Justia Labor & Employment Law Opinion Summaries

At issue in this case was whether the delivery drivers for a Maine dairy company fell within the scope of an exemption from Maine’s overtime law. Specifically at issue was an exemption to the overtime law that covers employees whose work involves the “packing for shipment or distribution of” enumerated food products. The drivers argued that these words referred to the single activity of “packing,” whether the packing was for “shipment” or for “distribution.” The district court granted summary judgment to the dairy company, concluding that “distribution” was a stand-alone exempt activity. The First Circuit reversed, holding that the exemption at issue is ambiguous, and, under Maine law, must be construed in the narrow manner that the drivers favor in order to accomplish the overtime law’s remedial purposes. Remanded. View "O'Connor v. Oakhurst Dairy" on Justia Law

After James Walsh’s (Plaintiff) employment with Zurich American Insurance Company (Defendant) was terminated, he filed a complaint against Defendant, alleging breach of contract, willful violation of New Hampshire’s wage and hour law, and other claims based on Defendant’s substantial reduction of his incentive pay for a lucrative deal and failure to pay incentive on another deal. A jury found that Defendant willfully and without good cause withheld the compensation owed to Plaintiff and awarded him double damages and attorney’s fees. The First Circuit vacated the district court’s judgment insofar as it incorporated the jury’s verdict on one deal (the Great American Insurance Company, or GAIC, deal) and affirmed the judgment with respect to the other deal (the Automobile Protection Corp., or APCO, deal), holding (1) Defendant was not entitled to judgment as a matter of law on the breach of contract and wage claims; (2) the jury’s breach and willfulness findings stemming from Defendant’s withholding of incentive compensation for a deal made with GAIC were not in error; but (3) the district court erred in concluding that, if Plaintiff had an enforceable incentive plan when the deal was struck with APCO, Defendant lacked discretion as a matter of law to change Plaintiff’s incentive formula for that deal. Remanded. View "Walsh v. Zurich American Insurance Co." on Justia Law

This appeal concerned a dispute between employees represented by a Union and their successor employer. The parties agreed to arbitrate this dispute regarding change in the terms of pension provision in a collective bargaining agreement. The district court refused to compel arbitration on the grounds that ERISA preempted the Union’s claims, and this, in turn, presented an issue of arbitrability properly decided by a judge, not an arbitrator. The First Circuit vacated the order of the district court and remanded with instructions to grant the Union’s motion to compel arbitration, holding that the issue of ERISA preemption in this case was not an issue of arbitrability but, rather, one that was squarely for the arbitrator to decide. View "Prime Healthcare Services - Landmark LLC v. United Nurses & Allied Professionals, Local 5067" on Justia Law

Plaintiff filed suit against Puerto Rico’s Insurance Commissioner (Defendant), claiming that Defendant eliminated her job as a director within the Office of the Insurance Commissioner on account of her political affiliation. The district court denied Defendant’s motion for summary judgment as Plaintiff’s federal discrimination claims for damages, declaratory relief, and injunctive relief. In so holding, the court rejected Defendant’s argument that her qualified immunity defense entitled her to summary judgment on Plaintiff’s federal damages claim. The First Circuit reversed the district court’s denial of qualified immunity and remanded for further proceedings, holding that a reasonable official in Defendant’s position could have understood the First Amendment not to protect Plaintiff against politically motivated removal from her job. Remanded for further proceedings. View "Lopez-Erquicia v. Weyne-Roig" on Justia Law

Southeast Hospitals Group was formed through a merger of three hospitals, one of which had a union workforce. The union’s collective bargaining agreement granted union members a hiring preference when filling union positions. Southcoast, however, adopted a policy that grants nonunion employees a similar hiring preference for nonunion positions. The union commenced this action by filing an unfair labor practice charge with the National Labor Relations Board’s Regional Director. The Regional Director then filed a complaint with the Board, arguing that the policy unlawfully discriminates against union members. The Board concluded that the policy was invalid because it was not supported by a legitimate and substantial business justification and ordered Southcoast to rescind the policy and provide affirmative relief to affected employees. The First Circuit vacated the Board’s decision, holding that the decision was not supported by substantial evidence. Remanded. View "Southcoast Hospitals Group v. NLRB" on Justia Law

Eight police officers, a police cadet, and a provisionally hired 911 operator (collectively, the Officers) alleged that they suffered adverse employment actions by the Boston Police Department as a result of a racially discriminatory hair drug test. The Officers advanced a “disparate impact claim” under Title VII of the Civil Rights Act. The district court concluded that there was no actionable disparate impact. The first time on appeal, the First Circuit held that the Officers prevailed as a matter of law under the first prong of the three-prong disparate impact inquiry of that inquiry and remanded the case to the district court to consider the next two prongs. On remand, the district court again summary judgment for the Department. On appeal for the second time, the First Circuit vacated the district court’s grant of summary judgment to the Department on the third prong of the disparate impact inquiry, holding that a material dispute of fact existed preventing summary judgment on this matter. Remanded. View "Jones v. City of Boston" on Justia Law

Jamie Rogers, a seaman, was injured on a fishing vessel owned and operated by Block Island Fishing, Inc. Block Island made some “maintenance and cure” payments to Rogers. Block Island then brought this suit against Rogers to dispute the duration and amount of maintenance and cure payments that it owed. Block Island filed a motion for summary judgment. The district court found that November 18, 2014 was the date on which Block Island’s obligations ended and reserved for a jury to determine the exact sum that Block Island owed Rogers for his living expenses. The court then ruled that Block Island had overpaid Rogers and that Block Island could offset the sum of overpayment against any damages award that Rogers might win at trial. The First Circuit affirmed in part and vacated and remanded in part, holding (1) the district court erred by sua sponte replacing Block Island’s proposed date of July 31, 2014 with its own date without giving Rogers sufficient notice of opportunity to make his case against the new date; and (2) Block Island may offset any overpayment against Rogers’ potential damages award but may not sue for the sum in an independent action. View "Block Island Fishing, Inc. v. Rogers" on Justia Law

Plaintiffs, a group of construction-industry employers’ associations and employers, sought relief from a broad category of enforcement actions that may be brought under the Massachusetts Earned Sick Time Law (ESTL). Plaintiffs did so before any action to enforce the ESTL had been filed against any employer who was a party to a collective bargaining agreement (CBA). Plaintiffs argued that the ESTL was preempted by section 301 of the Labor-Management Relations Act with respect to those employers in the state who are parties to CBAs. Plaintiffs sought a judgment, inter alia, prohibiting the Massachusetts Attorney General from granting private rights of action to employees who are members of collective bargaining units. The district court dismissed the suit for failure to state a claim insofar as it constituted a facial, preemption-based challenge to the ESTL, and for lack of jurisdiction insofar as it represented an as-applied preemption-based challenge that was not ripe for adjudication. The First Circuit dismissed the suit for want of jurisdiction, holding that Plaintiffs’ request for pre-enforcement relief was not ripe for adjudication. View "Labor Relations Division of Construction Industries of Massachusetts, Inc. v. Healey" on Justia Law

Plaintiff, an African-American, filed an employment discrimination case against Amtrak, his employer, alleging that his opportunities for overtime were reduced because of his race and that he was subjected to a hostile work environment. The district court granted summary judgment in favor of Amtrak. The First Circuit affirmed, holding (1) Plaintiff failed to meet his initial burden of establishing a prima facie case of disparate treatment discrimination; and (2) even if Plaintiff’s complaints rose to the level of a hostile work environment, Plaintiff failed to demonstrate that he was subjected to any complained-of actions because of his race. View "Garmon v. National Railroad Passenger Corp." on Justia Law

Plaintiff filed a complaint against his employer, the United States Postal Service (USPS), and his supervisor, Michael King, (together, Defendants), alleging that Defendants terminated him from the Brookline, Massachusetts Post Office in retaliation for taking Family Medical Leave Act (FMLA) leave. Appellant alleged FMLA interference and FMLA retaliation in violation of 29 U.S.C. 2615, among other claims. The district court granted summary judgment on all claims with the exception of the FMLA retaliation claim. After a bench trial, the district court entered judgment for Defendants, concluding that Defendants could not have acted with retaliatory animus because King, as the USPS decisionmaker, lacked the requisite knowledge that Plaintiff’s leave was protected under the FMLA. The First Circuit affirmed, holding that the district court properly found that King lacked the requisite knowledge necessary to hold to hold him liable for retaliation in violation of the FMLA. View "Chase v. United States Postal Service" on Justia Law