Justia Labor & Employment Law Opinion Summaries

The plaintiff worked as an Admissions Coordinator at a Maryland hospital’s Center for Eating Disorders, where her duties required frequent in-person contact with medically vulnerable patients and other staff. During the COVID-19 pandemic, the hospital implemented a vaccine mandate for all employees, following state health directives and public health guidance. The hospital allowed employees to request religious or medical exemptions, evaluating each on a case-by-case basis. The plaintiff requested a religious exemption, which was denied after the hospital determined her role could not be performed remotely and that accommodating her would pose risks to patient safety. She was terminated after refusing vaccination.After her termination, the plaintiff filed a discrimination charge with the EEOC and then sued the hospital in the United States District Court for the District of Maryland, alleging a violation of Title VII for failure to accommodate her religious beliefs. The district court granted summary judgment to the hospital, finding that exempting the plaintiff from the vaccine requirement would have created an undue hardship by jeopardizing patient safety and increasing the risk of COVID-19 outbreaks in a sensitive healthcare environment.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit held that, under the standard clarified by the Supreme Court in Groff v. DeJoy, the hospital met its burden to show that granting the requested religious accommodation would have resulted in substantial increased costs and significant health and safety risks, both to patients and staff. The court also found that the hospital properly considered alternative accommodations and the aggregate impact of granting similar exemptions. The Fourth Circuit affirmed the district court’s judgment in favor of the hospital. View "Hall v. Sheppard Pratt Health System" on Justia Law

A professor was hired by a university in 2014 as a tenure-track Assistant Professor with a starting salary at the lowest end of the pay scale for her department. Over the next several years, she was denied promotions, demoted to at-will status, and claims she was paid less than male colleagues. She alleges that these actions were motivated by sex discrimination and retaliation for her complaints, including derogatory statements allegedly made by a department chair about her gender and sexual orientation. She filed charges with the Equal Employment Opportunity Commission (EEOC) and, after leaving the university, brought suit alleging violations of federal and state anti-discrimination laws.The United States District Court for the District of Maryland granted summary judgment to the university and individual defendants on all claims. The court found that her Title VII claims regarding the 2019 and 2020 promotion denials were procedurally barred—one as untimely and the other for failure to exhaust administrative remedies. The court also found that the evidence did not support her claims of sex discrimination, wage discrimination, or retaliation, concluding that the university’s stated reasons for its actions were legitimate and not pretextual.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. It affirmed the district court’s ruling that the Title VII claims related to the 2019 and 2020 promotion denials were procedurally barred. However, it reversed the grant of summary judgment on the remaining claims, holding that genuine disputes of material fact existed regarding sex discrimination in the 2016 promotion denial, retaliation, and wage discrimination. The court also held that the procedural bars of Title VII did not apply to the plaintiff’s claims under Title IX, Section 1983, or Maryland state law for the 2019 and 2020 promotion denials. The case was remanded for further proceedings on those claims. View "Hollis v. Morgan State University" on Justia Law

An attorney formerly employed by the Federal Public Defender’s Office (FDO) for the Western District of North Carolina alleged that her supervisor sexually harassed her. After she reported the harassment, the FDO’s Unit Executive took steps to separate her from the supervisor, including changing reporting lines, authorizing telework, and offering her a promotion. The attorney also initiated proceedings under the judiciary’s Employee Dispute Resolution (EDR) Plan, which provided for both investigation and mediation. During this process, she alleged additional retaliation and discrimination by the Unit Executive. She ultimately left her position and withdrew from the EDR process before a formal hearing could occur.The United States District Court for the Western District of North Carolina conducted a six-day bench trial and issued a lengthy decision. The court found that, while there were procedural missteps and some insensitive comments by supervisors, the FDO’s response to the harassment was not deliberately indifferent, retaliatory, or discriminatory. The court also found that the attorney’s due-process rights were not violated, as she was not coerced to abandon the EDR process based on a reasonable belief that the Unit Executive would be the final decisionmaker. The court granted summary judgment to two other officials, finding no evidence of discriminatory intent or deliberate indifference, and excluded certain “Me Too” evidence as inadmissible.The United States Court of Appeals for the Fourth Circuit, with a panel of judges from outside the circuit due to recusals, reviewed the case. The court affirmed the district court’s rulings, holding that the attorney failed to prove a due-process violation or equal-protection claim. The court found that the EDR process, while imperfect, was not fundamentally unfair or coercive, and that the FDO’s response to the harassment was not clearly unreasonable. The court also held that any error in excluding the “Me Too” evidence was harmless, denied the attorney’s motions to unseal certain materials and for summary reversal, and declined to consider a new constitutional challenge to Title VII’s exclusion of judiciary employees. View "Strickland v. Moritz" on Justia Law

Mary Herkert, an employee of the Social Security Administration (SSA) with multiple physical disabilities, requested a scheduled telework arrangement as an accommodation for her medical needs. After her request was denied and she indicated her intent to pursue equal employment opportunity remedies, Herkert was reassigned from her supervisory Branch Chief position to a non-supervisory management analyst role. Although the new position allowed her to telework as requested, Herkert contended that the reassignment was a demotion, resulting in a loss of supervisory authority, prestige, and advancement opportunities, despite no change in pay or benefits.After exhausting administrative remedies, Herkert filed suit in the United States District Court for the District of Maryland, alleging disability discrimination, retaliation, and failure to provide a reasonable accommodation under the Rehabilitation Act. The district court granted summary judgment to the SSA Commissioner, holding that Herkert’s reassignment did not constitute a sufficiently “significant” adverse employment action because her pay and benefits remained unchanged. The court also found the reassignment to be voluntary, relying on Herkert’s acceptance of the new position and her expression of gratitude. On this basis, the court concluded that Herkert could not prevail on her discrimination, retaliation, or reasonable accommodation claims.The United States Court of Appeals for the Fourth Circuit reviewed the case and vacated the district court’s judgment. The Fourth Circuit held that, in light of the Supreme Court’s decision in Muldrow v. City of St. Louis, a plaintiff challenging a job transfer for discrimination need not show a “significant” change in working conditions, but only “some disadvantageous change.” The appellate court also found genuine disputes of material fact regarding whether Herkert’s reassignment was truly voluntary. The case was remanded for further proceedings consistent with these clarified legal standards. View "Herkert v. Bisignano" on Justia Law

Sandra Gardner, a member of the International Association of Machinists, sought to bring a lawsuit against her union and several of its officers, alleging that the General Secretary-Treasurer, Dora Cervantes, had misused union funds for personal travel, thereby breaching her fiduciary duty under federal law. Before filing suit, Gardner and other union members sent multiple letters to the union’s leadership demanding an accounting of the allegedly misappropriated funds and requesting that the union itself bring legal action against the implicated officers. The union responded by commissioning an independent accounting firm to investigate the claims, which ultimately found no evidence of wrongdoing. The union’s Executive Council, relying on this report, declined to take further action.The United States District Court for the District of Maryland reviewed Gardner’s verified application for leave to file suit under 29 U.S.C. § 501(b). The district court denied her application, concluding that Gardner had not satisfied the statutory “demand requirement” because the union had responded to her request by conducting an accounting and found no basis for further action. The court did not address whether Gardner had shown “good cause” to proceed with her claim, as required by the statute.On appeal, the United States Court of Appeals for the Fourth Circuit held that Gardner had properly satisfied the demand requirement. The appellate court reasoned that Gardner’s letters clearly demanded both an accounting and that the union bring suit, and the union’s failure to initiate legal action meant the demand was not fully met. The Fourth Circuit reversed the district court’s denial of Gardner’s application and remanded the case for the district court to consider whether Gardner has demonstrated good cause to proceed with her § 501 claim. View "Gardner v. International Association of Machinists" on Justia Law

Dorothy Seabrook, a black woman, was the Family Programs Manager for the U.S. Army Reserve Command at Fort Bragg, North Carolina. In 2013, she was involved in disciplinary actions against an employee, Scott Hamilton. Subsequently, the Army investigated Seabrook for creating a toxic work environment and making inappropriate comments and physical contact. In 2014, she was suspended for two weeks and reassigned to another division. Seabrook filed an Equal Employment Opportunity (EEO) complaint in January 2015, alleging discrimination based on race, color, and sex. She received a poor performance evaluation in February 2015, which she believed was retaliatory, leading her to file a second EEO complaint.The Equal Employment Opportunity Commission (EEOC) investigated and found no discrimination. Seabrook then filed a pro se complaint in federal court, which was construed as alleging disparate treatment, hostile work environment, and retaliation under Title VII. The United States District Court for the Eastern District of North Carolina dismissed her complaint for failure to state a claim and denied her motion to alter or amend the judgment.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the district court's dismissal, holding that Seabrook failed to plausibly allege that the Army's actions were motivated by discriminatory bias. The court found that Seabrook's allegations did not support claims of disparate treatment, as her comparators were not similarly situated. Her hostile work environment claim failed because the alleged actions were not objectively abusive or severe. Lastly, her retaliation claim was dismissed due to a lack of causal connection between her EEO activity and the adverse employment actions. The court concluded that Seabrook's complaint did not meet the pleading standards required to survive a motion to dismiss. View "Seabrook v. Driscoll" on Justia Law

Wheeling Power Company operates the Mitchell Plant, where employees are represented by Local 492 under a collective bargaining agreement. After a fire at another plant owned by the same parent company, employees from that plant were temporarily assigned to the Mitchell Plant. These employees were not covered by Local 492’s agreement, leading the union to file a grievance. The grievance was denied, and the union took the matter to arbitration. The arbitrator found that assigning work to non-union employees violated the agreement but left the remedy to be determined by the parties, retaining jurisdiction in case of an impasse.The United States District Court for the Northern District of West Virginia upheld the arbitrator’s liability award. Wheeling Power appealed, arguing that the arbitrator exceeded his authority and that the award was not final because the remedy had not been determined.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that the complete arbitration rule applied, meaning the arbitrator’s decision was not final since he retained jurisdiction over the remedy. The court noted that the district court should have dismissed the case as premature. Despite Local 492 not raising this issue in the lower court, the appellate court chose to overlook the forfeiture to reinforce the complete arbitration rule’s importance and to avoid piecemeal litigation.The Fourth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss it without prejudice, allowing the parties to return to court once the arbitrator’s award becomes final. View "Wheeling Power Company - Mitchell Plant v. Local 492 Utility Workers Union of America" on Justia Law

Wilbert Finley, a production manager at Kraft Heinz’s Newberry, South Carolina plant, was responsible for overseeing product quality and food safety. Finley raised concerns about food safety, particularly regarding improperly sealed bacon packages and bone fragments in the meat. He reported these issues to his supervisors and HR, but was criticized and told not to stop production. On March 24, 2020, Finley was suspended and then terminated two days later, allegedly for dishonesty during an HR investigation into the botched firing of another employee, Yolanda Gaines.The United States District Court for the District of South Carolina granted summary judgment to Kraft Heinz, adopting the magistrate judge’s report and recommendation. The magistrate judge concluded that Finley could not establish that his safety complaints were a “contributing factor” in his dismissal, citing the March 24 investigation as a legitimate intervening event that severed any causal connection. The district court agreed, also finding that Kraft Heinz had shown by clear and convincing evidence that it would have terminated Finley regardless of his complaints.The United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded the case. The appellate court held that the district court and magistrate judge failed to properly consider all the evidence, including the close temporal proximity between Finley’s complaints and his termination, and the disputed facts regarding the March 24 investigation. The court found that a reasonable jury could infer that Finley’s food safety complaints contributed to his termination and that Kraft Heinz’s rationale for firing him was pretextual. Thus, the case was remanded for further proceedings. View "Finley v. Kraft Heinz Inc." on Justia Law

Katrina Robertson, an independent contractor working as a polygraph examiner for the Defense Intelligence Agency (DIA), was involved in an automobile accident while exiting the DIA campus. She sued the United States under the Federal Tort Claims Act (FTCA), alleging that a DIA employee's negligence caused the accident. The government moved to dismiss the case for lack of subject matter jurisdiction, arguing that it had not waived its sovereign immunity under the FTCA because a private employer in similar circumstances would be immune from suit under Virginia law.The United States District Court for the Eastern District of Virginia granted the government's motion to dismiss. The court found that the DIA was a "statutory employer" under the Virginia Workers' Compensation Act (VWCA) and that Robertson's injury occurred during the course of her work. Therefore, the VWCA provided the exclusive remedy, and the government was immune from the suit. The district court also denied Robertson's motion to certify a question to the Supreme Court of Virginia as moot.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that under the FTCA, the United States is liable only to the extent that a private party would be liable in similar circumstances. Since a private employer in Virginia would be immune from a negligence suit under the VWCA if it were a statutory employer, the United States had not waived its sovereign immunity. The court concluded that the district court properly dismissed the case for lack of subject matter jurisdiction. View "Robertson v. United States" on Justia Law

The case involves Medical Staffing of America, LLC, doing business as Steadfast Medical Staffing, and its owner, Lisa Ann Pitts, who were found to have violated the Fair Labor Standards Act (FLSA) by misclassifying approximately 1100 nurses as independent contractors instead of employees. This misclassification led to the nurses not receiving proper overtime compensation, resulting in nearly five million dollars in unpaid wages and an equal amount in liquidated damages.The United States District Court for the Eastern District of Virginia conducted a bench trial in 2021, where it found that Steadfast exercised significant control over the nurses, including setting their pay rates, controlling their schedules, and enforcing workplace policies. The court concluded that the nurses were employees under the FLSA and awarded the Secretary of Labor unpaid overtime compensation and liquidated damages. Steadfast's defense, claiming they acted in good faith based on legal advice, was rejected as the court found their reliance on incomplete legal advice unreasonable.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's judgment. The appellate court agreed with the lower court's findings that the nurses were employees based on the economic realities of their relationship with Steadfast. The court also upheld the district court's rejection of Steadfast's good faith defense and its adoption of the damages computations presented by the Secretary of Labor. The final judgment included over nine million dollars in unpaid overtime compensation and liquidated damages, along with an injunction against further FLSA violations by Steadfast. View "Chavez-DeRemer v. Medical Staffing of America, LLC" on Justia Law