Justia Labor & Employment Law Opinion Summaries

Daniel’la Deering, an in-house lawyer for Lockheed Martin, was terminated and subsequently sued the company for discrimination and retaliation. While her discrimination claim was dismissed at the summary judgment stage, her retaliation claim was set to go to trial. However, during the litigation, Deering misled Lockheed Martin and the district court about her employment status and income. She falsely claimed to be employed by nVent and did not disclose her higher-paying job elsewhere, even submitting false information in a deposition, declaration, and settlement letters.The United States District Court for the District of Minnesota, presided over by Judge David S. Doty, found that Deering’s actions constituted intentional, willful, and bad-faith misconduct. Lockheed Martin discovered the deception shortly before the trial, leading to an emergency motion for sanctions. The district court dismissed Deering’s case with prejudice and awarded Lockheed Martin $93,193 in attorney fees. Deering’s motions for a continuance and reconsideration were also denied by the district court.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 the district court did not abuse its discretion in dismissing the case due to Deering’s prolonged and intentional deception. The court emphasized that dismissal was appropriate given the severity and duration of the misconduct. Additionally, the appellate court found no abuse of discretion in the district court’s denial of Deering’s motions for a continuance and reconsideration. However, the appellate court dismissed Deering’s appeal regarding the attorney fee award due to a premature notice of appeal. View "Deering v. Lockheed Martin Corp." on Justia Law

A group of Union Pacific Railroad Company employees filed a class action lawsuit against the company, alleging that its fitness-for-duty program violated the Americans with Disabilities Act (ADA). Todd DeGeer, believing he was part of this class, filed an Equal Employment Opportunity Commission (EEOC) charge and an individual lawsuit after the class was decertified. DeGeer argued that his claims were tolled under the American Pipe & Construction Co. v. Utah doctrine. The district court dismissed his claims as untimely, finding that DeGeer was not a member of the narrowly defined class.The United States District Court for the District of Nebraska initially certified a class that included Union Pacific employees subjected to fitness-for-duty evaluations due to a reportable health event. DeGeer was on a list of employees provided by Union Pacific and submitted a declaration supporting the plaintiffs' certification motion. However, the class definition was later narrowed, and the district court certified the class under this new definition. The Eighth Circuit Court of Appeals later reversed the class certification, leading DeGeer to file his individual claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court's decision. The Eighth Circuit held that DeGeer was entitled to American Pipe tolling because the revised class definition did not unambiguously exclude him. The court emphasized that ambiguities in class definitions should be resolved in favor of applying tolling. Consequently, DeGeer's claims were tolled during the pendency of the class action, making his individual lawsuit timely. The case was remanded for further proceedings. View "DeGeer v. Union Pacific Railroad Co." on Justia Law

Erica Barrett and other employees of O’Reilly Automotive, Inc. alleged that the company’s 401(k) plan managers breached their fiduciary duty by imposing high recordkeeping expenses and inflated expense ratios on the plan, resulting in less money for the participants. They claimed that these high costs were due to either incompetence or laziness on the part of the plan managers.The United States District Court for the Western District of Missouri dismissed the complaint. The court found that the plaintiffs failed to provide meaningful benchmarks to support their claim that the plan’s fees were excessive. Specifically, the court noted that the plaintiffs did not adequately compare the costs of O’Reilly’s plan with those of similar plans offering the same services.The United States Court of Appeals for the Eighth Circuit reviewed the dismissal de novo. The court affirmed the district court’s decision, agreeing that the plaintiffs did not provide meaningful benchmarks to show that the plan’s fees were excessive. The court emphasized that the plaintiffs’ comparisons were flawed because they did not account for the different services included in the fees of the comparator plans. Additionally, the court found that aggregate data from the Investment Company Institute was insufficient to establish a plausible claim of mismanagement. The court also dismissed the failure-to-monitor claim against O’Reilly and its board of directors, as it was derivative of the primary claim. Finally, the court held that the district court did not abuse its discretion in dismissing the complaint with prejudice, as the plaintiffs did not formally request leave to amend their complaint. View "Barrett v. O'Reilly Automotive, Inc." on Justia Law

Raymond Black, a skilled mechanic at Swift Pork Company, was responsible for operating and fixing the loin-puller machine. He frequently took FMLA leave to care for his wife, who had severe cardiovascular disease. After returning to work from a bout of pneumonia, Black was reassigned to a different task, which led to a dispute with his supervisor. Black requested vacation time, which was denied, and then opted for FMLA leave to care for his sick wife. He was subsequently fired after a meeting with the human-resources director and plant manager.The United States District Court for the Southern District of Iowa granted summary judgment in favor of Swift Pork Company on both of Black's FMLA claims—interference and discrimination. Black then appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that there was sufficient evidence to create a jury question on whether Black's FMLA leave was medically necessary and whether Swift interfered with his FMLA rights by not crediting his absences and firing him. Therefore, the court reversed the summary judgment on the interference claim and remanded it for further proceedings.However, the court affirmed the summary judgment on the discrimination claim. The court concluded that there was no evidence that Swift fired Black because he took FMLA leave, especially given his extensive history of taking FMLA leave without repercussions. Negative comments from supervisors who did not make the termination decision were insufficient to establish a discriminatory motive.In summary, the Eighth Circuit reversed and remanded the interference claim but affirmed the dismissal of the discrimination claim. View "Black v. Swift Pork Company" on Justia Law

Mychal Byrd was injured in an automobile accident caused by an unknown motorist and subsequently died from his injuries. Byrd's medical expenses, totaling $474,218.24, were covered by the Gilster-Mary Lee Corporation Group Health Benefit Plan, a self-funded plan subject to ERISA. Byrd had an automobile insurance policy with Nationwide Insurance Company, which provided $50,000 in uninsured-motorist coverage. After Byrd's death, his family sued Nationwide in state court to collect the insurance proceeds. The Plan intervened, removed the case to federal court, and claimed an equitable right to the insurance proceeds.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the Plan, determining that the Plan was entitled to the insurance proceeds under the plan document. The plaintiffs, initially proceeding pro se, did not respond to the motion for summary judgment. After obtaining counsel, they moved for reconsideration, which the district court denied. The plaintiffs then appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the district court lacked subject-matter jurisdiction. The appellate court determined that the plaintiffs' claim did not fall within the scope of ERISA's civil enforcement provisions because the plaintiffs were neither plan participants nor beneficiaries. Consequently, the claim was not completely preempted by ERISA, and the federal court did not have jurisdiction. The Eighth Circuit vacated the district court's judgment and remanded the case with instructions to return it to Missouri state court. View "Kellum v. Gilster-Mary Lee Corporation Group Health Benefit" on Justia Law

Covenant Construction Services, LLC was the prime contractor on a federal construction project for a U.S. Department of Veterans Affairs facility in Iowa City, Iowa. Covenant subcontracted with Calacci Construction Company, Inc. to supply carpentry labor and materials. Calacci had a collective bargaining agreement (CBA) with two regional unions, requiring it to pay fringe-benefit contributions to the Five Rivers Carpenters Health and Welfare Fund and Education Trust Fund (the Funds). Despite multiple demands, Calacci failed to remit the required contributions.The Funds filed a lawsuit under the Miller Act to collect the unpaid contributions, liquidated damages, interest, costs, and attorneys' fees from Covenant and its surety, North American Specialty Insurance Company. The United States District Court for the Southern District of Iowa granted summary judgment in favor of the Funds, concluding that the Funds had standing to sue and that the Miller Act notice was properly served and timely.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the Funds sufficiently complied with the Miller Act's notice requirements by sending the notice to Covenant's attorney, who confirmed receipt. The court also held that the notice was timely as it was filed within 90 days of the last day of labor on the project. Additionally, the court upheld the award of liquidated damages and attorneys' fees, finding that the CBA obligated Calacci to pay these amounts and that Covenant, as the prime contractor, was liable for the amounts due under the payment bond.The Eighth Circuit concluded that the Funds were entitled to recover the unpaid contributions, liquidated damages, and attorneys' fees from Covenant and its surety, affirming the district court's judgment. View "Five Rivers Carpenters v. Covenant Construction Services" on Justia Law

Eniola Famuyide filed a lawsuit against Chipotle Mexican Grill and its subsidiary, alleging sexual assault and harassment in the workplace. Famuyide claimed that a co-worker began harassing her shortly after she started working in May 2021 and sexually assaulted her in November 2021. She reported the incident to her manager, took a leave of absence, and later faced issues accessing the company’s online portal, leading her to believe she had been terminated. Chipotle later informed her that the termination was an error. Famuyide's complaint included claims of hostile work environment, retaliation, and other related charges under Minnesota law.The United States District Court for the District of Minnesota reviewed the case and denied Chipotle's motion to compel arbitration. The court determined that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 applied, as the dispute arose after the Act's enactment date of March 3, 2022. Chipotle argued that the dispute arose before this date, pointing to the initial harassment and assault in 2021 and letters from Famuyide’s counsel in February 2022. However, the court found that no formal dispute existed between the parties until after the Act's enactment.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court held that a "dispute" under the Act did not arise until after March 3, 2022, as there was no conflict or controversy between Famuyide and Chipotle before that date. The court rejected Chipotle's arguments that the dispute arose either at the time of the assault or upon receipt of the February 2022 letters from Famuyide’s counsel. The court also declined to consider a March 1, 2022, letter from Chipotle’s counsel, as it was not part of the record. The district court's order was affirmed. View "Famuyide v. Chipotle Mexican Grill, Inc." on Justia Law

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