Justia Labor & Employment Law Opinion Summaries

Plaintiffs, two former employees of MET, initiated this action in Minnesota state court alleging that MET and their supervisor terminated them in violation of the Minnesota Whistleblower Act, Minn. Stat. 181.932, and Minnesota common law. MET and the supervisor removed the case to federal court. As in Barclay Square Properties v. Midwest Federal Savings & Loan Ass'n of Minneapolis, the court remanded the case to the district court for the purpose of making findings of fact concerning the supervisor's citizenship. On remand, the district court should determine whether the parties were completely diverse when plaintiffs filed their complaint and when MET and the supervisor filed the notice of removal. Accordingly, the court remanded to the district court but retained jurisdiction over the appeal. View "Chavez-Lavagnino, et al v. Motivation Education Training, et al" on Justia Law

Plaintiff, employed by the CRMC, filed charges of discrimination against her employer after CRMC's placement of her on administrative leave following work-related epileptic seizures and the hiring of a younger technician. Because plaintiff was not a qualified individual to perform the job duties with or without accommodation, the court did not err in granting summary judgment to CRMC based on the Americans with Disabilities Act, 42 U.S.C. 12101 et seq., and Missouri Human Rights Act, Mo. Rev. Stat. 213.010, claims. Plaintiff's age discrimination claims failed for the same reason her disability discrimination claims failed. Accordingly, the court affirmed the judgment. View "Olsen v. Capital Region Medical Center, et al" on Justia Law

This case involved the interpretation of two contractual provisions under Minnesota law: an indemnification clause in a contract between PDSI and Miller and an insurance contract between Harleysville and PDSI which extended insurance coverage to PDSI's indemnification of third parties for tort liability caused, in whole or in part, by PDSI or by those acting on its behalf. The court agreed with the district court's finding that a PDSI employee's suit fell squarely within the indemnity provision of the 1989 Agreement between PDSI and Miller. The court also agreed with the district court's interpretation of the insurance agreements as requiring Harleysville to cover Miller's settlement of the employee's claims. Further, the court concluded that the undisputed facts established as a matter of law that PDSI or those acting on its behalf at least partly caused the employee's bodily injury within the terms of the Harleysville policy. Accordingly, the court affirmed the judgment. View "Harleysville Ins. Co. v. Physical Distrib. Serv., et al" on Justia Law

The City terminated plaintiff's employment after she refused a state trooper's request to take a drug test. Plaintiff sued the City and others, claiming that she was terminated in retaliation for her decision to exercise her Fourth Amendment rights. Even assuming the termination violated plaintiff's Fourth Amendment rights, it was not clearly established at the time of the incident that such an action was unconstitutional, and therefore defendants were entitled to qualified immunity. The court also agreed with the district court that plaintiff's remaining federal claims failed to allege a constitutional violation. The court further held that the district court properly dismissed the official capacity claims and the claims against the City where plaintiff failed to allege facts indicating that the City delegated final policymaking authority to the officials. Finally, because plaintiff did not explain why her Arkansas Civil Rights Act, Ark. Code Ann. 16-123-105(a), claims warranted separate analysis, the district court did not err in dismissing the ACRA claims alongside the 42 U.S.C. 1983 claims. Accordingly, the court affirmed the judgment. View "Hess v. Abels, et al" on Justia Law

Plaintiff appealed the district court's dismissal of his breach of contract and retaliation claim against Boston Scientific. Plaintiff filed for Chapter 7 bankruptcy and then Boston Scientific terminated his employment shortly after his filing. The court concluded that, because the guaranteed payments at issue, if due at all, were property of the bankruptcy estate, plaintiff lacked standing to assert his breach of contract claim. Plaintiff's argument that had Boston Scientific not terminated him, the payments he received under the Employment Agreement would have been future earnings also failed. Because plaintiff never requested leave to amend his complaint to include a retaliation claim, the district court could not be faulted for failing to allow him to do so. Accordingly, the court affirmed the judgment. View "Longaker v. Boston Scientific Corp., et al" on Justia Law

Officers appealed the district court's orders striking the officers' affidavits submitted in resisting summary judgment, and granting summary judgment to the city on the officers' Fair Labor Standards Act (FLSA), 29 U.S.C. 203 et seq., claims against the city. The officers alleged that the response team instituted a policy of flextime in January 2006 and ending November 2009 that gave flextime or time off rather than receiving overtime compensation at time-and-a-half in violation of the FLSA. The court held that the district court did not abuse its discretion by striking affidavits submitted by the officers which contained precise estimations of hours owed because the officers "unjustifiably failed to comply" with their discovery obligations. Further, the officers have failed to provide any evidence of actual damages. Accordingly, the court affirmed the judgment. View "Carmody, et al v. K. C. Board of Police Comm., et al" on Justia Law

Plaintiff argued on appeal that Home Service terminated him contrary to the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq., and that Home Service breached his contract. The court affirmed the district court's judgment, holding that the district court did not err in granting summary judgment to Home Service, because plaintiff was not qualified to perform an essential function of his job - being DOT qualified to drive a delivery truck - because of his eye injury. The court also held that the district court did not err in granting summary judgment on plaintiff's mileage reimbursement claim and on his bonus claim. Accordingly, the court affirmed the judgment. View "Knutson v. Schwan's Home Service, Inc., et al" on Justia Law

NSP sought to vacate an arbitration award, arguing that the arbitrator exceeded his authority under a Collective Bargaining Agreement (CBA) with the Union to grant an award after first determining that NSP had just cause for making its termination decision. The court held that the language of the arbitrator's decision was sufficient to show that the arbitrator found the termination was supported by just cause. Having answered the first submitted question in the affirmative, the arbitrator had no authority to address the second question of remedy or to fashion a remedy different than the termination. Therefore, the district court properly vacated the arbitrator's award for reaching beyond his authority under the CBA. View "Northern States Power Co. v. IBEW, Local 160" on Justia Law

Plaintiff sued the City and her supervisors, claiming that the City's reasons for terminating her were pretextual. The district court granted defendants' motion for summary judgment on all of plaintiff's seven claims. The court affirmed the judgment because there was no evidence or reasonable inference that the City's reasons for terminating plaintiff's employment for failure in performance of her duties were pretextual. View "Brown v. City of Jacksonville, et al" on Justia Law

DM&E and its president and CEO, defendant, entered into an Employment Agreement to encourage his retention following an anticipated change of control. When DM&E terminated defendant without cause and triggered the Employment Agreement's severance provision, defendant filed a demand for arbitration under the Employment Agreement. DM&E then filed this action in federal court to enjoin the arbitration. The court agreed with the district court that the benefits sought in defendant's arbitration demand were not claims for benefits due under an Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq., plan. The court held that it lacked federal subject matter jurisdiction to consider arbitrability, or any other issue arising under the Employment Agreement. View "Dakota, MN & Eastern R.R. v. Schieffer" on Justia Law