Justia Labor & Employment Law Opinion Summaries

A registered nurse, who identified as a dark-skinned Salvadoran woman, was employed at an acute care hospital. After a night in which she took a prescribed opioid for shingles, she reported to work without notifying her supervisor of her medication use. On that day, two incidents occurred in which controlled opioids were improperly removed from the hospital’s secure medication dispensing system. Several coworkers observed that the nurse appeared disoriented, drowsy, and exhibited slurred speech. Following these observations and the missing medication, supervisors required her to undergo a fitness for duty exam and drug test, which was positive for opiates but later deemed explained by her prescription. The hospital conducted an internal investigation, reviewed security logs, and ultimately terminated her employment for suspected drug diversion, policy violations, and unsafe patient care.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of the hospital on all claims. The nurse had alleged discrimination and retaliation based on color and national origin under Title VII, disability discrimination and failure to accommodate under the ADA, interference and retaliation under the FMLA, and violations of the Illinois Human Rights Act. The district court found that no reasonable factfinder could conclude the hospital’s actions were unlawful.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s grant of summary judgment. The appellate court held that the nurse failed to establish a prima facie case of discrimination or retaliation under Title VII, as her conduct and observed behavior distinguished her from other employees. The court also found insufficient evidence to support her ADA, FMLA, and IHRA claims, concluding that the hospital’s actions were not shown to be motivated by unlawful animus or to have violated any statutory rights. The court affirmed the judgment in favor of the hospital on all claims. View "Lohmeier v Gottlieb Memorial Hospital" on Justia Law

Stella Paterakos, a white woman, worked as an Assistant Community Living Specialist for the City of Chicago. In 2020, after Crystal Warren, a black woman, became her supervisor, Paterakos was disciplined three times, resulting in suspensions of one, three, and five days. The cited reasons for discipline included violations of office policies, work assignments, and issues related to her use of Family and Medical Leave Act (FMLA) leave. Paterakos admitted to much of the conduct underlying the suspensions but alleged she was singled out for harsh treatment due to her race. She also claimed that her third suspension interfered with or retaliated against her for taking FMLA leave. Additionally, she was temporarily assigned to a different office, which she argued was racially motivated.After her third suspension, Paterakos filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging violations of Title VII of the Civil Rights Act, the Equal Protection Clause, the FMLA, and the Age Discrimination in Employment Act. The defendants moved for summary judgment. The district court granted summary judgment on all claims, finding no reasonable jury could conclude that the suspensions or the temporary assignment were motivated by race, age, or constituted unlawful FMLA interference or retaliation. Paterakos appealed, dropping her age discrimination claim but challenging the summary judgment on her Title VII, Equal Protection, and FMLA claims.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit affirmed the district court’s judgment, holding that no reasonable jury could find that the suspensions or assignment were based on race rather than documented performance issues. For the FMLA claims, the court held that the defendants’ honest belief that Paterakos was abusing her FMLA leave defeated her interference and retaliation claims. View "Paterakos v City of Chicago" on Justia Law

Alex Kedas worked for the Illinois Department of Transportation (IDOT) for over thirty years, primarily as a senior resident engineer. In 2016, Kedas complained to management and legal counsel that a female colleague was receiving better job assignments due to gender favoritism. After his complaint, Kedas received a counseling memorandum, a negative performance evaluation, and was denied a merit-based bonus. In subsequent years, he was assigned less significant projects and faced additional disciplinary actions. Kedas believed these actions were retaliatory and ultimately resigned in 2021, claiming constructive discharge due to an intolerable work environment.Kedas filed a lawsuit in the United States District Court for the Central District of Illinois, alleging retaliation under Title VII of the Civil Rights Act of 1964. The district court granted partial summary judgment for IDOT, finding that only certain actions—specifically, the counseling memorandum, the negative performance review, the denial of a bonus, and the 2018 job assignments—could be considered materially adverse employment actions. However, the court then found no sufficient evidence of a causal link between Kedas’s protected activity and his 2018 job assignments or constructive discharge. The remaining claims proceeded to trial, where the jury found IDOT had retaliated by issuing the counseling memorandum but awarded no damages.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment rulings de novo. The appellate court held that Kedas failed to present sufficient evidence to support claims of constructive discharge or a causal connection between his protected activity and the 2018 job assignments. The Seventh Circuit affirmed the district court’s judgment, concluding that no reasonable jury could find in Kedas’s favor on these issues. View "Kedas v Illinois Department of Transportation" on Justia Law

A customer service analyst at a large corporation alleged that her supervisors created a hostile work environment characterized by inappropriate behavior and a culture of “machismo.” She reported these concerns to human resources, including claims of increased workload without overtime approval and specific instances of inappropriate conduct. The company investigated, found low morale but no evidence of discrimination or harassment, and paid her owed overtime. After her complaints, the analyst received escalating warnings about her work performance, culminating in the lowest possible rating on her annual review. She was then given the choice between a performance improvement plan or resignation. Following an emotional reaction to this meeting, the company withdrew the improvement plan option and terminated her employment.She filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging gender discrimination and retaliation under Title VII, and age discrimination and retaliation under the Age Discrimination in Employment Act. The district court granted summary judgment in favor of the employer, finding insufficient evidence to support her claims.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo, considering whether a reasonable factfinder could conclude that her gender, age, or protected activity caused her termination. The court held that the plaintiff failed to identify similarly situated comparators who were treated more favorably, did not present evidence that her age was the “but for” cause of her termination, and could not establish a causal link between her complaints and adverse employment actions. The court found no evidence of pretext or retaliation and concluded that the record did not support her allegations. The Seventh Circuit affirmed the district court’s grant of summary judgment to the employer. View "Ontiveros v. Exxon Mobil Corporation" on Justia Law

Monica Richards, a long-time employee in her early fifties, applied for a promotion at Eli Lilly & Company after serving as an interim District Sales Manager. The promotion was instead awarded to a younger, less experienced candidate. Richards filed suit in federal court, alleging age discrimination under the Age Discrimination in Employment Act (ADEA) and Massachusetts law. She sought to proceed collectively on behalf of all Eli Lilly employees aged 40 or older who were denied promotions since February 2022, claiming a companywide bias favoring “Early Career Professionals” over older employees.In the United States District Court for the Southern District of Indiana, Richards moved for conditional certification of a collective action and requested that notice be sent to potential opt-in plaintiffs. The parties disputed the appropriate standard for issuing such notice. The district court applied the Lusardi “modest factual showing” standard, declined to consider the employer’s opposing evidence, and granted conditional certification, agreeing to send notice. Recognizing uncertainty in the law, the district court certified the question for interlocutory appeal under 28 U.S.C. § 1292(b).The United States Court of Appeals for the Seventh Circuit reviewed the case to clarify the standard for issuing notice in Fair Labor Standards Act (FLSA) and ADEA collective actions. The court held that, before notice may issue, plaintiffs must present evidence raising a material factual dispute as to whether the proposed collective is similarly situated. Both parties’ evidence must be considered, and the district court retains discretion to manage the process, including authorizing limited discovery or narrowing the scope of notice. The court rejected both the lenient Lusardi standard and heightened standards requiring proof by a preponderance of the evidence or a strong likelihood of similarity. The Seventh Circuit vacated the district court’s order and remanded for further proceedings under the clarified standard. View "Richards v. Eli Lilly & Company" on Justia Law

A high school in Indiana implemented a policy requiring teachers to address students by the first names listed in the school’s database, which, for transgender students, reflected their chosen names. A teacher objected to this policy on religious grounds, believing that using names inconsistent with students’ biological sex would violate his faith. The school initially accommodated him by allowing him to address all students by their last names only. After a year, complaints from students, parents, and staff led the school to rescind this accommodation, requiring the teacher to use students’ first names or face termination. The teacher resigned and later attempted to rescind his resignation, but the school treated it as final.The teacher sued the school corporation in the United States District Court for the Southern District of Indiana, alleging violations of Title VII for failure to accommodate his religion and for retaliation. The district court denied the teacher’s motion for summary judgment on the accommodation claim, finding a factual dispute about the sincerity of his religious beliefs. The court granted summary judgment to the school on both claims, concluding that accommodating the teacher imposed more than a de minimis cost due to student and staff complaints and potential Title IX liability. The court also found no evidence of pretext in the school’s stated reasons for its actions.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case in light of the Supreme Court’s decision in Groff v. DeJoy, which clarified that an employer must show a “substantial” burden to deny a religious accommodation under Title VII. The Seventh Circuit held that material factual disputes remained regarding whether the accommodation caused an undue hardship on the school’s mission or exposed it to legal liability. The court affirmed the denial of summary judgment on the sincerity issue, affirmed the decision not to revisit the retaliation claim, reversed the grant of summary judgment to the school on the accommodation claim, and remanded for further proceedings. View "Kluge v. Brownsburg Community School Corporation" on Justia Law

Richard Schneiter, a long-time employee of the Wisconsin Department of Corrections, was terminated after the Milwaukee Journal Sentinel reported that he had posted offensive memes on his private Facebook page. These posts were derogatory towards Muslims, blacks, liberals, and the LGBTQ community. The Department of Corrections initiated an investigation and concluded that Schneiter's posts created security concerns, diminished public trust, and questioned his ability to perform his duties without bias.The United States District Court for the Western District of Wisconsin granted summary judgment in favor of the defendants. The court applied the balancing test from Pickering v. Board of Education and determined that the Department's interests as a public employer outweighed Schneiter's free speech interests. The court also found that Schneiter had received adequate notice and an opportunity to be heard, thus dismissing his due process claim.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the lower court's decision. The appellate court held that the Department's interests in maintaining security, discipline, and public trust in its correctional facilities outweighed Schneiter's interest in posting the memes. The court emphasized the deference given to law enforcement and correctional agencies in assessing the disruptive nature of an employee's speech. Additionally, the court rejected Schneiter's due process claim, stating that public employers are not required to have specific social media policies before disciplining employees for social media activities that interfere with their job duties. Schneiter's argument of bias in the disciplinary process was also dismissed due to lack of evidence. View "Schneiter v. Carr" on Justia Law

Univar Solutions USA Inc. entered into a collective bargaining agreement (CBA) with Teamsters Local Union No. 283 in 2016, which required Univar to make pension contributions to a multiemployer pension fund. The CBA included an evergreen clause, automatically renewing the agreement annually unless either party provided notice of termination. In 2020, the parties extended the CBA by one year. Before the new expiration date, Univar sent a notice proposing modification or termination of the agreement and later entered a successor agreement allowing it to withdraw from the Fund and cease contributions. The Fund sued, claiming Univar's notice was too ambiguous to terminate the agreement.The United States District Court for the Northern District of Illinois ruled in favor of the Fund, finding that the 2020 extension did not prevent the CBA from automatically renewing under the evergreen clause. The court also found Univar's January 2021 letter insufficient to terminate the agreement, concluding that the CBA remained in effect through March 28, 2022. Consequently, the court granted summary judgment to the Fund, ordering Univar to pay the requested contributions and the Fund's legal fees.The United States Court of Appeals for the Seventh Circuit reviewed the case and disagreed with the district court's findings. The appellate court held that the 2020 extension did not nullify the evergreen clause and that Univar's January 2021 letter provided clear notice of its desire to terminate the CBA. The court concluded that Univar properly terminated the CBA before its expiration date, allowing it to cease contributions as per the successor agreement. The appellate court reversed the district court's summary judgment in favor of the Fund, vacated the award of attorneys' fees, and remanded the case. View "Central States Southeast and Southwest Areas Pensi v Univar Solutions USA Inc." on Justia Law

Christopher Pable, a software engineer with the Chicago Transit Authority (CTA), discovered a cybersecurity vulnerability in the BusTime system, which was developed by Clever Devices, Ltd. Pable reported the vulnerability to his supervisor, Mike Haynes, who tested it on another city's transit system. Clever Devices, which had a significant contract with the CTA, alerted the CTA about the incident, leading to the termination of Pable and Haynes. Pable then sued the CTA and Clever Devices under the National Transit Systems Security Act, alleging retaliation for whistleblowing.The United States District Court for the Northern District of Illinois dismissed Pable's complaint during the discovery phase, citing the deletion of evidence and misconduct by Pable's attorney, Timothy Duffy. The court also imposed monetary sanctions on both Pable and Duffy. The court found that Pable and Duffy had failed to preserve relevant electronically stored information (ESI) and had made misrepresentations during the discovery process.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court did not abuse its discretion in dismissing Pable's complaint under Federal Rule of Civil Procedure 37(e) due to the intentional spoliation of evidence. The court also upheld the monetary sanctions imposed under Rule 37(e), Rule 37(a)(5), and 28 U.S.C. § 1927, finding that Duffy's conduct unreasonably and vexatiously multiplied the proceedings. The appellate court declined to impose additional sanctions on appeal, concluding that the appeal was substantially justified. View "Christopher Pable v CTA" on Justia Law

Timothy Upchurch, a Black man, has worked at the Indiana Department of Correction’s Correctional Industrial Facility (CIF) for over thirty years. He filed discrimination and retaliation claims under Title VII against the State of Indiana, challenging his demotion from Correctional Lieutenant to Officer, subsequent written reprimands, a suspension, and non-promotions. The district court substituted the Indiana Department of Correction for the State of Indiana as the defendant and granted summary judgment to the Department.The United States District Court for the Southern District of Indiana found insufficient evidence of race discrimination or retaliation to support Upchurch's claims. Upchurch appealed, challenging the substitution of the Department for the State as the defendant and the summary judgment decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed with the district court that the Indiana Department of Correction was the proper defendant under Title VII, as it had actual hiring and firing responsibility. The court also reviewed the grant of summary judgment de novo, finding that the Department provided nondiscriminatory explanations for its actions, and Upchurch failed to show these explanations were pretextual. The court noted that Upchurch did not provide sufficient evidence to support his claims of race discrimination or retaliation, including failing to show that comparators were similarly situated or that the Department's actions were motivated by his race or complaints about discrimination.The Seventh Circuit affirmed the district court's judgment, concluding that no reasonable jury could find that race discrimination or retaliation motivated the adverse employment actions against Upchurch. View "Upchurch v. Indiana" on Justia Law