Justia Labor & Employment Law Opinion Summaries

Plaintiff filed suit against the Postal Service for breach of prior settlement agreements, as well as various other claims related to her employment at the Postal Service. The district court dismissed plaintiff's breach of contract claim for lack of subject matter jurisdiction, holding that the Tucker Act, 28 U.S.C. 1491(a)(1), granted the Court of Federal Claims exclusive jurisdiction to hear breach of contract claims against the Postal Service that put more than $10,000 in controversy. The district court also dismissed seven of plaintiff's claims for lack of subject matter jurisdiction because plaintiff had not complied with the Federal Tort Claims Act (FTCA), 28 U.S.C. 2675(a), and held that plaintiff's three remaining claims were barred by res judicata. The court concluded that, even assuming that the Tucker Act conferred jurisdiction on the Court of Federal Claims to hear claims against the Postal Service, the Postal Reorganization Act (PRA), 39 U.S.C. 401 and 409, also vested the district court with independent jurisdiction over such claims. Therefore, the court reversed the district court's determination that it lacked subject matter jurisdiction to hear plaintiff's breach of contract claim. Although the district court had subject matter jurisdiction to consider plaintiff's breach of contract claim, it did not err in dismissing it because she failed to state a claim upon which relief could be granted. None of her remaining claims were viable and, therefore, the court affirmed the dismissal of her complaint. View "Tritz v. U.S. Postal Service" on Justia Law

This case arose when EGT filed charges against the Union with the Board after the Union engaged in protest activities at the site of a grain terminal operated by EGT. On appeal, the Union challenged the district court's contempt awards. The court concluded that the district court did not abuse its discretion when it awarded compensatory damages to EGT and that the record supported the amount of damages awarded to EGT. The court concluded, however, that the district court abused its discretion when it awarded compensatory damages to BNSF and the various law enforcement agencies that responded to the scenes of the Union's protests, because these entities were not parties to the underlying Board action. Accordingly, the court affirmed in part and reversed in part. View "Ahearn v. Int'l Longshore & Warehouse Union" on Justia Law

Plaintiffs, current and former employees of Amgen and AML, participated in two employer-sponsored pension plans, the Amgen Plan and the AML Plan. The Plans were employee stock-ownership plans that qualified as "eligible individual account plans" (EIAPs) under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1107(d)(3)(A). Plaintiffs filed an ERISA class action against Amgen, AML, and others after the value of Amgen common stock fell, alleging that defendants breached their fiduciary duties under ERISA. The court concluded that defendants were not entitled to a presumption of prudence under Quan v. Computer Sciences Corp., that plaintiffs have stated claims under ERISA in Counts II through VI, and that Amgen was a properly named fiduciary under the Amgen Plan. Therefore, the court reversed the decision of the district court and remanded for further proceedings. View "Harris v. Amgen" on Justia Law

Plaintiff, seeking to represent approximately 538 employees of Medline, appealed the district court's denial of class certification. The complaint asserted claims against Medline for violating California labor laws. The court concluded that the district court applied the wrong legal standard and abused its discretion when it denied class certification on the grounds that damages calculations would be individual. The district court also abused its discretion by finding that the class would be unmanageable despite the record's demonstration to the contrary. Therefore, the court reversed and remanded with directions to enter an order granting plaintiff's motion for class certification. View "Leyva v. Medline Industries, Inc." on Justia Law

Plaintiff brought suit against Boeing and BISS alleging breach of contract as well as several statutory and common law claims. At issue was the enforceability of a forum selection clause. The court held that the evidence submitted and the allegations made by plaintiff were more than sufficient to create a triable issue of fact as to whether the forum selection clause at issue here was enforceable under M/S Bremen v. Zapata Off-Shores Co. Therefore, the district court abused its discretion by granting BISS's motion to dismiss without convening an evidentiary hearing. The district court also abused its discretion in denying plaintiff leave to amend his pleadings. Accordingly, the court reversed and remanded. The court did, however, grant Boeing's and BISS's joint motion to strike the portions of plaintiff's reply brief that included new evidence or alleged new facts not in the record before the district court. View "Petersen v. Boeing Co." on Justia Law

Plaintiffs sued Integrity on behalf of a putative class of workers, claiming violations of the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and Nevada labor laws. Plaintiffs alleged that Integrity violated federal and state labor laws by requiring them to pass through a security clearance at the end of each shift, for which they were not compensated. Plaintiffs also sought compensation for their entire 30-minute unpaid lunch periods because they spent up to 10 minutes of the meal period walking to and from the cafeteria and/or undergoing security clearances. The court agreed with the other circuits to consider the issue that the fact that Rule 23 class actions use an opt-out mechanism while FLSA collective actions use an opt-in mechanism did not create a conflict warranting dismissal of the state law claims. The court concluded that preliminary and postliminary activities were still compensable under the FLSA if they were integral and indispensable to an employee's principal activities. Because the court held that plaintiffs have stated a valid claim for relief under the FLSA for the time spent passing through security clearances, the court reversed the district court's dismissal of the parallel state law claim. The court agreed that plaintiffs failed to state a claim under the FLSA for their shortened lunch periods. The court remanded to the district court to consider plaintiffs' argument that Nevada defined "work" differently than federal law, such that plaintiffs' lunch periods might be compensable under state law even if they were not compensable under federal law. View "Busk, et al v. Integrity Staffing Solution" on Justia Law

In 2001, petitioner fell from a barge to a dry dock while working as a ship laborer. He then filed a workers' compensation claim under the Longshore and Harbor Workers' Compensation Act, 33 U.S.C. 901-950, for the injuries from his fall. In 2003, petitioner shot himself in the head, causing severe injuries. Petitioner also sought compensation for these injuries under the Act, alleging that his suicide attempt resulted from his 2001 fall and the litigation over that claim. The Benefits Review Board subsequently affirmed the ALJ's denial of benefits. The court held, however, that evidence that a claimant planned his suicide did not necessarily preclude compensation under the Act because the proper inquiry was whether the claimant's work-related injury caused him to attempt suicide. In this case, the ALJ erroneously applied the irresistible impulse test instead of the chain of causation test. Therefore, the court granted the petition for review and remanded for further proceedings. On remand, the question was whether there was a direct and unbroken chain of causation between petitioner's work-related injury and his suicide attempt. View "Kealoha v. Office of Workers Comp. Programs" on Justia Law

Plaintiffs, former employees of brokerage firms, filed four class actions challenging California's forced-patronage statute, section 450(a) of the California Labor Code. At issue was whether federal securities law preempted the enforcement of California's forced-patronage statute against brokerage houses that forbid their employees from opening outside trading accounts. The court affirmed the judgment and concluded that the district court correctly determined that the Securities Exchange Act of 1934, 15 U.S.C. 78o(g), and related self-regulatory organizations (SROs) rules preempted plaintiffs' forced-patronage suits. View "McDaniel, et al v. Wells Fargo Investments, LLC, et al" on Justia Law

Plaintiff brought a Title VII action against her former employer, West Coast, claiming sexual harassment and retaliatory discharge. The district court granted summary judgment to West Coast and plaintiff appealed. Because the court concluded that the evidence, viewed favorably to plaintiff, did not show sexual harassment that was sufficiently severe or pervasive to alter the terms of plaintiff's employment and subject her to an abusive environment, the court affirmed the judgment for West Coast on her sexual harassment claim. The court concluded that the evidence was sufficient to raise a material question of fact as to whether plaintiff's July 14 complaints - which the court already said could be protected activity - were a but-for cause of her termination. Therefore, the court believed that the district court erred in granting summary judgment on the retaliation claim. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Westendorf v. West Coast Contractors of NV" on Justia Law

This case stemmed from a union dispute involving local union officials who diverted union resources in an attempt to establish a new competing union. At issue on appeal was whether section 501 of the Labor Management Reporting and Disclosure Act (LMRDA), 29 U.S.C. 501, created a fiduciary duty to the union as an organization, not merely the union's rank-and-file members. The court held that it did. Because defendants were not entitled to an authorization defense, the record was sufficient to support the jury's finding that defendants violated their fiduciary duties to UHW under section 501. The district court did not abuse its discretion by excluding irrelevant evidence. The district court properly issued the permanent injunction. The court upheld that district court's interpretation of the verdict form and its denial of defendants' motion to alter or amend the judgment. There was no abuse of discretion in the district court's ruling on the challenge to the special verdict. Accordingly, the court affirmed the judgment. View "SEIU, et al v. NUHW, et al" on Justia Law