Justia Labor & Employment Law Opinion Summaries

Plaintiff sued her former employer alleging violations of her rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The employer believed that plaintiff suffered from a serious health condition and placed her on involuntary FMLA leave. After plaintiff submitted certifications of her fitness to return to work, the employer informed her that she had exhausted her FMLA leave and terminated her employment. The court affirmed the district court's grant of the employer's motion to dismiss where the statute entitled plaintiff to a certain amount of leave and her employer did not interfere with that entitlement. Further, the court concluded that plaintiff had no right to FMLA benefits where she admitted that she never suffered a serious health condition within the meaning of the Act. The court rejected defendant's claim of equitable estoppel where she did not establish a submissible case of detrimental reliance; and the employer's mistaken belief that plaintiff suffered a serious health condition could not entitle her to FMLA benefits. View "Walker v. Trinity Marine Products, et al." on Justia Law

Plaintiffs filed suit against their former employer alleging retaliatory termination after plaintiffs filed grievances against their supervisor. A jury found that the employer did retaliate against plaintiffs and awarded backpay and damages for emotional distress to each plaintiff. Both parties appealed. The court concluded that the evidence of discriminatory animus was sufficient to submit plaintiffs' retaliation claims to the jury; the employer's proffered non-discriminatory explanation for the terminations failed to address the discriminatory motivation; and the employer's argument that the discriminatory motivation was cured was unavailing. Accordingly, the district court properly denied the employer's motion for judgment as a matter of law on the retaliation claims. The court agreed with the district court's decision to instruct the jury that it could award damages for emotional distress; the district court did not clearly abuse its discretion in denying the employer's motion for new trial or remittitur; and the court affirmed the district court's decision to refuse an instruction on punitive damages. Accordingly, the court affirmed the judgment. View "Bennett, et al. v. Riceland Foods, Inc." on Justia Law

Plaintiff, injured on an oil and gas rig, filed suit against various third parties - including TESCO and TESCO employee Jeffrey Anderson - after recovering workers' compensation benefits from his employer, DeSoto. SWE was the owner/operator of the oil and gas well. The court concluded that the SWE contract did not establish that the common law duty of care Anderson owed plaintiff extended to preventing unforeseen injuries caused by DeSoto's failure to follow SWE's safety rules; Anderson and TESCO had no duty to foresee that injury to a DeSoto employee would occur because other DeSoto employees not under defendants' control had failed to exercise their duty of care; ordinary care did not require Anderson to foresee that his encouraging word would cause a DeSoto driller to do something he had not already decided, indeed, been ordered to do; and the amount of encouragement Anderson gave the DeSoto driller was insubstantial. Finally, the district court did not abuse its discretion in striking an expert report submitted by plaintiff and in denying the motion to amend. Accordingly, the court affirmed the judgment. View "Williams v. Chartis Casualty Co. et al." on Justia Law

The Union filed a grievance on behalf of a nurse terminated by the Hospital, alleging that the Hospital lacked "just cause" to terminate. The court concluded that the arbitrator did not exceed his authority by awarding reinstatement and back-pay; the manner in which the collective bargaining agreement (CBA) expired had no effect on the arbitrator's authority; the circumstances of the Union's decertification and the CBA's expiration were known to, and expressly considered by the arbitrator in making his award; and there was no basis to conclude that the arbitrator's exercise of his remedial authority failed to "draw its essence" from the CBA. Accordingly, the court affirmed the district court's grant of summary judgment confirming the arbitration award. View "Midwest Division - LSH, LLC v. Nurses United For Improved Patient Care" on Justia Law

Plaintiff sued the City under 42 U.S.C. 1983 after she was sexually assaulted by a City policy officer. The officer was charged with first degree sexual assault and subsequently terminated from the police force. On appeal, plaintiff challenged the district court's grant of summary judgment to the City. The court concluded that a jury could reasonably infer, based on the evidence, that the City's custom of ignoring violent misconduct and failing to supervise or discipline officers was a moving force behind the officer's assault on plaintiff. Accordingly, the court vacated the district court's grant of summary judgment and remanded for further proceedings. View "Doe v. City of Marianna, AR" on Justia Law

Plaintiff sued her former employer and others after she was terminated, alleging federal claims of discrimination based on her gender, religion, and disability, as well as defamation under state law. On appeal, plaintiff challenged the district court's adverse grant of summary judgment on the remaining claims that were not dismissed. The court concluded that the district court did not err in granting summary judgment on plaintiff's discrimination claims to Trumann Health where, under the McDonnell Douglas analysis, Trumann Health articulated a legitimate, nondiscriminatory reason for firing her and plaintiff did not show other similarly situated employees were more favorably treated; the district court properly granted summary judgment on plaintiff's libel claims against her co-workers; and Trumann Health could not be liable for defamation because plaintiff premised Trumann Health's liability upon the individual defendants' liability. Accordingly, the court affirmed the judgment. View "Evance v. Trumann Health Services, et al." on Justia Law

Plaintiff sued the University and others under 42 U.S.C. 1983 after her employment was terminated for gross misconduct. On appeal, plaintiff challenged the district court's adverse grant of summary judgment on her due process violation and gender discrimination claims. The court concluded that, assuming plaintiff had a property interest in her continued employment, her due process claim failed because she received all of the process that she was due; regardless of whether defendants deprived plaintiff of a liberty interest in her reputation, she could not establish a due process violation because she did not sufficiently, if at all, request a name-clearing hearing; the district court did not err in finding that plaintiff failed to show direct evidence of discrimination or that defendants' explanation for terminating her was a pretext for gender discrimination. Accordingly, the court affirmed the judgment. View "Floyd-Gimon v. University of Arkansas, et al." on Justia Law

Plaintiff sued his employer under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 623, and the Iowa Civil Rights Act (ICRA), Iowa Code 216.6, alleging that he was discharged from his employment due to his age. The district court granted summary judgment in favor of the employer. The court concluded that, taken together, plaintiff's evidence was sufficient to allow a rational factfinder to find that the employer's proffered reasons for terminating him were pretextual. Plaintiff's evidence was not inconsistent with a reasonable inference of age discrimination and, therefore, the court reversed the grant of summary judgment and remanded for further proceedings. View "Ridout v. JBS USA, LLC" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of U.S. Bank on her claims of discrimination and retaliation under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-1 et seq. The court concluded that summary judgment in favor of U.S. Bank on plaintiff's discrimination claim was proper where the bank had a legitimate, non-discriminatory basis for issuing a written warning and where plaintiff had not met her burden of demonstrating pretext. The court also concluded that summary judgment in favor of U.S. Bank was proper where plaintiff failed to show a causal connection between her protected activity and the bank's alleged adverse employment action. Accordingly, the court affirmed the judgment. View "Muor v. U.S. Bank Nat'l Assoc." on Justia Law

Plaintiff alleged that NCS conducted a spam e-mail campaign that harmed his business, in violation of Iowa and federal law. After a bench trial, the district court entered judgment in favor of NCS and dismissed plaintiff's claims. The district court heard from plaintiff and NCS's principals in a bench trial and it found NCS's principals more credible than plaintiff. The court concluded that the evidence cited by plaintiff did not establish a clear error in the district court's determination. The court also concluded that the district court did not err by concluding that a salesman was an independent contractor rather than an employee of NCS. The court rejected plaintiff's contention that an employment relationship made NCS responsible for any e-mail activity by the salesman. The primary consideration was the hiring party's control over the means of performance and the court agreed with the district court that the weight of the evidence taken as a whole established an independent contractor agreement. Accordingly, the court affirmed the judgment. View "Kramer, III v. National Credit System" on Justia Law