Justia Labor & Employment Law Opinion Summaries

This putative class action was brought by Sandra Babcock, a corrections officer at the Butler County Prison in Butler, Pennsylvania. Babcock claimed that Butler County failed to properly compensate her and those similarly situated for overtime in violation of the Fair Labor Standards Act (“FLSA”). At issue in this appeal was whether a portion of time for the Butler County Prison corrections officers’ meal periods was compensable under the FLSA. The Third Circuit concluded there was no provision of the FLSA that directly addressed this issue. Two tests were suggested by other courts of appeal: one looked to whether the employee had been relieved from all duties during the mealtime; the other (more generally adopted) looked to the party to which the “predominant benefit” of the mealtime belongs. The District Court noted that the Third Circuit had not yet established a test to determine whether a meal period is compensable under the FLSA. After its review of this case, the Court adopted the “predominant benefit test” and affirmed the District Court. View "Babcock v. Butler County" on Justia Law

Appellant Matthew Faush was an employee of a temporary staffing agency. He was assigned to Tuesday Morning, Inc., where he claimed he was subjected to slurs and accusations based on his race. Ultimately he was terminated. Appellant filed suit against Tuesday Morning, claiming violations of Title VII of the Pennsylvania Human Relations Act. The district court granted summary judgment to Tuesday Morning on the ground that because appellant was not Tuesday Morning’s employee, Tuesday Morning was not liable for employment discrimination. The Third Circuit reversed, finding that a rational jury, applying the factors announced by the Supreme Court in “Nationwide Mutual Insurance Co. v. Darden,” could have found on these facts that appellant was Tuesday Morning’s employee for purposes of Title VII and the Human Relations Act. The case was remanded for further proceedings. View "Faush v. Tuesday Morning, Inc." on Justia Law