Justia Labor & Employment Law Opinion Summaries

Southeast Technical Institute (STI) in South Dakota is a public post-secondary technical school funded by the State through Sioux Falls School District No. 49-5 and governed by the Sioux Falls School Board. STI terminated Registrar Matt Onnen for awarding degrees to students who had not earned them, not awarding degrees when students had earned them, and failing to verify students for graduation. Meanwhile, Onnen filed a qui tam complaint against the school district, its superintendent, and the school board members, alleging that Defendants violated the False Claims Act (FCA) by knowingly submitting false or fraudulent claims to the federal government for student grants and guaranteed loans. Onnen did not sue STI or any STI employee. The district court granted summary judgment for Defendants. The Eighth Circuit Court of Appeals affirmed, holding the district court did not err in concluding Onnen's affidavit was insufficient to prove that any defendant committed a knowing violation of the FCA. Therefore, summary judgment was appropriate. View "United States ex rel. Onnen v. Sioux Falls Indep. Sch. Dist." on Justia Law

The United Automobile, Aerospace, and Agricultural Implement Workers International Union and Local 997 appealed the district court judgment after a five-day bench trial declaring that Whirlpool Corporation may unilaterally modify the health care benefits it provided to retired hourly workers previously employed at the Newton, Iowa manufacturing facilities of Whirlpool's now-dissolved subsidiary, Maytag Corporation. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly found that a case or controversy existed when Whirlpool filed its declaratory judgment action; and (2) the retirees did not have a vested right to the previously granted health benefits under ERISA, as the benefits were provided in a collectively bargained agreement that had no express vesting provision. View "Maytag Corp. v. Int'l Union" on Justia Law

The Laborers District Council of Minnesota and North Dakota (the Union) petitioned for review of a decision of the National Labor Relations Board ordering the Union to cease and desist violating section 8(b)(4)(ii)(B) of the National Labor Relations Act by coercing Lake Area Fence, a newly formed commercial fencing subcontractor, not to do fence installation work for Century Fence Company, a nonunion contractor. The Eighth Circuit Court of Appeals denied the petition for review and granted the Board's cross-petition to enforce its decision and order, holding that the Board's decision was a reasonable construction of the statute and was supported by substantial evidence on the administrative record as a whole. View "Laborers Dist. Council v. NLRB" on Justia Law

Plaintiff sued the County of Dakota, Nebraska, and former sheriff's deputy Rodney Herron, alleging Title VII violations, sexual harassment, and violation of the Equal Pay Act. The County advanced a limited offer to settle the Title VII and Equal Pay Act claims, which Plaintiff accepted. Plaintiff then sought an award of attorney's fees on the partial judgment, and the district court ultimately awarded $24,500 in attorney's fees to Williams in two separate orders. The district court certified its orders as final judgments under Fed. R. Civ. P. 54(b) so as to allow for an interlocutory appeal. Defendants appealed. The Eighth Circuit Court of Appeals dismissed the appeal for lack of jurisdiction, holding that the district court abused its discretion by entering final judgment under Rule 54(b). View "Williams v. County of Dakota" on Justia Law

Rinchem Company, Inc. fired Jeffrey Sherman after Sherman alleged lied in the course of Rinchem's investigation of complaints about his behavior. Sherman disputed Richem's allegation and contended that Rinchem's accusation defamed him and compelled him to reveal to prospective employers that he had been fired for lying. The district court granted summary judgment to Rinchem on Sherman's defamation claim. Sherman appealed, arguing that the district court (1) should have granted his motion for summary judgment as a sanction for spoliation of evidence, or, in the alternative, an adverse-inference instruction; and (2) erred in granting summary judgment on his defamation claim. The Eighth Circuit Court of Appeals affirmed, holding (1) federal law applies to the imposition of sanctions for the spoliation of evidence, and the district court did not abuse its discretion by denying a sanction for the spoliation of evidence, as Sherman conceded that Richem did not act in bad faith; and (2) the district court did not err in granting summary judgment on Sherman's spoliation of evidence claim, as Rinchem was entitled to qualified privilege that defeated the claim. View "Sherman v. Rinchem Co., Inc." on Justia Law

Plaintiff brought suit under 42 U.S.C. 1983 against the County of Dakota, Nebraska, and former county official Rodney Herron. Plaintiff alleged defendants committed gender discrimination in violation of her Fourteenth Amendment rights. Herron appealed the district court's denial of summary judgment, asserting that he was entitled to qualified immunity. The Eighth Circuit Court of Appeals affirmed, holding (1) Plaintiff met her burden to show that Herron violated her Fourteenth Amendment right to be free from gender discrimination; (2) the right Herron violated was clearly established; and (3) because Plaintiff satisfied both prongs of the qualified-immunity analysis, the district court correctly found that Herron was not entitled to qualified immunity. View "Williams v. Herron" on Justia Law

Toni Duncan sued her former employer, Dakota County, Nebraska, under 42 U.S.C. 1983 for hostile-work-environment sexual harassment and constructive discharge in violation of the Equal Protection Clause of the Fourteenth Amendment. Duncan also sued Sheriff James Wagner and her supervisor, Chief Deputy Rodney Herron, in their individual capacities. The district court (1) granted summary judgment to Wagner; and (2) denied the motions for summary judgment by the County and Herron on the basis of qualified immunity. The Eighth Circuit Court of Appeals reversed in part, holding that Herron was entitled to qualified immunity on Duncan's claim, as Herron did not violate Duncan's right to equal protection. Remanded. View "Duncan v. Herron" on Justia Law

Plaintiff sued her former employer, Dakota County, Nebraska under 42 U.S.C. 1983 and 1985. She also sued a sheriff, chief deputy, and sergeant, claiming the chief deputy and sheriff created or fostered a sexually hostile work environment, and the chief deputy and sergeant conspired to deprive her of her civil rights. The defendants moved for summary judgment based on qualified immunity, which the district court denied. The Eighth Circuit Court of Appeals (1) affirmed the denial of summary judgment to the chief deputy, holding that Plaintiff sufficiently showed the five elements of a hostile-work-environment sexual harassment claim and that the right the chief deputy violated was clearly established; (2) reversed the denial of summary judgment as to the sheriff and sergeant on Plaintiff's claim that they conspired to violate her constitutional rights, as Plaintiff failed to demonstrate the existence of a conspiracy; and (3) reversed the denial of summary judgment as to the sheriff on Plaintiff's sexually hostile work environment claim, as the sheriff's conduct was not sufficiently severe to create a sexually hostile work environment. View "Crutcher-Sanchez v. Wagner" on Justia Law

Mischelle Richter appealed (1) the district court's order dismissing her retaliation claims under Title VII and the Missouri Human Rights Act for failure to exhaust administrative remedies, and (2) the dismissal of her wrongful discharge claim under Missouri law for failure to state a claim upon which relief may be granted. The Eighth Circuit Court of Appeals (1) affirmed the district court's dismissal of the retaliation claims, holding that Richter did not properly exhaust her retaliation claims; but (2) reversed and remanded on the state-law wrongful discharge claim, holding that Richter alleged sufficient facts to state a wrongful discharge claim under Missouri law. View "Richter v. Advance Auto Parts, Inc." on Justia Law

In this diversity action involving Minnesota's Whistleblower Act, Appellant Ann Hilt alleged that her employer, St. Jude Medical S.C., Inc., decided to terminate her based, in part, on her reports concerning St. Jude's illegal conduct and her participation in a government investigation. The district court granted summary judgment in favor of St. Jude. The Eighth Circuit Court of Appeals affirmed the judgment of the district court, holding that Hilt failed to present sufficient evidence to demonstrate that St. Jude's proffered reasons for including her in the St. Jude's ten percent reduction in force was a pretext for a retaliatory motive. View "Hilt v. St. Jude Med. S.C., Inc." on Justia Law