Justia Labor & Employment Law Opinion Summaries

Former employees of Honeywell, who retired before age 65 during the terms of Honeywell's 2007 and 2010 collective bargaining agreements (CBAs), filed a class action alleging that Honeywell's announced plan to terminate early retiree healthcare benefits at the end of 2017 breached the CBAs and violated the Employee Retirement Income Security Act of 1974 (ERISA), because those healthcare benefits vested when each class member retired.The Eighth Circuit agreed with the Sixth Circuit and held that the Supreme Court's decision in CNH Indus. N.V. v. Reese, 138 S. Ct. 761 (2018), was controlling in this case. Under Reese, the court held that plaintiffs' retiree healthcare benefits were not vested as a matter of law. Therefore, the court reversed and remanded for further proceedings. View "Pacheco v. Honeywell International Inc." on Justia Law

Where a jury awarded plaintiff nominal compensatory damages and punitive damages for his claim of hostile work environment against his former employer, the Eighth Circuit affirmed the district court's denial of defendant's post-trial motions and grant of attorney's fees to plaintiff. The court held that the $250,000 award of punitive damages was supported by the record where plaintiff repeatedly complained to supervisors that his manager was using racial slurs and the company did not take action; plaintiff's 42 U.S.C. 1981 claim was timely under the applicable four year statue of limitations where the workplace abuse continued into the limitations period; the punitive damages amount was constitutionally sound in light of the degree of reprehensibility of defendant's misconduct; and the district court did not abuse its discretion in awarding attorney's fees and accepting the attorney's hourly rate as reasonable. View "Bryant v. Jeffrey Sand Co." on Justia Law

The Eighth Circuit reversed the district court's denial of summary judgment to the acting county sheriff and the county in an action brought by plaintiff alleging violation of her First Amendment right to intimate association. Plaintiff contended that the sheriff had terminated her based on her marriage to her husband, who had been terminated shortly before plaintiff.The court held that the sheriff's termination of plaintiff did not amount to a constitutional violation, because the fact that the marriage was a motivating factor in the decision to terminate plaintiff did not mean that the sheriff directly and substantially interfered with their marriage. In this case, the husband was terminated for sexually harassing other employees. Plaintiff was placed on administrative leave before the sheriff determined that her return would create a hostile work environment due to her loyalty to her husband. The court also held that, because the sheriff did not commit an unconstitutional act, no municipal liability attached to the county. View "Muir v. Decatur County, Iowa" on Justia Law

Plaintiff filed suit against his employer, Boeing, for wrongful discharge in violation of public policy. Plaintiff was an at-will employee with Special Action Program (SAP) clearances and access for his classified work. After his SAP status was terminated, plaintiff refused Boeing's requests to debrief.The Eighth Circuit affirmed the district court's denial of Boeing's motion to dismiss for lack of subject matter jurisdiction and grant of dismissal under Federal Rule of Civil Procedure 12(b)(6). The court held that the district court correctly concluded it had subject matter jurisdiction over plaintiff's wrongful termination claim where the claim did not challenge the merits of the security clearance decision. The court also held that the district court properly dismissed plaintiff's wrongful discharge claim. In this case, plaintiff failed to state a claim upon which relief could be granted because the manuals he cites did not clearly prohibit him from being debriefed in a SAP facility. View "Dubuque v. The Boeing Co." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment to Continental in a personal injury action. In this case, plaintiff was an employee of Great Western, and Continental had hired Great Western as an independent contractor to gauge wastewater levels in holding tanks at its well sites in North Dakota.The court held that the master service contract between Continental and Great Western did not provide that Continental would supervise, inspect, or direct Great Western's work, and plaintiff failed to demonstrate that Continental directly supervised his work or instructed him on the use of the well site equipment. Therefore, because Continental did not control plaintiff's work nor instruct him on the use of the equipment, it was not liable for negligence because it did not owe plaintiff a duty. The court also held that the district court did not err in finding that Continental's failure to answer plaintiff's amended complaint, which was filed after the parties briefed summary judgment, did not constitute an admission. Finally, to the extent plaintiff made a premises liability argument on appeal, the court would not consider the claim because it was not raised before the district court. View "Vandewarker v. Continental Resources, Inc." on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for the Housing Authority and plaintiff's supervisor in an action alleging various discrimination, retaliation, and constitutional claims. Plaintiff resigned from his job after he failed a drug test and his employer sought documentation of the prescription medications plaintiff was using, as well as a clearance letter from plaintiff's healthcare professionals addressing the issue.The court held that, by not including in his EEOC charge the adverse acts which he maintained forced him to resign, plaintiff failed to administratively exhaust his constructive discharge allegation; plaintiff failed to establish a prima facie case of disability discrimination; plaintiff failed to show that he suffered an adverse employment action because he was suspended before his employer had any reason to suspect that he might be disabled; and plaintiff failed to show that he possessed a property interest in his employment under Arkansas law in order to prevail on his procedural due process claim. View "Voss v. Housing Authority of the City of Magnolia" on Justia Law

The Eighth Circuit affirmed the district court's judgment in favor of JBS in an action under the Americans with Disabilities Act (ADA), the Iowa Civil Rights Act (ICRA), and the Iowa Wage Payment Collection Law (IWPCL). Plaintiff alleged a failure to accommodate claim and a termination claim, as well as a claim that JBS intentionally failed to pay plaintiff a portion of his earned wages.The court held that, even if plaintiff was disabled, he was not qualified to perform the essential functions of his job, and his claims failed on that basis. The court explained that lifting was an essential function of the maintenance mechanic position that could not be reasonably accommodated, and plaintiff failed to show that accommodations JBS offered were unreasonable. The court held that plaintiff was not a qualified individual under the ADA and thus his termination claim also failed. Finally, because mere allegations were insufficient to rebut a properly supported motion for summary judgment, the district court properly granted summary judgment as to the IWPCL claim. In this case, JBS's payroll records reflected that plaintiff was correctly paid and any errors were quickly remedied. View "Gardea v. JBS USA, LLC" on Justia Law

After the sheriff's department decided not to reinstate plaintiff, she filed suit against the county alleging retaliation and sex, pregnancy, and disability discrimination, in violation of Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act (ADA), and the Nebraska Fair Employment Practice Act (NFEPA). The Eighth Circuit affirmed the district court's dismissal of her claims and held that her Title VII claim failed because she did not plead any facts showing that another candidate was similarly situated or went through a reinstatement process. Because her state claim mirrored her Title VII claim, it likewise failed. View "Jones v. Douglas County Sheriff's Department" on Justia Law

The Eighth Circuit affirmed the district court's grant of Medtronic's motion to remand an employment contract dispute back to state court. Applying Minnesota law, the court held that plaintiff waived his right to remove the case to federal court because the employment contract he signed contained an enforceable forum selection clause. In this case, Medtronic alleged that plaintiff failed to repay the company pursuant to the Repayment Agreement. The court held that the Employee Agreement contained a clear and unequivocal forum selection clause that unambiguously encompassed the Repayment Agreement. View "Medtronic Sofamor Danek, Inc. v. Gannon" on Justia Law

Plaintiff filed suit against his former employer for race and age discrimination under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act (ADEA), the Arkansas Civil Rights Act, and for promissory estoppel. The Eighth Circuit affirmed the district court's grant of the company's motion to strike portions of plaintiff's statement of material disputed facts and grant of summary judgment.The court held that the district court did not abuse its discretion in striking paragraphs of plaintiff's statement of material fact as unsupported by the record or irrelevant and immaterial; the district court properly granted the employer summary judgment on claims arising more than 180 days before plaintiff filed his EEOC charges; the district court properly granted the employer summary judgment on the failure to rehire claim because plaintiff took no action, never applied for reemployment, and believed he could not perform the duties of the position; the Arkansas Civil Rights Act claims were time-barred; and there was no factual basis for the promissory estoppel claim. View "Kirklin v. Joshen Paper & Packaging of Arkansas Co." on Justia Law