Justia Labor & Employment Law Opinion Summaries

Plaintiff, an employee of Cargill, sued under the Family and Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., asserting FMLA entitlement and retaliation claims. The district court granted Cargill's motion for summary judgment on both claims. The court held that plaintiff had provided insufficient evidence for a reasonable jury to find that she gave Cargill adequate notice under the FMLA; plaintiff's notice requirement was not excused on the basis of extraordinary circumstances; and there were no genuine issues of material fact as to her failure to satisfy her notice obligation under the FMLA and therefore, the district court did not err in dismissing plaintiff's entitlement claim. Further, plaintiff failed to make a prima facie case for FMLA retaliation and the district court did not err in dismissing this claim. View "Bosley v. Cargill Meat Solutions Corp." on Justia Law

A jury found in favor of plaintiff in his employment-discrimination suit under the Missouri Human Rights Act (MHRA), section 213.010 of the Missouri Revised Statutes, against Kaman. Both parties appealed. The court held that plaintiff made a submissible case for punitive damages by providing clear and convincing proof from which a reasonable factfinder could conclude that Kaman acted with evil motive or reckless indifference when it retaliated against him; the $500,000 in punitive damages that the jury awarded plaintiff did not violate due process; the district court did not did not err in refusing to grant a new trial on plaintiff's discrimination and retaliation claims; and the district court did not abuse its discretion in restricting plaintiff's recovery of attorneys' fees. Accordingly, the court affirmed the judgment. View "Trickey v. Kaman Industrial Technologies Corp." on Justia Law

A class of about 1,600 Minnesota delivery drivers employed by Domino's Pizza alleged that, under Minnesota law, a fixed delivery charge that customers paid Domino's was a gratuity wrongfully withheld from them. The court held that the varied context of the pizza delivery transactions made it unreasonable for some customers to construe the delivery charge as a payment for personal services, thereby preventing one-stroke determination of a classwide question. Therefore, the district court abused its discretion by certifying the class. Accordingly, the court reversed the class certification order and remanded for further proceedings. View "Luiken, et al v. Domino's Pizza, LLC" on Justia Law

American Family appealed the district court's order denying its motion for judgment as a matter of law or, in the alternative, for a new trial and awarding defendant attorney's fees pursuant to section 91A.8 of the Iowa Wage Payment Collection Law (IWPCL). The court concluded that the district court did not abuse its discretion in granting defendant's Rule 15(b)(2) motion to amend the pleadings to add the IWPCL claim because the claim was tried with American Family's implied consent and the amendment did not result in prejudice to American Family. The district court did not abuse its discretion in awarding attorney's fees to defendant under the IWPCL. Any error in giving jury Instruction 13A was harmless in light of the subsequently given Instruction No. 14. Accordingly, the court affirmed the judgment of the district court. View "American Family Mutual Ins. Co. v. Hollander" on Justia Law

Plaintiff sued the former Mayor of the City of Russelville and the members of the Russellville City Council in federal district court, alleging age and race discrimination. Defendants subsequently filed an interlocutory appeal, seeking a reversal of the district court's denial of legislative immunity. The court concluded that defendants were entitled to legislative immunity where defendants not only eliminated plaintiff's position, but also instantaneously created a seemingly identical position. In the present case, control over the position at issue moved from the Mayor to the City Council, a quintessential legislative decision. View "Leaphart v. Williamson, et al" on Justia Law

Hostess provided an "employee welfare benefit plan" under the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1002(1). In this appeal, appellant challenged the order of the district court affirming the grant of summary judgment by the bankruptcy court in favor of Hostess on his claim for civil penalties for Hostess's failure to give notice of certain health insurance coverage rights required under the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA), 29 U.S.C. 1166(a), and the denial of attorney's fees. Although it was undisputed that Hostess failed to provide two notices required by COBRA, the court rejected appellant's arguments and held that the bankruptcy court did not err in granting summary judgment to Hostess on his claim for civil penalties. The court agreed with the bankruptcy court that it could not "fairly call the outcome of the litigation some success on the merits" as required to award attorney's fees and costs to appellant. View "Deckard v. Interstate Bakeries Corp., et al" on Justia Law

Hallmark sued its former employee, defendant, for a breach of the parties' separation agreement and won a jury verdict of $860,000 on its breach of contract claim. Defendant appealed, arguing that the district court erred in delivering an adverse inference instruction to the jury and the award on Hallmark's breach of contract claim was excessive. In light of the overwhelming evidence of bad faith and prejudice before the district court, the court concluded that its failure to issue explicit findings before delivering the otherwise warranted adverse inference instruction was harmless error which did not prejudice defendant. By awarding Hallmark more than its $735,000 severance payment, the jury award placed Hallmark in a better position than it would find itself had defendant not breached the agreement. Accordingly, the jury's award of the $125,000 payment was improper and the court vacated and remanded for the district court to reduce the fee award appropriately. View "Hallmark Cards v. Murley" on Justia Law

Plaintiff sued her former employer, the Third Judicial District, and its current and former directors under 42 U.S.C. 1983, claiming that the employer fired her in violation of the First Amendment. The district court denied defendants' motions for summary judgment based on qualified immunity. The court dismissed the appeal for lack of jurisdiction where qualified immunity was not a defense available to a governmental entity and its current director in his official capacity. Further, the remaining defendant was deceased and was not a proper party on appeal. View "Campbell v. State of Iowa, et al" on Justia Law

Bristol Care appealed the denial of its motion to compel arbitration in a suit initiated by its former employee asserting claims under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and seeking class action certification. Given the absence of any contrary congressional command from the FLSA that a right to engage in class actions overrides the mandate of the Federal Arbitration Act, 9 U.S.C. 3-4, in favor of arbitration, the court held that arbitration agreements containing class waivers were enforceable in claims brought under the FLSA. Because the court concluded that the Mandatory Arbitration Agreement (MAA) signed by the employee and Bristol Care was enforceable, the court reversed the district court's decision and directed the district court to enter an order granting Bristol Care's motion to stay proceedings and compel arbitration. View "Owen v. Bristol Care, Inc." on Justia Law

Plaintiff, a former software developer for Lockheed Martin Corporation, brought this action for judicial review after Connecticut General terminated his disability benefits in 2007. The court held that the district court properly applied an abuse of discretion standard; on the record, it was not an abuse of discretion to terminate plaintiff's benefits; and the district court did not err in denying plaintiff an opportunity to depose the expert at issue. Accordingly, the court affirmed the judgment. View "Siegel v. Connecticut General Life Ins., et al" on Justia Law