Justia Labor & Employment Law Opinion Summaries

Plaintiff appealed the district court's decision affirming the Commissioner's denial of social security benefits. The court rejected plaintiff's contention to the extent that she alleged the ALJ failed to develop the record or make explicit findings regarding the mental and physical demands of her past relevant work as a factory packer and assembler. The court concluded that the ALJ had sufficient evidence on the record as a whole to reach his determination where the ALJ adequately compared the demands of plaintiff's past with her residual functioning capacity to perform light work, including with her manipulative limitations. Accordingly, the court affirmed the denial of benefits. View "Young v. Astrue" on Justia Law

After plaintiff's employment was terminated by Minco as part of a reduction in force, he brought this action under the Uniformed Employment and Reemployment Rights Act (USERRA), 38 U.S.C. 4301 et seq. The court concluded that the jury's finding that plaintiff's position of employment would have been terminated had he not left for military service was entirely consistent with USERRA's text and its implementing regulations. Plaintiff did not properly preserve his remaining contention. Accordingly, the court affirmed the judgment. View "Milhauser v. Minco Products, Inc." on Justia Law

Plaintiff appealed the district court's adverse grant of summary judgment to defendants on plaintiff's claim that defendants retaliated against her in violation of the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq. The court held that the district court did not err in deciding that plaintiff failed to establish a prima facie case of retaliation under the FLSA. No reasonable jury could conclude that plaintiff's discussion with one of the defendants about the ten-minute deduction on her time card was a sufficiently clear and detailed FLSA complaint for defendants reasonably to understand that plaintiff was alleging a FLSA violation. View "Montgomery v. Havner, et al" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of her former employer on her interference claim brought under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The court held that the district court erred in concluding as a matter of law that plaintiff could not establish an interference claim. A reasonable jury could conclude that she satisfied the FMLA's notice requirement by providing notice of her need for medical leave or, in the alternative, that plaintiff had been terminated for taking such leave when a serious health condition unexpectedly prevented her from fulfilling her work assignment. View "Clinkscale v. St. Theresa of New Hope" on Justia Law

Plaintiffs were unionized delivery drivers covered by a collective bargaining agreement (CBA), which established a pension plan operated by a third-party pension management firm. After a dispute arose in 2006 after the drivers' employers and union re-negotiated the CBA, the drivers sued their employer, the union, and the pension management firm for various breaches of duty. Because the drivers failed to establish that equitable tolling applied, the court held that their complaint was untimely and the district court's summary judgment dismissal was proper. The court also held that the employer failed to identify a compelling reason why it could not have brought its claims against the union in an NLRB proceeding. Accordingly, the court affirmed the district court's judgment that the drivers' claims were barred by the statute of limitations under 29 U.S.C. 160(b) and that the other claims were dismissed, including the employer's crossclaims against the union. View "Gerhardson, et al v. Gopher News Co., et al" on Justia Law

Plaintiff, a female physician of Iranian origin, brought claims under Title VII, 42 U.S.C. 2000e et seq., and the Iowa Civil Rights Act, Iowa Code ch. 216, alleging discrimination based on her sex, pregnancy, and national origin. The court affirmed the district court's grant of summary judgment to defendant, concluding that plaintiff could not assert a claim under either statute because she was an independent contractor. View "Glascock v. Linn County Emergency Medicine" on Justia Law

Plaintiff filed suit against her employer, alleging discrimination and retaliation claims under 42 U.S.C. 1983; the Arkansas Equal Pay Act, Ark. Code. Ann. 11-4-601; and the Arkansas Civil Rights Act (ACRA), Ark. Code. Ann. 16-123-101 et seq. On appeal, plaintiff challenged the district court's grant of summary judgment dismissing all claims. The court affirmed the judgment, concluding that no reasonable factfinder could find that any defendant was guilty of intentional, gender-based wage discrimination when plaintiff's initial salary as a new zoning official was established in November 2006; plaintiff's failure-to-hire claim failed based on undisputed evidence supporting defendants' nondiscriminatory reason for hiring another candidate based on more experience and better qualifications and because plaintiff failed to demonstrate pretext; and plaintiff's remaining claims also failed. View "Hill v. City of Pine Bluff, et al" on Justia Law

Plaintiffs, current and former employees of Redland, commenced this action alleging that Redland violated the overtime provision of the Fair Labor Standards Act (FLSA), 29 U.S.C. 207(a)(1), by changing the designation of their workweek, but not their work schedule, so that fewer hours qualified as "overtime." Agreeing with a Department of Labor investigator, the district court found no FLSA violation and granted Redland's motion for summary judgment. The court rejected plaintiffs' contention that an employer's permanent change in the designated workweek violated section 207(a)(1) unless it was justified by a legitimate business purpose. So long as the change was intended to be permanent, and it was implemented in accordance with the FLSA, the employer's reasons for adopting the change are irrelevant. Accordingly, the court affirmed the judgment. View "Abshire, et al v. Redland Energy Services" on Justia Law

This dispute arose out of an employment contract between defendant and plaintiffs, his employer. After receiving a favorable judgment in a prior proceeding, defendant moved to dismiss plaintiffs' complaint in the present action on the basis of res judicata. Defendant also filed a motion requesting sanctions and attorney's fees. The district court granted the motion to dismiss but declined to impose sanctions or award attorney's fees. Both parties appealed. The court concluded that the district court properly decided the merits of defendant's res judicata defense on a motion to dismiss. On the merits, Count VI was barred by res judicata where the cause of action existed at the time of the first judgment and it occurred from the same transaction or occurrence. Finally, the court affirmed the district court's decision to deny sanctions and attorney's fees. View "C.H. Robinson Worldwide, Inc., et al v. Lobrano, Jr." on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and state law, alleging that defendant had retaliated against him after he raised complaints protected by those statutes. The district court granted summary judgment to defendant on the federal law claims and dismissed the state law claims without prejudice. The court concluded that plaintiff failed to make a prima facie case of retaliation under ERISA. Likewise, plaintiff failed to make a prima facie case of retaliation under the FLSA. At any rate, plaintiff failed to show a causal connection between his complaint about holiday meal time and his termination six months later. Accordingly, the court affirmed the judgment. View "Shrable v. Eaton Corp." on Justia Law