Justia Labor & Employment Law Opinion Summaries

The case involves the Board of Trustees of a multiemployer pension plan primarily benefitting unionized bakery drivers in New York City, which applied for Special Financial Assistance (SFA) in 2022. The Pension Benefit Guaranty Corporation (PBGC) denied the application, citing the plan's termination in 2016 as a disqualifying factor. The Fund, asserting it was in "critical and declining status," sued under the Administrative Procedure Act (APA).The United States District Court for the Eastern District of New York granted summary judgment in favor of the PBGC, agreeing that the plan's termination made it ineligible for SFA. The court also concluded that a terminated plan could not be restored under ERISA, thus affirming the PBGC's denial of the Fund's application.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the SFA statute does not exclude plans based solely on a prior termination. The court found that the statute's reference to "critical and declining status" incorporates the definition from 29 U.S.C. § 1085(b)(6) without importing limitations from other sections. Consequently, the court reversed the district court's judgment and remanded the case with instructions to enter summary judgment for the Fund, vacate the PBGC's denial of the SFA application, and remand to the PBGC for reconsideration. View "Bd. of Trs. of the Bakery Drivers Loc. 550 v. Pension Benefit Guaranty Corporation" on Justia Law

Natasha Knox, a Black woman of Jamaican descent, worked as a customer service attendant at three Clean Rite laundromats in the Bronx from December 2018 until her termination in April 2019. She alleged that her supervisors, Cecilia Ashmeade and Kenneth Ferris, made derogatory comments about her race and national origin, and that Clean Rite failed to accommodate her disability following a thumb injury. Knox also claimed she was not paid for extra shifts worked at other locations and was wrongfully terminated after reimbursing herself for taxi fare from the cash register, which she claimed was permitted.The United States District Court for the Southern District of New York granted summary judgment in favor of Clean Rite, dismissing Knox’s claims of discriminatory and retaliatory termination, hostile work environment, refusal to accommodate her disability, and unpaid wages. The district court found that Knox had not provided sufficient evidence to support her claims. Knox’s motion to strike the defendants’ answer and request for default judgment against Ashmeade and Ferris, who had failed to appear, was denied as moot.The United States Court of Appeals for the Second Circuit reviewed the case de novo and found that Knox had presented sufficient evidence to survive summary judgment on all her claims. The court noted that evidence such as Knox’s testimony and sworn affidavit could lead a reasonable jury to find in her favor. The court vacated the district court’s judgment and remanded the case for further proceedings on each of Knox’s claims. The claims against Ashmeade and Ferris were reinstated for the district court to reconsider Knox’s motion to strike their answer and for default judgment. View "Knox v. CRC Management Co." on Justia Law

Angel Tudor, a teacher with post-traumatic stress disorder (PTSD), worked for Whitehall Central School District for approximately 20 years. Tudor had an accommodation allowing her to leave campus for 15-minute breaks during her prep periods to manage her PTSD symptoms. In 2016, Whitehall prohibited teachers from leaving school grounds during prep periods, leading Tudor to take medical leave. Upon her return, Whitehall provided inconsistent accommodations, which Tudor claimed were insufficient. For the 2019-20 school year, Tudor's schedule included a study hall period during which she was not guaranteed her requested break, leading her to take unauthorized breaks.The United States District Court for the Northern District of New York granted summary judgment in favor of Whitehall, holding that Tudor's ability to perform her job without accommodation was fatal to her failure-to-accommodate claim under the Americans with Disabilities Act (ADA). The court assumed Tudor had a qualifying disability but found that she could not establish the third element of her claim because she could perform her job's essential functions without accommodation.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that the district court erred. The appellate court held that an employee may qualify for a reasonable accommodation under the ADA even if they can perform the essential functions of their job without it. The court emphasized that the ADA requires employers to provide reasonable accommodations, not just necessary ones. The judgment of the district court was vacated, and the case was remanded for further proceedings consistent with this opinion. View "Tudor v. Whitehall Central School District" on Justia Law

Three former employees of Amazon filed a class action complaint seeking payment for straight-time and overtime wages under Connecticut’s wage laws for time spent undergoing mandatory security screenings after clocking out. The employees argued that this time should be compensable under state law. Amazon required employees to pass through security screenings when exiting the secured area of their fulfillment centers, but not upon entry. The screenings involved metal detectors and varied based on the personal belongings employees carried. Employees were not compensated for the time spent in these screenings.The United States District Court for the District of Connecticut granted summary judgment in favor of Amazon, dismissing the employees' complaint. The court relied on the United States Supreme Court’s decision in Integrity Staffing Solutions, Inc. v. Busk, which held that time spent in mandatory security screenings is not compensable under federal law. The employees appealed the decision and moved to certify a question to the Connecticut Supreme Court regarding the applicability of Connecticut’s wage laws to their case.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the question of whether Connecticut’s wage laws require compensation for time spent in mandatory security screenings is unresolved. The court decided to certify this question to the Connecticut Supreme Court for a definitive resolution. Additionally, the court asked the Connecticut Supreme Court to address whether a de minimis exception applies to such compensable time and, if so, what amount of time is considered de minimis. The Second Circuit reserved its decision and dismissed the employees' motion to certify as moot, pending the Connecticut Supreme Court's response. View "Del Rio v. Amazon.com.DECE, LLC" on Justia Law

Xerox Corporation filed a petition under Section 301 of the Labor Management Relations Act (LMRA) for injunctive and declaratory relief against Local 14A, Rochester Regional Joint Board, Xerographic Division Workers United (the Union). After the collective bargaining agreement (CBA) between Xerox and the Union expired, Xerox terminated retiree benefits. The Union argued that Xerox could not unilaterally terminate vested benefits and sought to enforce the expired agreement’s arbitration provision. Xerox sought to stay and enjoin arbitration.The United States District Court for the Western District of New York granted Xerox’s petition, concluding that the Union’s grievance was not arbitrable under the expired CBA. The district court reasoned that the Union failed to identify language in the agreement that could be understood to have promised vested benefits beyond the agreement’s expiration. Additionally, the reservation-of-rights clause in plan documents barred an interpretation that benefits had vested.On appeal, the Union argued that the district court erred. The United States Court of Appeals for the Second Circuit agreed with the Union. The appellate court found that the Union identified language that could be reasonably understood as guaranteeing benefits beyond the contract’s expiration or as constituting deferred compensation. Furthermore, the reservation-of-rights clause in plan documents did not conclusively bar an interpretation that benefits had vested. To discern the parties’ intent, the appropriate trier of fact would need to consult extrinsic evidence.Accordingly, the Second Circuit vacated the district court’s judgment and remanded the case for further proceedings. View "Xerox Corporation v. Local 14A, Rochester Regional Joint Board, Xerographic Division Workers United" on Justia Law

The New York Court of Appeals answered a certified question from the Second Circuit, holding that liability under Section 296(15) the New York State Human Rights Law (NYSHRL) is limited to an aggrieved party's employer. The New York Court of Appeals answered a second certified question by identifying four factors to use in determining whether an entity is an aggrieved party's employer: the selection and engagement of the servant; the payment of salary or wages; the power of dismissal; and the power of control of the servant's conduct. In this case, plaintiffs filed suit alleging that Sirva, Inc., as Allied's parent, can be held liable under the NYSHRL for employment discrimination on the basis of plaintiff's criminal convictions. Based on the answers to the certified questions, the Second Circuit vacated the district court's grant of summary judgment and remanded for further proceedings. View "Griffin v. Sirva Inc." on Justia Law

Plaintiffs, employed as English teachers by defendants, filed suit on behalf of themselves and others similarly situated, alleging that defendants violated the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and New York Labor Law. Plaintiffs alleged that defendants failed to pay them both the statutory minimum wage for hours worked out of the classroom and statutory overtime when plaintiffs' classroom and out‐of‐classroom work exceeded 40 hours per week. The Second Circuit affirmed the district court's dismissal of the FLSA claims, holding that defendants were exempt from the FLSA's minimum wage and overtime requirements applicable to teachers working as bona fide professions because defendants were "educational establishments" under 29 C.F.R. 541.204(b). View "Fernandez v. Zoni Language Centers" on Justia Law

Pier Sixty challenged the determination that it violated Sections 8(a)(1) and 8(a)(3) of the National Labor Relations Act (NLRA), 29 U.S.C. 158(a)(1) and (3), by discharging an employee in retaliation for protected activity. The court held that Pier Sixty has not shown the existence of an "extraordinary circumstance" that requires the court to waive the ordinary rule against considering arguments not presented to the Board as required by 29 U.S.C. 160(e). Therefore, the court did not reach the merits of the challenge to Acting General Counsel Solomon's appointment. The court also affirmed the Board's determination that Pier Sixty violated Sections 8(a)(1) and 8(a)(3) by discharging Hernan Perez since Perez's conduct was not so "opprobrious" as to lose the protection of the NLRA. The court's decision rests heavily on the deference afforded to the Boards factual findings, made following a six‐day bench trial informed by the specific social and cultural context in this case. However, the court noted that Perez's conduct sits at the outer‐bounds of protected, union‐related comments. Accordingly, the court granted the Board's application for enforcement and denied Pier Sixty's cross-petition for review. View "NLRB v. Pier Sixty, LLC" on Justia Law

Plaintiff, a skydiver, filed suit against his former employer, Altitude Express, under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and New York law, alleging that he was terminated from his position as a skydiving instructor based on his sexual orientation. The district court found a triable issue of fact as to whether plaintiff faced discrimination because of his sexual orientation in violation of New York law, but otherwise granted summary judgment for the employer. Specifically, the district court held that defendants were entitled to summary judgment on plaintiff's Title VII claim because Second Circuit precedent holds that Title VII does not protect against discrimination based on sexual orientation. A jury found for defendants on the state-law claims. The court declined plaintiff's request that it reconsider its interpretation of Title VII in order to hold that Title VII's prohibition on discrimination based on "sex" encompasses discrimination based on "sexual orientation" because a three-judge panel lacks the power to overturn Circuit precedent. See Simonton v. Runyon. The court also concluded that plaintiff's assertions that he is entitled to a new trial on his state-law, sexual-orientation discrimination claim have no merit. The court rejected plaintiff's claims of evidentiary errors and unfair discovery practices, and defense counsel did not improperly influence the jury by appealing to prejudice of homosexuals. Accordingly, the court affirmed the judgment. View "Zarda v. Altitude Express" on Justia Law

Plaintiffs, black-car drivers in the greater New York City area, filed suit alleging that defendants, owners of black-car "base licenses" and affiliated entities, violated the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and the New York State Labor Law (NYLL), N.Y. Lab. Law 650 et seq. The district court conditionally certified the action and then granted summary judgment for defendants. The court agreed with the district court that plaintiffs constitute independent contractors for FLSA purposes as a matter of law. In this case, plaintiffs determined the manner and extent of their affiliation; whether to work exclusively for certain accounts or provide rides for rival accounts; the degree to which they would invest in their driving businesses; and when, where, and how regularly to provide rides for clients. Accordingly, the court affirmed the judgment. View "Saleem v. Corporate Transportation Group, Ltd." on Justia Law