Justia Labor & Employment Law Opinion Summaries

A former applicant for the position of police commissioner in St. Louis alleged that after a competitive selection process, he and another white male candidate were certified as the only eligible finalists. The mayor publicly stated she did not want to select either finalist because both were white males, emphasizing the city’s diversity. The city then abandoned the original selection process, reopened the search with lower minimum qualifications, and ultimately hired a different white male candidate after two Black finalists withdrew. The plaintiff, who was ranked first and asserted he was entitled to the position under civil service rules, claimed the process was reopened solely due to the race of the finalists.The United States District Court for the Eastern District of Missouri denied the defendants’ motion to dismiss on the grounds of failure to state a claim and qualified immunity. The court found that the plaintiff had plausibly alleged an adverse employment action and a violation of clearly established equal protection rights, relying on the Supreme Court’s decision in Ricci v. DeStefano, which prohibits invalidating a selection process based on race. The defendants argued that the plaintiff suffered no adverse employment action since a white male was ultimately selected and asserted that the plaintiff had no entitlement to the promotion.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed only the denial of qualified immunity. The appellate court held that, accepting the allegations as true, the complaint sufficiently alleged that the defendants’ actions violated the plaintiff’s clearly established right to equal protection by reopening the hiring process for racial reasons and denying him promotion. The court also found the complaint adequately alleged personal involvement by each defendant. The Eighth Circuit affirmed the district court’s order denying qualified immunity and left the underlying claims to be resolved in further proceedings. View "Sack v. City of St. Louis" on Justia Law

Dale Gourneau worked as a carman for BNSF Railway Company, inspecting railroad cars to ensure compliance with safety regulations. In January 2020, BNSF terminated Gourneau following a disciplinary proceeding. Gourneau subsequently filed a whistleblower complaint with the Occupational Safety and Health Administration of the Department of Labor, alleging that BNSF unlawfully retaliated against him for reporting hazardous safety conditions in good faith.After administrative proceedings, an Administrative Law Judge found in favor of Gourneau, ordering reinstatement, backpay, compensatory damages, punitive damages, and attorneys’ fees. The Administrative Review Board affirmed the ALJ’s decision and order. BNSF petitioned the United States Court of Appeals for the Eighth Circuit for review, arguing that the Department’s process violated the company’s Seventh Amendment right to a jury trial.The United States Court of Appeals for the Eighth Circuit examined whether the administrative adjudication of Gourneau’s claims for legal remedies—liability, backpay, compensatory damages, and punitive damages—implicated the Seventh Amendment. The court determined that Gourneau’s claim was analogous to a common-law wrongful discharge action and sounded basically in tort, entitling BNSF to a jury trial. The court rejected arguments that the “public rights” exception allowed agency adjudication without a jury trial, finding that Gourneau’s claim was a standalone suit between private parties and not so integrated into a regulatory scheme as to justify agency resolution without a jury. The court concluded that Congress may not avoid a jury trial by assigning such disputes to an agency.The Eighth Circuit granted the petition for review, vacated the order of the Administrative Review Board, and remanded the case for further proceedings consistent with its opinion, holding that BNSF is entitled to a jury trial on Gourneau’s claims for legal remedies before any equitable claims are adjudicated. View "BNSF Railway Co. v. Dept. of Labor" on Justia Law

A Native American woman was recruited in 2017 to work as a Clinical Research Manager at a health research institute that focuses on underserved populations, including Native Americans. She supervised a small team and was initially hired, in part, because her background was seen as beneficial for engaging Native American study participants and diversifying management. Over several years, she led or participated in research studies, experienced workplace conflicts, and alleged that she and her assistant were subject to “tokenism” and disparate treatment. In 2022, following complaints about workplace discrimination, disputes over recruitment methods, and changes in her role, the institute’s leadership eliminated her position as part of a reduction in force (RIF) to meet a 5% budget improvement mandate. Her salary was funded mostly by internal, non-grant money, unlike other managers whose salaries were grant-funded.She filed suit in the United States District Court for the District of South Dakota, alleging race discrimination in violation of Title VII and state law. The district court granted summary judgment for the employer, finding that she failed to establish a prima facie case of race discrimination and failed to show that the RIF was a pretext for unlawful discrimination.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. Applying the McDonnell Douglas burden-shifting framework, the court assumed without deciding that a prima facie case was made, but held that the employer had articulated a legitimate, non-discriminatory reason for the termination: budgetary constraints and the unique funding of her position. The appellate court further found that the plaintiff did not present sufficient evidence for a reasonable jury to conclude that this stated reason was pretextual or that racial discrimination was a determinative factor in her termination. The Eighth Circuit affirmed the district court’s judgment. View "Tobacco v. McKennan" on Justia Law

The plaintiff, a lead engineer employed by JanCo FS3, LLC (doing business as Velociti Services), worked at UMB Bank's Technology Operations Center in Kansas City and later at the 1010 Grand Building. He had a permanent disabled parking placard due to an ankle replacement, which affected his mobility. After his building assignment changed, he requested to park in a handicap spot at 1010 Grand, rather than his assigned spot at the Tech Center. Velociti requested updated medical documentation to support his accommodation request, but the plaintiff only provided his handicap placard renewal paperwork, which did not explain his disability or limitations. Despite repeated requests and deadline extensions from Velociti, he did not submit the required medical certification. He continued to park in the unassigned garage, received disciplinary warnings, and was ultimately fired for insubordination.The United States District Court for the Western District of Missouri granted summary judgment in favor of the defendants, finding that the plaintiff failed to provide sufficient medical documentation to support his accommodation request and did not demonstrate that the defendants’ actions were motivated by discriminatory animus. The court held that the employer’s enforcement of its parking policy and subsequent termination of the plaintiff for insubordination constituted legitimate, non-discriminatory reasons for the adverse action.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The Eighth Circuit affirmed the district court’s decision, holding that any breakdown in the interactive process was due to the plaintiff’s failure to provide necessary medical information, not the employer’s refusal to accommodate. The court also held that the plaintiff did not present direct or indirect evidence of disability discrimination or retaliation, and that the employer’s stated reason for termination was not pretextual. The judgment for the defendants was affirmed. View "Hibbert v. MC Realty Group, LLC" on Justia Law

Five individuals obtained over $1.8 million in workplace sexual harassment judgments against various related business entities and individuals. When these judgments went unpaid, they brought a civil suit under the Racketeer Influenced and Corrupt Organizations Act (RICO) against fifteen defendants, alleging a scheme to evade collection of the judgments. The plaintiffs claimed that the defendants orchestrated fraudulent asset transfers and used a sham consignment scheme involving false customs forms to prevent the plaintiffs from seizing assets to satisfy their judgments.Previously, the United States District Court for the Southern District of Iowa dismissed the plaintiffs’ RICO claims based on predicate acts of bankruptcy crimes, money laundering, and obstruction of justice, as well as their claim for declaratory relief regarding alter ego liability. However, the court allowed the RICO claims predicated on wire fraud related to the consignment scheme to proceed. After discovery, the defendants moved for summary judgment. The district court granted summary judgment for the defendants, holding that the plaintiffs failed to show proximate causation between the alleged wire fraud and their inability to collect on their judgments, and that they were not entitled to adverse inference sanctions for alleged discovery misconduct.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The Eighth Circuit held that the plaintiffs failed to establish that the consignment scheme was a but-for cause of their injury, as they did not show that any assets subject to seizure belonged to the judgment debtors. The court further concluded that claims based on other predicate offenses failed due to insufficient evidence and lack of particularity. The appellate court also found no error in the district court’s refusal to draw adverse inferences or to allow amendment of the complaints at this stage. The court affirmed summary judgment for all defendants on all claims. View "Rennenger v. Aquawood, LLC" on Justia Law

Anthony Knight was employed by Cambria Company, LLC as a process engineering technician, primarily assisting with production line functionality. In late 2022, Knight’s father passed away, leading Knight to struggle with depression. He subsequently requested and was granted leave under the Family and Medical Leave Act (FMLA) from February to April 2023. In mid-March 2023, while Knight was on FMLA leave, Cambria terminated his employment, citing elimination of his position due to a reduction in force. Cambria stated that Knight was selected for termination because of his shorter period of employment compared to other employees, and his job responsibilities were shifted to other departments without hiring a replacement.Knight filed suit in the United States District Court for the District of Minnesota, alleging that Cambria discriminated against him and interfered with his FMLA entitlements. During discovery, Cambria asserted that the decision to terminate Knight was based solely on seniority and the need to reduce headcount due to production slowdowns. The district court granted summary judgment in favor of Cambria, finding that Knight had not produced sufficient evidence of discriminatory intent or pretext, and that Cambria provided legitimate, nondiscriminatory reasons for his termination.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The Eighth Circuit held that Knight failed to raise a genuine dispute as to whether Cambria’s stated reasons for termination were pretextual or connected to his FMLA leave. The court found that Cambria’s reduction in force and reliance on seniority were legitimate reasons, and Knight’s evidence did not show intentional discrimination or unlawful interference with FMLA rights. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "Knight v. Cambria Company, LLC" on Justia Law

Becky Joseph was employed as a Lead Installer by a Minnesota-based construction company. After being hired, she worked on projects in Nevada and experienced conflicts with several supervisors. Joseph frequently complained to management about being disrespected and not having her opinions valued, and at one point threatened to resign, but later withdrew her resignation. She was involved in a minor workplace accident and had an incident with hotel staff during a company-provided stay. After further complaints about her supervisors, Joseph alleged that the men at the company were treated as more valuable than women and referenced discrimination. The company investigated her complaints but found no substantiating evidence. Joseph was then offered a transfer to another jobsite, which she declined, choosing instead to resign.Joseph subsequently filed suit in the United States District Court for the Western District of Michigan, alleging sex discrimination and retaliation in violation of Title VII of the Civil Rights Act and Michigan’s Elliott-Larsen Civil Rights Act. The case was transferred to the District of Minnesota, where the district court granted summary judgment for the employer. The district court found that Joseph’s complaints did not mention sex discrimination until after the events in question, that there was no evidence linking the employer’s actions to discriminatory animus, and that her claims were not supported by any documentary evidence. The court also determined that Joseph’s complaints did not amount to protected activity under the retaliation statutes.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed. The court held that Joseph failed to provide direct evidence or sufficient facts to support a prima facie case of discrimination or retaliation. The court determined the employer had legitimate, non-discriminatory reasons for its actions and that Joseph had not shown those reasons were pretextual. The judgment of the district court was affirmed. View "Joseph v. Thomas-Grace Const. Inc." on Justia Law

Several local iron workers unions and their associated trust fund boards sued a Tennessee-based company, alleging that the company failed to make required contributions for work performed by its employees within the unions’ territorial jurisdiction. The plaintiffs claimed the company was obligated to make these contributions under collective bargaining agreements with the unions, and they sought to recover the amounts they alleged were owed, including interest and damages.The United States District Court for the Eastern District of Missouri handled the case. During discovery, the defendant company moved to exclude the testimony of the plaintiffs’ witness, Bradley Soderstrom, arguing he was an undisclosed expert and his damages calculations were speculative. The district court agreed, excluding Soderstrom’s expert opinions and associated audit reports because the plaintiffs had not disclosed him as an expert and his calculations relied on unsupported assumptions. The district court granted summary judgment in favor of the company on one claim after finding the company was not a party to the relevant agreement, and on the remaining claims due to lack of admissible evidence of damages. The court also awarded attorneys’ fees to the company but did not set an amount. Plaintiffs appealed, challenging the exclusion of Soderstrom’s testimony, the grant of summary judgment, and the award of attorneys’ fees.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s exclusion of Soderstrom’s testimony, noting that plaintiffs failed to contest the finding that his damages model was speculative. The appellate court also affirmed summary judgment for the company because plaintiffs had no admissible evidence of damages without Soderstrom’s expert analysis. The court dismissed the appeal regarding attorneys’ fees, finding it was not ripe since the district court had not yet determined the fee amount. View "Iron Workers STL Pension Fund v. Barnhart Crane & Rigging Co." on Justia Law

Kevin Flowers, a participant in an employee benefits plan governed by the Employee Retirement Income Security Act of 1974 (ERISA), receives prescription drug benefits administered by Caremark, a pharmacy benefits manager. Flowers alleges that Caremark unjustly enriches itself by limiting maintenance prescription coverage to either CVS retail pharmacies or Caremark’s mail-order delivery service. He claims this violates Arkansas statutes requiring PBMs not to mandate home delivery and to provide reasonably adequate and accessible pharmacy networks, leading him and similarly situated individuals to pay out of pocket at local pharmacies.Reviewing the case, the United States District Court for the Western District of Arkansas granted Caremark’s motion to dismiss. The court determined that Flowers failed to plausibly plead a violation of the Mail Order Provision because Caremark did not require prescriptions to be filled solely through home delivery. Regarding the Network Adequacy Provision, the district court found that ERISA preempted the Arkansas requirements, particularly those imposing geographic coverage standards for pharmacy networks.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s dismissal de novo. The court affirmed the district court’s ruling, holding that Flowers did not plausibly allege a violation of the Mail Order Provision. The court also concluded that the geographic coverage requirements imposed by Arkansas regulations under the Network Adequacy Provision are preempted by ERISA, as they force PBMs to tailor their networks in ways that interfere with nationally uniform plan administration and constitute an impermissible connection with ERISA plans. The court expressly left open whether the Network Adequacy Provision, without its implementing regulations, would also be preempted. The court affirmed the district court’s dismissal of Flowers’s claims. View "Flowers v. Caremark PCS Health, LLC" on Justia Law

Sara Dobbins worked for the U.S. Department of Agriculture (USDA) and experienced mental health issues related to domestic abuse, leading to accommodations at work such as flexible schedules and telework. After her supervisor retired, the USDA allowed her to continue with adjusted scheduling, but with new requirements. When Charles Parr became her supervisor in 2021, he restricted these accommodations due to her frequent unapproved absences and tardiness. Over four months, Dobbins accumulated over thirty “absent without leave” infractions. The USDA suspended her, and later terminated her employment. Dobbins filed an EEOC complaint alleging sex and disability discrimination, hostile work environment, failure to accommodate, and retaliation. The EEOC found no actionable harassment or discrimination.The United States District Court for the Western District of Missouri granted summary judgment in favor of the USDA, finding that Dobbins did not provide sufficient evidence of discrimination or harassment, and failed to exhaust administrative remedies for her failure to accommodate claim.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment order de novo. The appellate court agreed that Dobbins did not present direct or indirect evidence that her suspension or termination were motivated by discrimination based on sex or disability. The court found that her absences, not her disabilities, were the basis for the adverse actions, and that her comparator evidence was insufficient as the other employee was not similarly situated. The court further held that Dobbins’s hostile work environment claim failed because the conduct described was not sufficiently severe or pervasive, nor clearly linked to her disability. Additionally, her failure to accommodate claim was barred for failure to exhaust administrative remedies, and her sex discrimination and retaliation claims were waived because she did not contest them at summary judgment. The court affirmed the district court’s judgment. View "Dobbins v. Rollins" on Justia Law