exclusion and that the owner's injury arose out of and in the course of his employment with Gear Automotive. Because the undisputed facts established both elements of the Employee exclusion, Gear Automotive was not entitled to coverage. Ultimately, the owner, as an employee, attempted to recover under a policy of insurance that was not intended to cover Gear Automotive's liability to its employees. Accordingly, the court affirmed the district court's grant of summary judgment. View "Gear Automotive v. Wilshire Ins. Co." on Justia Law

Chrylser appealed an adverse jury verdict in favor of plaintiff on a retaliation claim under the Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213. Plaintiff cross-appealed, claiming that the district court improperly granted a motion for directed verdict on a punitive-damages claim and improperly reduced the attorney's fee award. The court held that the jury instruction on plaintiff's retaliation claim was proper; evidence was sufficient to support the verdict under the MHRA "contributing factor" standard; and the evidence was sufficient to support the jury's economic-damages award. The court affirmed the district court's refusal to submit the punitive damages claim to the jury. Because plaintiff also requested attorney's fees for time spent on post-trial motions and appellate work, however, the court remanded to the district court for consideration of this request, leaving the issue to the district court's discretion. View "Al-Birekdar v. Chrysler Group, LLC" on Justia Law

Plaintiff sued United Systems for sex and disability discrimination after she was terminated. After plaintiff prevailed on both claims, United Systems appealed the district court's denial of its post trial motions for judgment as a matter of law and for remittitur of the mental anguish damages. The court concluded that a legally sufficient basis existed for a reasonable jury to determine that plaintiff had made a showing that she had been discriminated against by her employer. Since the court concluded that the district court did not err in denying United Systems' motion for judgment as a matter of law on plaintiff's sex discrimination claims, the court need not address the denial of the motion on her disability discrimination claims. Considering precedent and the record made in this case, the court could not conclude that the award of $100,000 to plaintiff was monstrous, shocking, or grossly excessive. Accordingly, the district court did not manifestly abuse its discretion in denying the motion for remittitur. View "Hudson v. United Systems of Arkansas, Inc." on Justia Law

Plaintiff filed claims against the county and its officials alleging unlawful suspension and discharge, sex discrimination, retaliation, violation of her procedural and substantive due process rights, and civil conspiracy. The court held that plaintiff's claims were not time barred under Tyler v. University of Arkansas Board of Treasurers; plaintiff had suffered tangible job detriments in the form of her suspension and terminations, but plaintiff failed to show that her rejection of her supervisor's advances caused that detriment; plaintiff could not establish a prima facie case of a hostile work environment because she did not allege sufficiently severe or pervasive conduct; plaintiff's allegations of different treatment were insufficient to establish a prima facie case of discrimination; plaintiff failed to establish the requisite causal relationship to show a violation of the First Amendment in respect to her EEOC charge and her complaints about her supervisor; and plaintiff did not articulate how the county and its officials violated her Fourteenth Amendment rights of due process and equal protection. Accordingly, the court affirmed the district court's grant of summary judgment to the county and its officials. View "Butler v. Crittenden County, Arkansas, et al" on Justia Law

Plaintiff, who is visually impaired, filed suit against BNSF, alleging that BNSF retaliated against him for reporting a safety violation and that BNSF discriminated against him based on his disability. The district court granted summary judgment in favor of BNSF on the whistleblower claim, and the jury found in favor of BNSF on the discrimination claims. The court held that plaintiff's whistleblower claim was untimely and summary judgment should have been granted on that ground; the district court did not err in excluding as irrelevant the evidence of plaintiff's safety complaint; sufficient evidence supported the jury's finding that plaintiff could not perform the essential functions of the locomotive machinist position with or without reasonable accommodation; and the district court did not abuse its discretion in denying plaintiff's motion to set aside the order awarding costs. View "Hohn v. BNSF Railway Co." on Justia Law

Plaintiff sued her former employer, SatCom, alleging violations of the Minnesota Whistleblower Act (MWA), Minn. Stat. 181.932; Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-.43; common law of wrongful termination, and Fair Labor Standards Act, 29 U.S.C. 201 et seq. Although plaintiff succeeded in establishing a prima facie case of retaliation where three of her reports constituted a protected activity, the court affirmed the district court's grant of summary judgment in favor of SatCom because SatCom had a legitimate, non-retaliatory reason for terminating plaintiff. Because the district court's McDonnell-Douglas analysis was sufficiently thorough to encompass plaintiff's claims under the Reporting Clause and Opposition Clause of the MWA, plaintiff was not entitled to reversal on this basis. Accordingly, the court affirmed the district court's grant of summary judgment in favor of SatCom. View "Wood v. SatCom Marketing, LLC, et al" on Justia Law

Plaintiff asserted wrongful termination claims against the WCRA, alleging disability discrimination and retaliation in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213; the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-.43; and the Minnesota Whistleblower Act, Minn. Stat. 181.932. On appeal, plaintiff challenged the district court's grant of summary judgment dismissing these claims. The court held that there was no evidence giving rise to an inference that the WCRA terminated her because of her medical condition; plaintiff had no claim of ADA retaliation because she did not engage in protected activity by complaining about disability discrimination; the court doubted that the supervisor's alleged harassment of plaintiff and intimidating management style created a hostile work environment; plaintiff's claim that the WCRA failed to provide reasonable accommodations for her disability failed because she never requested or otherwise adequately informed the WCRA of the need for additional accommodations; plaintiff's Whistleblower Act claim was without merit because there was no evidence plaintiff was terminated because she engaged in statutorily protected conduct; and plaintiff's contention that the district court abused its discretion by excluding certain affidavits was without merit because any error was harmless. Accordingly, the court affirmed the judgment. View "Lenzen v. Workers Compensation Reinsurance Assoc." on Justia Law