Justia Labor & Employment Law Opinion Summaries

Allan Sanders, a foreman general at Union Pacific Railroad Company, sued his employer under the Americans with Disabilities Act (ADA). Sanders claimed that Union Pacific discriminated against him by imposing work limitations due to perceived cardiovascular health issues and by failing to provide a reasonable accommodation during a cardiovascular test. Sanders had suffered a brief cardiac arrest due to complications from a bleeding ulcer but had fully recovered. Union Pacific required him to undergo a fitness-for-duty evaluation, including a treadmill test, which he could not complete due to knee pain from osteoarthritis. Sanders requested an alternative test on a bicycle, which Union Pacific denied, leading to work restrictions that prevented him from returning to his job.The United States District Court for the District of Nebraska denied Union Pacific’s renewed motion for judgment as a matter of law after a jury found in favor of Sanders on both claims and awarded him damages. Union Pacific appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that there was sufficient evidence for a reasonable jury to conclude that Union Pacific regarded Sanders as disabled due to perceived cardiovascular issues and that Sanders was qualified to perform his job. The court also found that Union Pacific’s refusal to allow an alternative test constituted a failure to provide reasonable accommodation. The court rejected Union Pacific’s “direct threat” defense, concluding that the company’s decision was not objectively reasonable or based on the best available evidence. The appellate court upheld the jury’s verdict on both the disparate treatment and failure-to-accommodate claims. View "Sanders v. Union Pacific Railroad Co." on Justia Law

Enright Seeding, Inc. is involved in a dispute with the International Union of Operating Engineers, Local 150, AFL-CIO, regarding the nature of their collective bargaining agreement. Enright Seeding, a construction industry subcontractor, signed a bargaining agreement with the union in 2007, which included language suggesting it was a § 9(a) agreement under the National Labor Relations Act, indicating majority employee support for the union. The company later claimed that its obligations ended when it repudiated the contract in 2016. The union, however, argued that the agreement was a § 9(a) agreement and that the company violated the Act by not providing requested information.An administrative law judge determined that the agreement was a § 9(a) agreement and that Enright Seeding violated Sections 8(a)(1) and (5) of the Act by failing to provide the requested information. The judge also concluded that even if the agreement was under § 8(f), the company did not clearly repudiate it. A three-member panel of the National Labor Relations Board (NLRB) affirmed this decision, focusing on the § 9(a) status and not addressing the repudiation issue.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the NLRB's decision was not supported by substantial evidence, as there was no actual evidence of majority employee support for the union in 2007, only boilerplate contract language. The court emphasized that all evidence must be considered to determine the status of the relationship, and mere contract language is insufficient. The court also rejected the argument that Enright Seeding was barred from disputing the agreement's status due to the six-month limitation period in § 10(b) of the Act.The Eighth Circuit vacated the NLRB's order and remanded the case for further proceedings, without expressing a view on whether Enright Seeding had effectively repudiated the agreement or whether the union was entitled to the requested information under a § 8(f) agreement. View "NLRB v. Enright Seeding, Inc." on Justia Law

Michelle Collins, a black woman, worked at Union Pacific Railroad Company for 42 years, holding over twenty positions. She alleged that several managers discriminated against her based on race, including assigning her unpleasant tasks and increasing her workload. Collins also reported conflicts with a coworker, Rhonda VanLew, who allegedly made her job more difficult. In 2020, Collins filed an internal complaint about VanLew, and VanLew also filed a complaint against Collins. A Union Pacific analyst concluded that the conflict was appropriately resolved by local management.The United States District Court for the Western District of Missouri granted summary judgment in favor of Union Pacific. The court found that Collins could not establish a prima facie case of race discrimination or retaliation because she did not suffer an adverse employment action. Additionally, the court ruled that Collins's hostile work environment claim failed as she could not prove severe or pervasive harassment based on her race.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the summary judgment on the hostile work environment claim, agreeing that Collins did not sufficiently oppose the summary judgment on this ground in the lower court. However, the court reversed and remanded the discrimination and retaliation claims. The appellate court noted that the district court's analysis relied on outdated legal standards requiring a "materially significant disadvantage," which the Supreme Court had recently clarified was not necessary. The case was sent back to the district court to reconsider these claims under the correct legal framework. View "Collins v. Union Pacific Railroad Co." on Justia Law

Clyde O. Carter, Jr. filed a complaint under the Federal Rail Safety Act (FRSA) against BNSF Railway Company, alleging retaliation for reporting a work-related injury. Carter claimed that BNSF initiated disciplinary investigations and terminated him due to his injury report. Initially, an administrative law judge (ALJ) found in favor of Carter, and the Administrative Review Board (ARB) affirmed. However, the United States Court of Appeals for the Eighth Circuit vacated the ARB’s order and remanded the case for further proceedings.The Occupational Safety and Health Administration initially found no FRSA violation by BNSF. After Carter objected, the case was transferred to an ALJ, who ruled in Carter’s favor. The ARB affirmed, but the Eighth Circuit vacated this decision, citing errors in the ALJ’s causation theory and lack of substantial evidence supporting the ARB’s findings. On remand, a different ALJ found that Carter’s injury report was not a contributing factor in BNSF’s decisions to investigate and terminate him, attributing the actions to Carter’s dishonesty. The ARB affirmed this decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and denied Carter’s petition for review. The court held that substantial evidence supported the ALJ’s findings that Carter’s injury report did not contribute to BNSF’s decision to terminate him. The court also found no procedural errors in the ALJ’s handling of the case on remand. Consequently, the court concluded that Carter failed to prove that his injury report was a contributing factor in his termination, and thus, BNSF was not liable under the FRSA. The petition for review was denied. View "Carter v. Secretary, Department of Labor" on Justia Law

Nycoca Hairston, an employee at the United States Army’s Pine Bluff Arsenal, alleged that her immediate supervisor sexually harassed her and that she was unlawfully terminated in retaliation for her complaints. Hairston sued the Secretary of the Army under Title VII of the Civil Rights Act of 1964. After a jury trial on her retaliation claim, the Army prevailed. Hairston appealed the district court’s denial of her post-trial motions and its decision to limit the testimony of one of her witnesses.The United States District Court for the Eastern District of Arkansas initially granted summary judgment in favor of the Army on both Hairston’s hostile work environment and retaliation claims. Hairston appealed, and the Eighth Circuit affirmed the summary judgment on the hostile work environment claim but reversed it on the retaliation claim, remanding it for trial. After the jury ruled in favor of the Army, Hairston filed a Motion for New Trial and a Motion to Alter or Amend Judgment, which the district court denied. Hairston then filed an appeal.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court determined that it lacked jurisdiction over Hairston’s post-trial motions because she failed to file an amended notice of appeal after the district court ruled on those motions. However, the court did have jurisdiction to address Hairston’s challenge to the district court’s decision to limit the testimony of one of her witnesses. The Eighth Circuit found that the district court did not abuse its discretion in excluding the testimony, as it was deemed irrelevant and more prejudicial than probative. Consequently, the Eighth Circuit affirmed the judgment of the district court. View "Hairston v. Wormuth" on Justia Law

The case revolves around Thomas Clobes, a Christian employee at a 3M manufacturing plant in Minnesota, who objected to 3M's COVID-19 vaccination policy on religious grounds. Clobes was told he would be terminated if he did not get vaccinated. He submitted a religious accommodation request to 3M, asking to continue with the same accommodations he had been following, such as wearing a mask and maintaining social distance. 3M did not immediately grant the request and asked Clobes follow-up questions about his religious beliefs and objections to the vaccine. Meanwhile, 3M continued to send daily email and loudspeaker announcements urging employees to get vaccinated. However, the vaccine requirement was eventually lifted due to the Federal Contractor Mandate being enjoined.In the District Court of Minnesota, Clobes sued 3M, alleging religious discrimination and a hostile work environment under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA). The district court granted 3M's motion to dismiss, ruling that Clobes failed to demonstrate that he suffered an adverse employment action or that similarly situated non-Christians were treated differently by 3M. The court also found that Clobes failed to allege any conduct on 3M's part that rose to the level of severe or pervasive harassment, and that there was no causal connection between Clobes's religion and 3M's conduct. The court denied Clobes leave to amend his complaint, reasoning that amendment would be futile as Clobes failed to identify any additional facts that would establish a viable claim.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court found that Clobes's complaint failed to plausibly support the elements of a hostile work environment claim, namely, that a causal nexus existed between 3M's allegedly harassing conduct and Clobes's status as a Christian, and that the harassment affected a term, condition, or privilege of employment. The court also upheld the district court's denial of leave to amend the complaint, as Clobes had not complied with the local rules requiring a copy of the proposed amended pleading to accompany any motion to amend. View "Clobes v. 3M Company" on Justia Law

In December 2019, Tonya Huber, a store manager for Westar Foods, Inc., missed work due to a diabetic episode. Shortly after, Westar fired her. Huber sued Westar, alleging disability discrimination under the Americans with Disabilities Act (ADA) and Nebraska Fair Employment Practices Act (NFEPA), and interference with and retaliation for exercising her rights under the Family and Medical Leave Act (FMLA). Westar filed a motion for summary judgment, which the district court granted. Huber appealed.The district court granted Westar's motion for summary judgment, concluding that Huber failed to present direct evidence of disability discrimination and that she did not meet her burden under the McDonnell Douglas burden-shifting framework to show that Westar's reason for firing her was pretextual. The court also found that Huber failed to show that Westar interfered with her FMLA rights or retaliated against her for exercising those rights.The United States Court of Appeals for the Eighth Circuit reversed and remanded the case for further proceedings. The court found that genuine issues of fact existed regarding whether Westar's reason for firing Huber was pretextual and whether Westar interfered with or retaliated against Huber for exercising her FMLA rights. The court concluded that a reasonable jury could find that Westar's termination decision was motivated by discriminatory animus and that Westar interfered with Huber's FMLA rights. The court also found that genuine issues of fact existed regarding whether Huber provided Westar with notice of her need for FMLA leave as soon as practicable and whether there was a causal connection between her FMLA rights and Westar's termination decision. View "Huber v. Westar Foods, Inc." on Justia Law

A physical therapist, Pamela Cole, filed a lawsuit against her employer, Group Health Plan, Inc., alleging religious discrimination under Title VII and the Minnesota Human Rights Act. Cole, a member of the Eckankar religion, objected to the company's COVID-19 vaccine mandate on religious grounds. Although the company exempted her from the mandate, it imposed conditions such as wearing a medical-grade mask and potentially being reassigned to a different work setting. Cole argued that these conditions, along with a badge system that publicly identified vaccination status, singled out unvaccinated employees and subjected them to ridicule and criticism.The District Court for the District of Minnesota dismissed Cole's complaint, ruling that she failed to state a claim. Cole appealed this decision to the United States Court of Appeals for the Eighth Circuit.The Eighth Circuit Court reviewed the dismissal de novo, meaning it considered the case anew, as if no decision had been previously made. The court found that Cole had plausibly alleged a claim of disparate treatment, a form of religious discrimination. The court noted that Cole had sufficiently alleged that she was a member of a protected class due to her religious beliefs, that she met her employer's legitimate expectations, and that the circumstances gave rise to an inference of discrimination. The court also found that whether Cole had suffered an adverse employment action, a key element of a discrimination claim, required further factual development.The Eighth Circuit Court reversed the district court's decision, remanding the case for further proceedings. The court concluded that dismissal of the complaint on the basis of no adverse action was improper at this stage of the proceedings. View "Cole v. Group Health Plan, Inc." on Justia Law

Robert Wayne Goosen, an employee of the Minnesota Department of Transportation (MNDOT), suffered an on-the-job injury in 2018 that required multiple surgeries and physical therapy. In 2021, after reaching his maximum medical improvement, Goosen's doctor determined that he could return to work with certain physical restrictions. However, MNDOT concluded that Goosen could not perform the essential functions of his job due to these restrictions and could not be reasonably accommodated. Goosen subsequently filed a lawsuit alleging that MNDOT violated the Americans with Disabilities Act (ADA) by failing to provide a reasonable accommodation.The district court granted MNDOT's motion for summary judgment. The court found that no reasonable jury could conclude that Goosen was qualified to perform the essential functions of his former position or that a reasonable accommodation was possible. Goosen appealed this decision.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed with the lower court's determination that Goosen could not perform the essential functions of his job, even with reasonable accommodation. The court also found that Goosen failed to make a facial showing that reassignment to a different position within MNDOT was a reasonable accommodation. The court concluded that Goosen did not provide sufficient evidence to support his claim that MNDOT violated the ADA. View "Robert Goosen v. Minn. Dept. of Transportation" on Justia Law

This case is a class action involving commercial truck drivers who claimed they were not paid properly by Werner Enterprises, Inc., and Drivers Management, LLC. The drivers alleged that they were not adequately compensated for off-duty time spent on short rest breaks and time spent resting in their trucks’ sleeper-berths. The case has been appealed multiple times, with the court previously vacating a jury verdict in favor of the drivers because the district court improperly allowed the drivers to submit an expert report after the deadline. On remand, the district court entered judgment in favor of the defendants. The drivers appealed again, and the court vacated the judgment and remanded the case back to the district court to conduct an analysis regarding whether the expert report should be excluded as a discovery sanction and whether the district court should appoint an independent expert.On remand, the district court concluded that exclusion of the drivers’ expert report was the appropriate sanction for its late disclosure and that appointment of an independent expert was not appropriate. It then entered judgment in favor of the defendants. The drivers appealed this decision, asserting that the district court erred in its analysis. The defendants cross-appealed, asserting that the drivers’ notice of appeal was untimely, requiring dismissal of the appeal.The United States Court of Appeals for the Eighth Circuit rejected the defendants’ contention on cross-appeal and affirmed the judgment of the district court. The court found that the district court did not abuse its discretion in excluding the expert report and denying the drivers’ motion for a new trial. The court also found that the district court did not err in declining to appoint an expert and in entering judgment in favor of the defendants. View "Petrone v. Werner Enterprises, Inc." on Justia Law