Justia Labor & Employment Law Opinion Summaries

A fast-casual restaurant chain hired an individual with arthritis in her knees for a cashier/service-team member position. Prior to starting, she requested to be allowed to sit for five minutes after every ten minutes of standing, due to her medical condition. The restaurant required employees in her role to multitask and maintain mobility throughout their shifts, handling various duties such as operating the register, restocking, cleaning, and serving customers. The employer concluded that her requested accommodation would prevent her from performing essential job functions and did not permit her to begin work until the accommodation issue was resolved.The United States District Court for the Eastern District of Kentucky reviewed the case after the employee sued under the Americans with Disabilities Act (ADA) and the Kentucky Civil Rights Act (KCRA), alleging failure to accommodate her disability and failure to engage in the interactive process. The district court granted summary judgment to the employer, holding that the requested accommodation was not reasonable as a matter of law, and that her claim regarding the interactive process could not proceed without a viable accommodation claim.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court affirmed, holding that the employee’s proposed accommodation—sitting for five minutes after every ten minutes of standing—was not objectively reasonable because it would fundamentally alter essential functions of the cashier/service-team member position, which required continuous mobility and multitasking. The court further held that, because no reasonable accommodation was shown, the claim arising from the employer’s alleged failure to engage in the interactive process also failed as a matter of law. The judgment of the district court was therefore affirmed. View "Bowles v. SSRG II, LLC" on Justia Law

Two individuals worked as delivery drivers for a transportation company for over a decade, primarily out of the company’s New Jersey terminal. Their work mainly involved picking up and delivering goods in New Jersey, with occasional deliveries in neighboring states. Each driver had a contract with the company that included a forum-selection clause requiring any disputes to be litigated in Memphis, Tennessee, and a choice-of-law clause providing that Tennessee law would govern any disputes. The company is incorporated in Delaware, headquartered in Illinois, and has operations nationwide, including in Tennessee, but neither the drivers nor the company’s relevant activities were based in Tennessee.The drivers filed a putative class action in the United States District Court for the District of New Jersey, alleging that the company violated New Jersey wage laws by withholding earnings and failing to pay overtime, among other claims. The case was transferred to the United States District Court for the Western District of Tennessee pursuant to the forum-selection clause. The company then moved to dismiss the complaint, arguing that the Tennessee choice-of-law provision applied and that Tennessee law did not recognize the claims brought under New Jersey statutes. The district court agreed, upheld the choice-of-law provision, and dismissed the case.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the enforceability of the choice-of-law provision under Tennessee’s choice-of-law rules. The court held that the contractual choice-of-law clause was unenforceable because there was no material connection between Tennessee and the transactions or parties. As a result, the Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. The court did not reach the question of whether Tennessee law was contrary to the fundamental policies of New Jersey. View "Andujar v. Hub Group Trucking, Inc." on Justia Law

An individual received health insurance through his employer, with the plan administered by a third-party insurer. After being injured in a car accident, he recovered damages from the other driver’s employer and, based on communications from his insurer and its agent, paid $25,000 in reimbursement to the plan. He later learned that the full plan document did not contain a reimbursement obligation, contrary to what was represented in the summary plan description. A similar situation occurred when his wife was injured in a separate accident; litigation in state court ultimately resulted in a declaratory judgment that the plan did not provide for reimbursement, and this was affirmed on appeal.The individual then sued the insurer, its agent, and his employer in federal court under the Employee Retirement Income Security Act of 1974 (ERISA), alleging he was defrauded into paying reimbursement. The United States District Court for the Northern District of Ohio dismissed most claims, but allowed one ERISA claim under § 1132(a)(3) to proceed. While his federal appeal was pending, the plaintiff filed state law claims in state court, which were removed to federal court. The district court held that these state law claims were completely preempted by ERISA and dismissed the action, reasoning that the claims were duplicative of the pending federal lawsuit and arose from the same events.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiff’s state law claims were completely preempted by ERISA under the standard articulated in Aetna Health Inc. v. Davila, because the claims sought relief for benefits allegedly due under the terms of an ERISA-governed plan and did not rely on a legal duty independent of ERISA or the plan. The court further concluded that dismissal, rather than remand or amendment, was appropriate due to the duplicative nature of the proceedings. View "Patterson v. UnitedHealth Group, Inc." on Justia Law

An employee at a nuclear power plant operated by a subsidiary corporation left active work due to a medical condition but remained employed while on short-term disability. After the employee transitioned to long-term disability, the employer terminated his employment. The union, representing the plant’s workers, filed a grievance on the employee’s behalf, arguing that the collective bargaining agreement (CBA) required continued employment and benefits. The union initiated arbitration against the employer but mistakenly named the employer’s parent company as the respondent. Despite the error, counsel for the correct employer participated in the arbitration, and all parties consistently identified the subsidiary as the actual employer during the proceedings.After the arbitrator issued an award in favor of the union—ordering reinstatement and benefits for the employee—the employer did not comply. Instead, the parent and subsidiary together filed suit in the United States District Court for the Western District of Michigan, seeking to vacate the award due to the mistaken caption. The union counterclaimed for confirmation of the award. The district court ruled for the union, finding extensive evidence that the subsidiary had engaged in and intended to be bound by the arbitration, and that the erroneous caption was merely a procedural defect to which the employer had waived any objection by participating fully and not raising a timely challenge.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that when an arbitration demand and award misname the party against whom the award is meant to be entered, but there is no ambiguity about the real party, a federal court may enforce the award. The court further held that any objection to the misnomer was waived by the employer’s participation and failure to object, and that the error was a curable misnomer not warranting vacatur or modification of the award. View "Holtec International Corp. v. Michigan State Utility Workers Council" on Justia Law

A former employee of a county health department brought suit under the Americans with Disabilities Act (ADA), alleging that her employer discriminated against her based on her night blindness, retaliated against her for requesting an accommodation, and failed to accommodate her asthma. She had been promoted to a position requiring some nighttime driving, which became increasingly difficult due to her night blindness. Later, she was reassigned to a shift that required her to work alone at night at a location she considered unsafe, and she raised concerns about both her vision and personal safety. She also experienced a severe asthma flare-up when she temporarily lost access to her medication, which affected her ability to work.The United States District Court for the Western District of Tennessee dismissed her constitutional claims but allowed her ADA claims to proceed to trial. At trial, the jury found in her favor on all three ADA claims: failure to accommodate her asthma, discrimination based on her night blindness, and retaliation for requesting an accommodation. The county moved for judgment as a matter of law at several points, arguing that her conditions did not qualify as disabilities under the ADA and that the evidence was insufficient, but the district court denied these motions.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of judgment as a matter of law de novo, considering the evidence in the light most favorable to the plaintiff. The appellate court held that the jury reasonably found that both night blindness and asthma could qualify as disabilities under the ADA, given the broad and individualized inquiry required by the statute and its amendments. The court also found sufficient evidence to support the jury’s findings of discrimination, retaliation, and failure to accommodate. Accordingly, the Sixth Circuit affirmed the district court’s judgment in favor of the plaintiff on all ADA claims. View "Edwards v. Shelby Cnty., Tenn." on Justia Law

A shift supervisor at a coffee shop in Ann Arbor, Michigan, led efforts to organize a union at her workplace. She was a prominent organizer, engaging in various activities such as wearing union buttons, speaking to customers about unionization, and attending a labor board hearing. Several months into the campaign, she was terminated by her employer, who cited her violation of a company policy requiring at least two employees to be present in the café. The supervisor had left a barista alone at the store at the end of her shift without notifying management, which the company claimed was the reason for her discharge.After her termination, Workers United filed unfair labor practice charges with the National Labor Relations Board (NLRB), alleging that the discharge was motivated by anti-union animus. An Administrative Law Judge found in favor of the union, concluding that the employer’s stated reason was pretextual and that the discharge was unlawfully motivated. The NLRB affirmed the ALJ’s decision and expanded the remedy, ordering the employer to compensate the supervisor not only for lost earnings and benefits but also for any “direct or foreseeable pecuniary harms” resulting from the discrimination.The United States Court of Appeals for the Sixth Circuit reviewed the case on the NLRB’s application for enforcement of its order. The court held that substantial evidence supported the NLRB’s finding that the supervisor’s discharge was motivated by anti-union animus and thus constituted an unfair labor practice. However, the court determined that the NLRB exceeded its statutory authority under the National Labor Relations Act by awarding compensation for “direct or foreseeable pecuniary harms” beyond lost earnings and benefits. The court granted enforcement of the unfair labor practice finding but vacated the expanded remedy and remanded for further proceedings. View "National Labor Relations Board v. Starbucks Corp." on Justia Law

A nonprofit organization in Detroit, which provides educational and family services to at-risk youth, employed the plaintiff as a full-time case manager after she had previously worked as an independent contractor. The plaintiff’s responsibilities included monitoring students and managing case files, a task that required onsite work due to funding and audit requirements from a key county contract. After a building flood, the plaintiff raised health concerns about mold exposure and requested to work remotely, providing doctor’s notes that did not explicitly require remote work. The employer accommodated her request temporarily by shifting her to part-time remote work, but emphasized that onsite file management was essential. The plaintiff later returned to full-time onsite work. Over the following year, she filed several complaints with state agencies regarding workplace safety, pay, and reimbursement issues. During the COVID-19 pandemic, the organization faced financial difficulties, leading to a restructuring that offered the plaintiff a choice between an independent contractor role with reduced hours and benefits or a severance package. She declined both, ending her employment.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the employer on all claims, finding insufficient evidence to support the plaintiff’s allegations of discrimination, retaliation, failure to accommodate, and wrongful termination. The court determined that the plaintiff could not perform essential job functions remotely and that the employer’s actions were based on legitimate business reasons.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the plaintiff failed to present evidence of a hostile work environment, disability-based discrimination, or retaliation under federal and state law. The court also found that the employer’s restructuring and accommodation decisions were not pretextual and that the plaintiff’s wrongful termination claim was inadequately developed and unsupported by the record. View "Kellar v. The Yunion, Inc." on Justia Law

A former correctional officer with the Michigan Department of Corrections was terminated after a coworker accused him of making harassing and inappropriate comments. The officer, after being served with a misconduct charge and attending a disciplinary conference with his union representative, was formally terminated in July 2019. He challenged his termination through arbitration, which concluded in December 2020 with a decision upholding his dismissal. Nearly three years later, he filed a federal lawsuit against two department officials, alleging violations of his constitutional rights under 42 U.S.C. § 1983, specifically focusing on procedural due process.The United States District Court for the Western District of Michigan initially dismissed the officer’s first complaint without prejudice for lack of prosecution after he failed to respond to a motion to dismiss. When he refiled a similar complaint, the district court dismissed it again, this time on the grounds that the claim was untimely under Michigan’s three-year statute of limitations for personal injury actions and that, except for his procedural due process claim, he had forfeited his other constitutional arguments. The court also found that his procedural due process claim failed to state a claim upon which relief could be granted.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the dismissal de novo. The court held that the officer’s procedural due process claim accrued, at the latest, on the date of his post-termination arbitration hearing in December 2020, making his June 2024 complaint untimely. The court further held that Michigan law does not permit equitable tolling of the statute of limitations in this context and that the officer failed to plausibly allege inadequate process either before or after his termination. The Sixth Circuit affirmed the district court’s dismissal. View "Bozzo v. Nanasy" on Justia Law

A married couple, both employees of UT-Battelle, objected to their employer’s COVID-19 vaccine mandate on religious grounds, specifically because of their belief that the vaccines’ development involved the use of fetal cell lines from abortions, which conflicted with their Christian faith. UT-Battelle required employees seeking religious exemptions to undergo a panel interview and read a “fact sheet” presenting religious leaders’ support for vaccination. Employees granted religious accommodations were placed on unpaid leave, while those with medical accommodations were not. Mrs. Bilyeu ultimately received a medical exemption before the policy took effect and did not lose pay or work time. Mr. Bilyeu, however, was placed on unpaid leave after exhausting his vacation days, returning to work only after the policy was rescinded.The United States District Court for the Eastern District of Tennessee granted summary judgment to UT-Battelle on all claims except Mrs. Bilyeu’s retaliation claim, which was later settled. The court found that Mrs. Bilyeu lacked standing and that Mr. Bilyeu had not suffered a materially adverse employment action under Title VII.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment as to Mrs. Bilyeu, holding she lacked Article III standing because she suffered no cognizable injury after receiving her medical accommodation. For Mr. Bilyeu, the Sixth Circuit vacated the summary judgment on his disparate treatment and failure-to-accommodate claims, instructing the district court to reconsider them in light of the Supreme Court’s decision in Muldrow v. City of St. Louis, which eliminated the “materially adverse” requirement for adverse employment actions under Title VII. The court reversed the summary judgment on Mr. Bilyeu’s retaliation claim, finding sufficient evidence for a reasonable jury to conclude that the interview process could dissuade a reasonable worker from seeking a religious accommodation, and remanded for further proceedings. View "Bilyeu v. UT-Battelle, LLC" on Justia Law

Two African American truck drivers employed by a large transportation company in Nashville alleged that their supervisors subjected them to a racially hostile work environment. The plaintiffs claimed they were assigned longer routes and more hours than their non-African American colleagues for the same pay, denied certain benefits, and given older or more damaged trucks. They also testified that their supervisors, one of whom was also African American, repeatedly called them “monkey” and “monkey ass,” used demeaning language, and threatened or criticized them in ways not directed at white coworkers. The plaintiffs reported this conduct to company liaisons and managers, but the alleged harassment continued. One plaintiff resigned due to the conditions, while the other was terminated for alleged performance issues, which he disputed.The United States District Court for the Middle District of Tennessee granted summary judgment to the employer, finding that the plaintiffs had not provided sufficient evidence of race-based harassment to support a hostile work environment claim. The court reasoned that the terms used by the supervisors were not inherently racist, that the plaintiffs had not shown the terms were used only against African Americans, and that the plaintiffs’ comparative evidence was insufficient because it did not establish the race of the relevant comparators with the required specificity.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the grant of summary judgment de novo. The appellate court held that the plaintiffs’ testimony regarding the use of “monkey” and “monkey ass” by supervisors constituted evidence of race-based harassment, given the well-established history of those terms as racial slurs against African Americans. The court also found that the plaintiffs’ comparative and other evidence was admissible and sufficient to raise genuine issues of material fact regarding the severity and pervasiveness of the harassment and the employer’s liability. The Sixth Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Smith v. P.A.M. Transport, Inc." on Justia Law