Justia Labor & Employment Law Opinion Summaries

J.H. participated in an employee welfare-benefit plan insured by Anthem Blue Cross Life and Health Insurance Company, with her son, A.H., as a beneficiary. After seeking benefits for A.H.'s yearlong stay at a mental-health treatment center, Anthem denied coverage, and Plaintiffs' appeal to Anthem was unsuccessful. Over a year after their final appeal through Anthem was decided, Plaintiffs filed a lawsuit to recover benefits under § 502(a)(1)(B) of the Employee Retirement Income Security Act of 1974 (ERISA).The United States District Court for the District of Utah dismissed the action, concluding it was time-barred under a provision of the Plan that required civil actions under ERISA § 502(a) to be brought within one year of the grievance or appeal decision. Plaintiffs argued that another sentence in the Plan set a three-year limitations period, creating an ambiguity that should be interpreted in their favor.The United States Court of Appeals for the Tenth Circuit reviewed the case and held that the two provisions were not inconsistent and both applied. The court explained that the one-year limitations period for § 502(a) actions and the three-year limitations period for other actions were distinct and could both be applicable. The court affirmed the district court's dismissal, concluding that Plaintiffs' action was time-barred as it was filed beyond the one-year limitations period specified in the Plan. View "J.H. v. Anthem Blue Cross Life and Health Insurance" on Justia Law

The case involves two Utah corporations, 3484, Inc. and 3486, Inc., created by film producer David Wulf to produce Hallmark movies. The companies shared personnel, including Jennifer Ricci and Brett Miller, who were responsible for various production roles. In April 2021, drivers employed by 3484 contacted a union representative to discuss organizing. Ricci questioned driver April Hanson about union activity and asked her to keep the conversation confidential. Later, Miller warned driver Roy Brewer that production would move to Canada if the drivers organized. The drivers went on strike, and after the strike, 3486 refused to reinstate them, alleging misconduct.The National Labor Relations Board (NLRB) found that the Employers committed unfair labor practices, including unlawful interrogation and threats, and ordered remedies. The Employers argued that the Board's findings were not supported by substantial evidence and that the Board's procedures and remedies were unauthorized or violated their constitutional rights. The Employers filed a petition for review, and the NLRB filed a cross-application for enforcement of its order.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court held that substantial evidence supported the Board's findings, except for the finding that 3484 unlawfully interrogated Hanson. The court also held that it lacked jurisdiction to consider the Employers' constitutional challenges and 3486's challenge to the Board's statutory authority because these arguments were not preserved for appellate review. The court granted the Board's cross-application for enforcement, except for the finding related to Hanson's interrogation, and remanded the case for further proceedings consistent with its opinion. View "3484, Inc. v. National Labor Relations Board" on Justia Law

Loretta Mauldin, an employee at the McAlester Army Ammunition Plant (MCAAP) since 1991, filed a lawsuit against the Secretary of the United States Department of the Army. Mauldin, who was born in 1958, claimed retaliation and discrimination based on age under the Age Discrimination in Employment Act (ADEA) and sex discrimination under Title VII of the Civil Rights Act. The case arose after Mauldin was not selected for a promotion to a Grade 9 Explosives Operator Supervisor position in 2018. She alleged that her non-selection was due to her age, sex, and prior Equal Employment Opportunity (EEO) activity, including supporting a co-worker's age discrimination complaint.The United States District Court for the Eastern District of Oklahoma granted summary judgment in favor of the Army, dismissing Mauldin's claims. The court found that Mauldin failed to establish a prima facie case of retaliation and discrimination. It concluded that the Army provided legitimate, nondiscriminatory reasons for selecting another candidate, Scott Harkey, who performed better in the interview process. The court also determined that Mauldin did not provide sufficient evidence to show that the Army's reasons were pretextual.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court correctly considered the Army's evidence, including testimony from the interview panelists and Mauldin's supervisor, Buckner. The court found that Mauldin did not demonstrate a genuine issue of material fact regarding pretext. The court emphasized that the interview process was neutral and that Mauldin's lower interview scores were a legitimate reason for her non-selection. Consequently, the Tenth Circuit upheld the summary judgment in favor of the Army, concluding that Mauldin's claims of retaliation and discrimination were not supported by sufficient evidence. View "Mauldin v. Wormuth" on Justia Law

Kenya Watkins, a Black woman, was employed by Genesh, Inc., d/b/a Burger King, from August 2014 to August 2015. She alleged that her manager verbally, physically, and sexually harassed her, including forcing her into a freezer, groping her, simulating sex with her, and stating she would not be promoted unless she had sex with him. Watkins filed an employment discrimination charge with the Kansas Human Rights Commission and the EEOC in early 2016. In December 2018, she alleged that Genesh admonished her then-employer, Church’s Chicken, for hiring her, leading to a second EEOC charge in 2019.In August 2019, Watkins sued Genesh in the United States District Court for the District of Kansas under 42 U.S.C. § 1981 for race discrimination. The district court dismissed her complaint, finding her allegations did not plausibly support racial harassment. The court noted that Watkins had pending EEOC charges and could file her Title VII claims once the EEOC proceedings concluded. In July 2021, the EEOC issued a right-to-sue letter for her 2019 charge, which Watkins did not pursue. In April 2022, the EEOC issued a right-to-sue letter for her 2016 charge, leading Watkins to file a second lawsuit in July 2022, raising claims under Title VII and other statutes.The United States District Court for the District of Kansas dismissed Watkins’s 2022 complaint as untimely. On appeal, the United States Court of Appeals for the Tenth Circuit affirmed the dismissal on claim preclusion grounds. The court held that Watkins’s Title VII claims were precluded by the final judgment in her 2019 lawsuit, as both suits arose from the same employment relationship. The court reaffirmed that the absence of a right-to-sue letter did not deprive Watkins of a full and fair opportunity to litigate her Title VII claims in the initial suit. View "Watkins v. Genesh" on Justia Law

Larry Lawson, former CEO of Spirit AeroSystems, Inc., retired and entered into a Retirement Agreement with Spirit, which allowed him to continue vesting in long-term incentive stock awards as if he were an active employee. This agreement was conditioned on his compliance with a non-competition covenant from his original Employment Agreement. Lawson later engaged with a hedge fund, Elliott Management, which was involved in a proxy contest with Arconic, a competitor of Spirit. Spirit deemed this a violation of the non-competition covenant and ceased payments and stock vesting under the Retirement Agreement.The United States District Court for the District of Kansas held a bench trial and found that Lawson had not violated the non-competition covenant, ruling in his favor. Spirit appealed, and the Tenth Circuit reversed, holding that Lawson had breached the covenant and remanded the case to determine the enforceability of the covenant under Kansas law.On remand, the district court found the non-competition covenant enforceable without applying the reasonableness test from Weber v. Tillman, concluding that the covenant was a condition precedent to the receipt of future benefits, not a traditional non-compete. The court severed the injunctive enforcement mechanism from the covenant, leaving only the condition precedent.The United States Court of Appeals for the Tenth Circuit affirmed the district court's judgment, predicting that the Kansas Supreme Court would not apply the Weber reasonableness test to a non-competition condition precedent to the receipt of future benefits. The court also denied Lawson's motion to certify the question to the Kansas Supreme Court, finding it unnecessary to resolve the issue. View "Lawson v. Spirit Aerosystems" on Justia Law

Stacie Culp and Stephanie Peters, both servers at Remington of Montrose Golf Club, LLC, alleged they were sexually harassed by bartender Jason DeSalvo. They filed claims under Title VII of the Civil Rights Act of 1964 and the Colorado Anti-Discrimination Act (CADA) for sexual harassment and retaliation. Remington's management conducted a limited investigation, resulting in DeSalvo's suspension and demotion. Culp claimed her hours were reduced in retaliation, leading to her resignation. Peters alleged inadequate investigation and retaliation, including being scheduled to work with DeSalvo post-suspension, leading to her departure.The United States District Court for the District of Colorado granted summary judgment for Remington on Peters's retaliation claim but allowed other claims to proceed to trial. The jury found against Peters on her remaining claims and returned inconsistent special verdicts on Culp's claims, awarding her punitive damages under Title VII despite finding no violation of her rights.The United States Court of Appeals for the Tenth Circuit affirmed the district court's summary judgment on Peters's retaliation claim, holding that neither the inadequate investigation nor the scheduling with DeSalvo constituted materially adverse actions. However, the court found the jury's verdict on Culp's claims irreconcilably inconsistent and vacated the verdict, remanding for a new trial on her harassment and retaliation claims. The court upheld the district court's evidentiary rulings, noting that objections to the admission of certain evidence were not properly preserved for appeal. View "Culp v. Remington of Montrose Golf Club" on Justia Law

HollyFrontier Cheyenne Refining, LLC transitioned a petroleum refinery into a renewable diesel production facility in 2021. During this transition, HollyFrontier reassigned work from hourly workers to salaried employees with higher education and technical expertise. The United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union Local 11-574 filed a grievance, alleging that this reassignment violated their collective bargaining agreement (CBA). An arbitrator ruled in favor of HollyFrontier on the reassignment issue but also decided that salaried employees should be included in the bargaining unit, an issue not submitted for arbitration.The United States District Court for the District of Wyoming reviewed the case and granted HollyFrontier's petition to vacate the arbitrator's decision regarding the inclusion of salaried employees in the bargaining unit. The court reasoned that the arbitrator exceeded his authority by deciding an issue that was not submitted for arbitration.The United States Court of Appeals for the Tenth Circuit reviewed the district court's decision. The Tenth Circuit affirmed the district court's vacatur of the arbitration award. The court held that the arbitrator exceeded his authority by addressing an issue not submitted for arbitration. The parties had only submitted the issue of whether HollyFrontier's reassignment of work violated the CBA, and the arbitrator's decision to include salaried employees in the bargaining unit was beyond the scope of the submitted issue. The court emphasized that arbitration is limited to the issues the parties agree to submit, and the arbitrator must stay within those bounds. View "HollyFrontier Cheyenne Refining, LLC v. United Steel Paper" on Justia Law

Marci Walkingstick Dixon, a Native American woman and member of the Cherokee Nation, worked at Northeastern State University (NSU) in the Information Technology Services Department. After being supervised by Dr. Richard Reif, she reported experiencing discriminatory comments and actions based on her race and sex. Following her complaint to NSU's Title IX officer, she faced increased hostility from Dr. Reif. In 2018, after a dispute over compensatory time and subsequent reprimand, she formally complained about a hostile work environment. NSU then began characterizing her time report as falsified and eventually terminated her employment, citing poor job performance and improper timekeeping.The United States District Court for the Eastern District of Oklahoma granted summary judgment in favor of NSU and Dr. Reif on Dixon's claims of Title VII sex and race discrimination, Title VII retaliation, and FMLA retaliation. The court found that Dixon failed to establish a prima facie case of discrimination or retaliation and could not show that NSU's reasons for her termination were pretextual. The court also concluded that Dr. Reif was not Dixon's employer under the FMLA.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court reversed the district court's summary judgment on Dixon's Title VII sex and race discrimination claims and her Title VII retaliation claim, finding that she had established a prima facie case and presented sufficient evidence of pretext. However, the court affirmed the summary judgment in favor of Dr. Reif on the FMLA retaliation claim, agreeing with the lower court's application of the economic reality test to determine that Dr. Reif was not Dixon's employer under the FMLA. View "Dixon v. Regional University System of the Oklahoma Board" on Justia Law

Morris Blackburn worked as a coal miner for twenty years, exposed to dust in an Energy West coal mine. He also smoked cigarettes, and eventually developed a respiratory disease. Based on this disease, Blackburn claimed benefits under the Black Lung Benefits Act. Energy West challenged the award of benefits, arguing Blackburn caused his disease by smoking cigarettes. The Department of Labor’s Benefits Review Board affirmed an award of compensation, and Energy West appealed. The Tenth Circuit found no reversible error in the award of benefits, and affirmed. View "Energy West v. Blackburn" on Justia Law

Plaintiff-Appellant Bryan “Shane” Jones appealed the dismissal of his Title VII sex discrimination claim against Defendant-Appellee Needham Trucking, LLC and his state law tort claim for wrongful interference with a contractual relationship against Defendant-Appellee Julie Needham. Jones completed an intake questionnaire with the EEOC. In response to questions seeking more detailed explanations, Jones wrote “[s]ee attached.” The attachment never made it to the EEOC, nor did the EEOC alert Jones that it was missing. Nevertheless, the EEOC prepared a charge form on his behalf, and issued a right-to-sue letter. Jones then filed his lawsuit, alleging sexual harassment, negligence, negligent or intentional infliction of emotional distress, wrongful interference with a contractual or business relationship, and violation of the Oklahoma Employment Security Act of 1980 (“OESA”). The district court held that Jones failed to exhaust his administrative remedies for his quid pro quo sexual harassment claim, that his state law tort claim was precluded by the Oklahoma Anti-Discrimination Act (“OADA”), and that his OESA claim failed for want of a private right of action. Needham Trucking argued that the facts alleged were insufficient to put it on notice of the quid pro quo harassment claim made in Jones’s amended complaint because the facts from the attachment were not reflected in the EEOC charge form or right-to-sue letter. The Tenth Circuit concluded that though the complaint Jones filed was more detailed than his charge form, the form only needed to “describe generally” the alleged discrimination. The Tenth Circuit reversed the district court with respect to the discrimination claim, but affirmed on the state law tort claims. View "Jones v. Needham" on Justia Law