Justia Labor & Employment Law Opinion Summaries

Kathleen Marez sued her former employer, Saint-Gobain Containers, Inc. for unlawful termination. Marez claimed that Saint-Gobain retaliated against her in violation of the family Medical Leave Act (FMLA) and that Saint-Gobain committed gender discrimination in violation of the Missouri Human Rights Act (MHRA). A jury returned a verdict in Marez's favor on the FMLA claim and in Saint-Gobain's favor on the gender discrimination claim. The district court awarded Marez liquidated damages and part of her requested attorneys' fees. The Eighth Circuit Court of Appeals affirmed, holding (1) there was sufficient evidence to support the jury's verdict in Marez's favor; (2) the district court did not abuse its discretion in awarding liquidated damages, as Saint-Gobain was liable for employment discrimination under the cat's-paw theory of liability, and liquidated damages may be awarded in eligible FMLA cases premised on cat's-paw liability; and (3) the district court did not abuse its discretion in its award of attorneys' fees. View "Marez v. Saint-Gobain Containers, Inc." on Justia Law

Shirley Frisby died from an apparent heart attack while working on an assembly line at Milbank Manufacturing Company in Arkansas. A claim for workers' compensation death benefits was filed just before the two-year statute of limitations expired. The Arkansas Workers' Compensation Commission denied the claim. Curtis Frisby, as administrator of his wife's estate, then commenced this wrongful death diversity action against Milbank. The district court dismissed the action as time barred. Curtis appealed, arguing that the filing of a workers' compensation claim tolls the statute of limitations for a tort claim against the employer for the same injury, and alternatively, that the Arkansas "savings statute" applies and provided him one year after the workers' compensation claim denial to file this action for the same injury. The Eighth Circuit Court of Appeals affirmed, holding (1) because Curtis was able to file a timely wrongful death tort action before or concurrent with the claim for workers' compensation benefits, the district court correctly rejected his tolling argument; and (2) the savings statute did not apply because the dismissal of the workers' compensation claim did not have the same effect as a nonsuit. View "Frisby v. Milbank Mfg. Co." on Justia Law

Appellant appealed the district court's grant of summary judgment in favor of her employer, G4S Youth Services, LLC, and her supervisor, Todd Speight (Appellees), on Appellant's claims that they terminated her employment based on her race, age, and use of family medical leave. The Eighth Circuit Court of Appeals affirmed, holding (1) because Appellant did not create a genuine issue of material fact as to whether G4S's legitimate, non-discriminatory reason for terminating her employment was merely a pretext for intentional race of age discrimination, the district court did not err in granting summary judgment in favor of Appellees on Appellant's race and age discrimination claims; and (2) because Appellant failed to raise a genuine issue of fact as to whether G4S retaliated against her for exercising her FMLA rights, the district court did not err in granting summary judgment on Appellant's Family and Medical Leave Act claims. View "Bone v. G4S Youth Servs., LLC" on Justia Law

Appellant brought this action under 42 U.S.C. 1983 against the Kansas City Board of Police Commissioners and its members, the chief of police, and certain police officers, alleging constitutional violations under the Fourth and Fourteenth Amendments of the Constitution. The district court dismissed the action for failure to exhaust administrative remedies, reasoning Title VII of the Civil Rights Act of 1964 provided the exclusive remedy for Appellant's claims and Appellant could not circumvent the Act's procedural requirements by solely pleading constitutional violations under section 1983. The Eighth Circuit Court of Appeals reversed, holding that to the extent that Appellant's complaint asserted the violation of rights secured by the Constitution and committed by persons acting under color of state law, the district court erred in dismissing her section 1983 action for failure to comply with Title VII's procedural requirements.

Plaintiff was terminated from his employment with the City of Victoria, Minnesota. Plaintiff bought an action against his former employer, alleging violations of the Americans with Disabilities Act (ADA), the Age Discrimination in Employment Act (ADEA), the Due Process Clause of the Fourteenth Amendment, and state law. The district court granted summary judgment in favor of the City. The Eighth District affirmed, holding (1) summary judgment on Plaintiff's ADA claim was proper; (2) Plaintiff's termination did not violate the ADEA, as Plaintiff was not qualified for the position because of his disability; and (3) Plaintiff was not deprived of property without due process of law by being discharged without a formal hearing.

Dr. Lee Davis, an African-American cardiologist, obtained medical-staff privileges at Jefferson Regional Medical Center (JRMC). Later, JRMC's Board of Directors voted to revoke Davis's medical-staff privileges for poor quality of patient care, improper medical documentation, and unprofessional behavior. Davis filed the instant suit in federal district court, alleging, inter alia, race discrimination and retaliation, in violation of 42 U.S.C. 1981 and the Arkansas Civil Rights Act (ACRA), and conspiracy to interfere with his civil rights, in violation of 42 U.S.C. 1985(3). The district court granted summary judgment to Defendants, JRMC, its CEO, and several physicians (Defendants), and dismissed all of Davis's claims. The Eighth Circuit Court of Appeals affirmed, holding (1) because Davis failed to provide any evidence giving rise to an inference that Defendants racially discriminated against him, the district court did not err in granting summary judgment on Davis's race discrimination claims; (2) Davis failed to establish a prima facie case of retaliation under section 1981 and ACRA; and (3) the district court did not err in dismissing Davis's civil rights conspiracy claim pursuant to section 1985(3), as Davis failed to show any racial animus on the part of Defendants.

Appellees entered into performance and stock agreements with their employer, appellant ONEOK, Inc. The agreements required Appellees to continue their employment for three years (performance period) in order to receive the full number of shares, but allowed pro rata payments if Appellees' employment terminated under certain conditions. After Appellees left ONEOK's employment before the earliest performance period ended, ONEOK denied Appellees' claims for pro rata payments under the agreements. Appellees sued ONEOK for breach of contract. The district court found for Appellees and awarded Appellees money damages equal to each of their pro rata shares under the agreements, and denied their request for attorney fees. The Eighth Circuit Court of Appeals reversed the denial of attorney fees, holding that the district court erred in determining Appellees were not entitled to attorney fees under the Nebraska Wage Payment and Collection Act (NWPCA). Remanded for a determination of the amount of the attorney fees award under the NWPCA.

United States Steel Corporation (U.S. Steel) operated an iron ore plant in Minnesota. After the economic downturn, U.S. Steel idled operations at the plant and laid off 313 workers represented by the United Workers of America Local 2660 (the Union). The Union filed a complaint for damages, alleging that U.S. Steel had violated the Worker Adjustment and Retraining Notification Act (the WARN Act) by failing to provide the required notice under the Act prior to the layoff. The district court granted summary judgment to U.S. Steel. The Eighth District Court of Appeals affirmed, holding (1) in light of the circumstances, U.S. Steel satisfied its burden of proving that the conditions giving rise to the WARN Act's unforeseeable business circumstances exception had been met; and (2) the notice given to the Union was sufficient under the WARN Act and was given as soon as practicable in this case.

Plaintiff sued her former employer after the company made public statements about her involvement in an incident in which a pernicious racial slur appeared on a return receipt that she handed to a customer. Plaintiff subsequently appealed the district court's dismissal of her claim for false light invasion of privacy and grant of summary judgment in favor of the employer on her defamation claim. The court concluded that plaintiff was a private figure and a reasonable jury could conclude that the employer's statements were false, that they harmed her reputation, and that this harm was distinguishable from any harm flowing from the generic news stories. Therefore, the district court erred by granting summary judgment to the employer on plaintiff's defamation claim. The court agreed, however, with the district court that Missouri would not recognize plaintiff's false light claim.

Plaintiff, an advanced practical nurse at the University, sued the Board of Curators, alleging a violation of the Equal Pay Act, 29 U.S.C. 206(d), claiming that she was paid less than a male who performed substantially equal work under similar work conditions. The district court, over plaintiff's objection, gave the business-judgment instruction and the jury returned a verdict for the Curators. Plaintiff appealed. The court concluded that the business-judgment instruction limited the jury from ruling for plaintiff solely for irrelevant reasons that were not in the proceeding three instructions. Taken as a whole, the instructions correctly stated the law, requiring a verdict for the plaintiff under some circumstances or for the defendant under others. Accordingly, there was no error and the court affirmed the judgment.