Justia Labor & Employment Law Opinion Summaries

Plaintiff brought this action against his former employer alleging wage discrimination and termination on the basis of race and national origin in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., the Minnesota Human Rights Act (MHRA), Minn. Stat. 363.01 et seq., and 42 U.S.C. 1981, as well as breach of his employment contract. The court affirmed the district court's holding that plaintiff failed to establish that the employer's proffered legitimate, nondiscriminatory reason for his termination was pretextual. Plaintiff also had not shown pretext through evidence that similarly situated non Hispanic or non Cuban born employees received more favorable treatment. Accordingly, the district court did not err in granting summary judgment on the Title VII and MHRA claims that plaintiff's termination was a result of unlawful discrimination. The district court also properly granted summary judgment on plaintiff's discriminatory wage claims. Finally, in the absence of evidence of an employment contract or any exception to at will employment, plaintiff's breach of contract claim failed and consequently, plaintiff's section 1981 claim also failed.

Plaintiffs, four women employed by NSP, brought this action alleging discriminatory pay practices under the Equal Pay Act (EPA), 29 U.S.C. 206 et seq., the Minnesota Human Rights Act (MHRA), Minn. Stat. 363.01 et seq., and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. The district court granted summary judgment in favor of NSP after concluding that plaintiffs had not established a prima facie case of wage discrimination. Plaintiffs appealed. The court concluded that the district court did not err in holding that the evidence showed that some employers did better than others in given years, but did not establish that NSP was liable for a violation of the EPA. The court also held that the district court did not err in finding that one plaintiff, Helen Goebel, could not make a prima facie case because the St. Cloud Service Center was a different establishment from the Chestnut Service Center and Goebel was the highest paid woman at that facility. Accordingly, the judgment was affirmed.

Plaintiff brought a claim under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, alleging that his employer engaged in prohibited discrimination by rescinding his offer of promotion on the basis of his perceived limitations. The employer moved for summary judgment, contending, in part, that plaintiff's claim was discharged in the company's Chapter 11 bankruptcy, which had concluded two months after rescission of plaintiff's offer. The district court held that plaintiff's ADA claim was discharged by virtue of his failure to submit a request for payment by the bar date for the majority of administrative expense claims. The court found that plaintiff's claim fit squarely within the definition of liabilities incurred in the ordinary course of business. Therefore, the court held that because plaintiff was not required to file a request for payment of an administrative expense at all, the judgment in favor of the employer was reversed and the case remanded for further proceedings.

Appellant was terminated for cause from his employment with Northwest Airlines shortly after he was arrested for possession of marijuana. At the same time, appellant had pending with Northwest a request for disability retirement benefits. Northwest later granted appellant's request, but he was ineligible for certain retirement benefits as a result of the termination. Appellant sued Northwest, claiming that the termination violated section 510 of the Employment Retirement Income Security Act (ERISA), 29 U.S.C. 1140. The district court denied Northwest's motion to dismiss for lack of subject-matter jurisdiction, but granted its motion for summary judgment. The court held that the district court properly exercised jurisdiction over the case where appellant's claim did not require an interpretation of a collectively bargained agreement. The court also held that appellant failed to show a causal connection between his termination and his application for disability retirement benefits. The court rejected appellant's remaining arguments. Accordingly, the court affirmed the judgment of the district court.

Plaintiffs commenced a diversity action against defendant, asserting claims for breach of the insurance contract and for vexatious refusal to pay. Applying Missouri law, the district court granted defendant summary judgment, concluding that the insurance policy at issue unambiguously excluded losses caused by plaintiffs' CEO, a shareholder, and by plaintiffs' COO, a non-shareholder, acting in collusion with the CEO. The court affirmed and held that the Officer-Shareholder exclusion was consistent with Missouri public policy, and in the alternative, the Officer-Shareholder exclusion was unambiguous and excluded plaintiffs' claim.

Plaintiffs, six current and former African-American employees, brought suit against Nucor alleging racial discrimination in violation of 42 U.S.C. 1981 and Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2000e-17. The district court denied plaintiffs' requests for class certification, granted summary judgment in favor of Nucor on several claims and the case proceeded to trial. A jury returned verdicts against Nucor and awarded each plaintiff monetary damages. The parties appealed and cross-appealed, contesting various rulings by the district court. The court held that the district court did not abuse its discretion in believing that evidence of a previous enforcement action alleging race discrimination at the Blytheville plant was relevant to the credibility of plaintiffs' allegations. The court also held that the district court properly admitted certain statements at issue. The court further held that because Nucor failed to renew its motion under Rule 50(b), the court was without power to disturb the district court's entry of judgment on the jury's punitive damages award. The court finally held that the district court did not abuse its discretion by concluding that plaintiffs had not met their burden of demonstrating the commonality of their claims and that summary judgment was warranted on plaintiffs' disparate impact claims, failure-to-train disparate treatment claims, and failure-to-promote disparate treatment claims. Accordingly, the judgment of the district court was affirmed.

Plaintiff sued defendant, asserting racial discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e to 2000e-17, and the Arkansas Civil Rights Act, Ark. Code Ann. 16-123-101 to -108. The district court granted defendant's motion for summary judgment. The court held that defendant offered nondiscriminatory, legitimate grounds for its decisions not to promote plaintiff and to terminate him. The court also held that, considering both plaintiff's individual claims and the cumulative effects of those claims, no reasonable jury could find pretext or discrimination. Therefore, the court affirmed the grant of summary judgment to defendant on plaintiff's claim that he was not promoted because of racial discrimination. The court also held that plaintiff's retaliation claim was properly dismissed.

Plaintiff appealed the dismissal of her action against a former employer alleging race, sex, and age discrimination and retaliation in violation of Title VII. The district court concluded that plaintiff had not filed a charge of discrimination with the EEOC within 300 days of her termination, as required to exhaust her claim, and therefore dismissed the case for failure to state a claim. The court held that because the district court rested its factual conclusions on matters outside the pleadings, it erred by failing to convert the employer's motion into one for summary judgment under Federal Rule of Civil Procedure 56. This error did not prejudice plaintiff with regard to her claims of age discrimination and retaliation, so the court affirmed the district court's dismissal in this respect. The court held that because the error was prejudicial with respect to the remaining claims of race and sex discrimination, however, the court reversed the district court's dismissal and remanded for further proceedings.

Plaintiff sued her employer under the Minnesota Human Rights Act (MHRA), Minn. Stat. 363A.01-43, and the Family Medical Leave Act (FMLA), 29 U.S.C. 2601-54, and asserted other state common law claims including breach of employment contract. Plaintiff subsequently appealed the dismissal of her breach of contract claim with prejudice, the denials of her motions for leave to amend her complaint, the denial of her motion for consideration, and the adverse grant of her MHRA and FMLA claims by the district court. The court did not reach the merits of plaintiff's arguments because any error with respect to the dismissal of the breach of employment contract claim was harmless where plaintiff resigned from her employment with the county and failed to generate a genuine issue of fact as to constructive discharge in the context of her MHRA reprisal claim. The court also held that because plaintiff failed to generate an issue of fact as to whether she suffered a materially adverse employment action, summary judgment was appropriate as to her MHRA retaliation claim. The court further held that summary judgment was properly granted on plaintiff's FMLA interference claim where plaintiff did not contest the district court's finding that she received the full twelve weeks of FMLA leave to which she was entitled each year she requested it. The court finally held that summary judgment was properly granted on plaintiff's FMLA retaliation claim where she failed to generate an issue of fact as to whether she suffered an adverse employment action.

Appellants, current and former shuttle bus drivers at the Minneapolis-St.Paul International Airport, brought suit against appellees in Minnesota state court alleging misclassifications of its drivers as franchisees rather than employees. At issue was whether the district court erred in granting the motion to compel arbitration, erred in enforcing the class action waiver clauses in the drivers' contracts, and erred in dismissing the federal action instead of staying it pending arbitration. The court held that the district court did not err in granting the motion to compel arbitration where appellants agreed to have an arbitrator determine threshold questions of arbitrability and therefore, appellants agreed to have the arbitrator decide whether the Federal Arbitration Act's (FAA), 9 U.S.C. 1, transportation worker exemption applied. The court also held that AT&T Mobility LLC v. Concepcion foreclosed appellants' claim that the district court erred in concluding the class action waivers were enforceable where the Supreme Court recently held that the FAA preempted a state-law-based challenge to the enforceability of class action waivers. The court held that, under the circumstances, the district court abused its discretion in dismissing the action rather than staying it pending completion of the arbitration.