Justia Labor & Employment Law Opinion Summaries

Plaintiff filed suit against her former supervisor and employer, the Department, for statutory and constitutional violations. The court concluded that it had jurisdiction over the supervisor's appeal where the supervisor challenged the sufficiency of plaintiff's pleadings to state 42 U.S.C. 1983, Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq., interference and retaliation claims. The court also concluded that plaintiff failed to state a section 1983 claim for gender discrimination where her conclusory assertion that she was discharged under circumstances similarly situated men were not imported legal language couched as factual allegations and failed to raise a right to relief above the speculative level. Accordingly, the district court erred in denying the supervisor's motion to dismiss the claim. Further, the district court erred in denying the supervisor's motion to dismiss the FMLA entitlement claim and the FMLA discrimination claim. The court remanded for the district court to consider whether to allow plaintiff to amend her pleadings. Finally, the court, declining to exercise pendant jurisdiction, did not have jurisdiction to hear the Department's appeal. View "Hager v. Arkansas Dept. of Health, et al." on Justia Law

The Market sought a declaration that its employment separation agreement with defendant was invalid because defendant had altered the agreement and fraudulently induced the president of the Market to sign it. Defendant counterclaimed to enforce the agreement. The court affirmed the district court's grant of summary judgment to the Market where defendant failed to fulfill a condition precedent - returning company property - and such failure meant that the Market had not duty to perform under the agreement. Alternatively, the district court did not abuse its discretion in striking defendant's pleadings based on defendant's deliberate and willful discovery abuses. The district court acted within its discretion to impose sanctions under Rule 37. View "St. Louis Produce Market v. Hughes" on Justia Law

Plaintiffs filed suit against their former employer and others under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq. After the district court adopted the magistrate judge's recommended dispositions, plaintiffs appealed. The court concluded that plaintiffs have failed to set forth sufficient evidence to show that they were due more in benefits and penalties than the amount that the district court determined that they were owed; the district court did not abuse its discretion in denying their requests for nonmonetary relief or in determining the reasonable attorney's fees and costs; and, therefore, the court affirmed the judgment of the district court. View "McDowell, et al. v. Price, et al." on Justia Law

This case concerned the 2011 NFL lockout. Active NFL players filed a class action suit (Brady suit) against the NFL, alleging violations of the federal antitrust laws and other claims. Retired NFL players also filed suit against the NFL and its teams, alleging antitrust violations (Eller I suit). After both actions were consolidated, the Brady suit was settled, the players re-designated the NFLPA as their collective bargaining agent, the NFL and NFLPA signed a new collective bargaining agreement (CBA) incorporating the settlement terms, the Brady plaintiffs dismissed their action, the lockout ended, and the 2011 NFL season commenced. Carl Eller and other retired NFL players (plaintiffs) then filed this class action (Eller II) against the NFLPA and others. The district court granted defendants' motion to dismiss and plaintiffs appealed, alleging claims for intentional interference with prospective economic advantage under Minnesota law. The court concluded that no reasonable jury could find that plaintiffs had a reasonable expectation of a prospective separate contractual relation with the NFL that would provide more than the increased benefits provided in the 2011 CBA. Even if plaintiffs alleged a reasonable expectation of prospective contractual relations or economic advantage with the NFL, plaintiffs failed to allege facts proving that defendants improperly or wrongfully interfered with these advantageous prospects. Accordingly, the court affirmed the judgment of the district court. View "Eller, et al. v. NFL Players Assoc., et al." on Justia Law

Plaintiff, a surgical technologist, filed suit against the hospital alleging racial discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1981. The court concluded that the district court did not clearly err in concluding that plaintiff failed to prove the hospital terminated her in retaliation for complaining of racial discrimination; in finding that plaintiff failed to prove that race was the motivating factor behind her termination, rather the district court believed that plaintiff was terminated for being insubordinate; and in finding that plaintiff was not subject to disparate terms and conditions of her employment based on race. Accordingly, the court affirmed the judgment of the district court. View "Wright v. St. Vincent Health System" on Justia Law

The Unions filed a grievance against Alcan, claiming that Alcan violated a collective bargaining agreement. On appeal, the Unions challenged the district court's order vacating the arbitrator's award of severance pay. The court reversed the judgment because a federal court must defer to the arbitrator's interpretation where the arbitrator was at least arguably construing or applying the collective bargaining agreement. The court denied the Unions' request for attorneys' fees. Alcan acted promptly to seek an order vacating the arbitration award and the company did not act dishonestly or in bad faith. View "Alcan Packaging Co. v. Graphic Communications, et al." on Justia Law

Plaintiff filed suit against Trinity alleging wrongful termination in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; Title VII of the Civil Rights Act, 42 U.S.C. 2000e-1 et seq.; the North Dakota whistleblower statute, N.D. Cent. Code 34-01-20(1); and N.D. Cent. Code 34-01-04 (the intimidation statute). On appeal, plaintiff challenged the district court's grant of summary judgment in favor of Trinity and the denial of her motion for a default judgment. The court found no abuse of discretion in the district court's denial of plaintiff's motion for summary judgment or default judgment, which asked the court to grant a dispositive discovery sanction against Trinity for its willful pattern of action in failing to comply with the scheduling order. Plaintiff failed to advance any evidence indicating that Trinity did in fact replace plaintiff with someone substantially younger, that she was treated differently than any other similarly situated male employee, that plaintiff engaged in a protected activity under the whistleblower statute, and that there was a private right of action under the intimidation statute. Accordingly, the court affirmed the judgment of the district court. View "Holmes v. Trinity Health" on Justia Law

ABF filed suit against defendants alleging a violation of a collective bargaining agreement (CBA). On appeal, ABF challenged the district court's grant of defendants' motion to dismiss under Rule 12(b)(6). ABF contended that because the agreement's grievance-resolution system was unavailable, the district court may appoint a disinterested tribunal to hear the grievance or, alternatively to provide redress. The court concluded that the district court could not appoint a new tribunal because the National Grievance Committee (NGC) rules provided a solution. Though the rules here did not mandate the NGC's specific response to a disqualification, they nonetheless made clear that resolving it by amending or modifying the rules was an issue for the NGC. In regards to ABF's request for redress directly from the court for breach of the National Master Freight Agreement (NMFA), the court rejected ABF's unavailability and futility arguments, as well as its remaining claims. Accordingly, the court affirmed the judgment of the district court. View "ABF Freight System, Inc. v. Int'l Brotherhood of Teamsters, et al." on Justia Law

Plaintiffs, two laborers, filed suit against their employer, ConAgra Foods, alleging that ConAgra violated the Fair Labor Standards Act (FLSA), 29 U.S.C. 216(b), by failing to compensate them and others similarly situated for time spent walking between changing stations where they donned and doffed their uniforms and the time clock where they punch in and out for the day. The court concluded that the time spent by the laborers donning and doffing their uniforms was excluded by agreement from the hours for which they were employed; donning and doffing was not an activity that the laborers were employed to perform, and it was therefore not a principal activity that begins and ends the workday; and it follows that the time spent walking between the clothes-changing stations and the time clock was not part of the workday and workweek for which the employer was liable to pay overtime compensation under the FLSA. Accordingly, the court reversed the district court's denial of ConAgra's motion for summary judgment and remanded for further proceedings. View "Adair, et al. v. ConAgra Foods, et al." on Justia Law

Plaintiff filed suit alleging sex and race discrimination, retaliation, and sex and race harassment in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and retaliation in violation of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The court concluded that the district court properly granted summary judgment for the state on plaintiff's race and sex discrimination and retaliation claims where plaintiff did not establish a prima facie case because she could not show, as a matter of law, that she suffered an adverse employment action. The court also concluded that summary judgment was appropriately granted on the harassment claim where the conduct described did not affect a term, condition, or privilege of employment because this conduct was not severe or pervasive enough to constitute actionable discrimination. Accordingly, the court affirmed the district court's judgment. View "Jackman v. Fifth Judicial District, et al." on Justia Law