Justia Labor & Employment Law Opinion Summaries

Appellants are four Minnesota state employees who sued unions that represented their local bargaining units. The employees sought monetary relief based on the amount of so-called “fair-share” fees that were deducted from employee paychecks for the benefit of the unions. The district court granted summary judgment in favor of the unions.  On appeal, the employees argue that the district court erred by granting summary judgment in favor of the unions on each of the claims for retrospective relief.   The Eighth Circuit affirmed, holding that the unions’ reliance on Section 179A.06 was objectively reasonable. It is an open question whether subjective intent is relevant to the defense, but the employees did not present a submissible case that the unions collected fair-share fees in subjective bad faith in any event. Therefore, the district court correctly granted summary judgment for the unions on these claims.   The unions prevailed on motions for summary judgment. The rules of civil procedure provide those costs “should be allowed to the prevailing party,” unless the court or a federal statute or rule directs otherwise. Further, the employees point to no authority that requires a district court to reduce an award of costs because a defendant opted to forgo a motion to dismiss and to file a dispositive motion only after developing a factual record. A defendant may choose how best to defend a lawsuit, and if the case is resolved in favor of the defense on a motion for summary judgment, then the defendant is presumptively entitled to costs. View "Linda Hoekman v. Education Minnesota" on Justia Law

Plaintiff, an employee of the Department of Veterans Affairs, sued Denis McDonough, Secretary of the Department of Veterans Affairs, for disability discrimination. Plaintiff alleged three violations of the Rehabilitation Act: failure to accommodate; disability discrimination; and retaliation for requesting an accommodation. The district court granted summary judgment to Secretary McDonough.   The Eighth Circuit affirmed. The court wrote that Plaintiff’s requested accommodation was not required under the Rehabilitation Act because it would impose an undue hardship on the VAPD. The court explained that Plaintiff’s accommodations would have violated the VAPD’s collective bargaining agreement, which requires that “[s]cheduled off-tours shall be rotated fairly and equitably among affected employees, i.e., day/evening, day/night.” Plaintiff’s requested accommodations are therefore presumptively unreasonable.   Plaintiff further argued that his reassignment was not reasonable for two reasons. First, he claimed that day shifts were not the only form of requested relief; they were just one of many possible accommodations the VAPD could have made. But the record undermines his argument. Further, he also suggested that his reassignment constituted an adverse employment action, not a reasonable accommodation. The VAPD provided the only available reasonable accommodation—reassignment. The district court was therefore correct to grant summary judgment to Secretary McDonough on Plaintiff’s failure to accommodate claim.   Moreover, Plaintiff claimed the unusual nature of his hiring process proves that the real reason for his non-selection was disability discrimination. However, showing that an interview process is “unusual” is not sufficient to prove that an employer’s proffered reason is pretextual. View "Jesse LeBlanc v. Denis McDonough" on Justia Law

The United States Secretary of Labor (“Secretary”) sued Alpha & Omega USA, Inc., d/b/a Travelon Transportation and its owner (together “Travelon”) for violating the Fair Labor Standards Act (FLSA). The district court granted summary judgment in favor of the Secretary. Travelon appealed, arguing the district court erred in granting the Secretary’s motion.   The Eighth Circuit reversed the district court’s grant of summary judgment finding that there were genuine issues of material fact regarding whether an employment relationship existed between Travelon and its drivers. The court wrote that when an employment relationship is in question, many courts decide whether workers are independent contractors or employees by applying the multi-factor “economic realities” test. This test examines six factors regarding the economic realities of the working relationship.   The court explained that here, viewing the evidence in the light most favorable to Travelon, issues of material fact remain as to the working relationship between Travelon and its drivers. Specifically, Travelon has offered evidence from which a rational trier of fact could find the “control,” “profits and losses,” and “integral to business” factors weigh in favor of the drivers being independent contractors.   Further, while the Secretary has shown evidence supporting an employment relationship between Travelon and its drivers, Travelon has also shown evidence of an independent contractor relationship. These competing narratives must be resolved before the district court makes its legal conclusion as to whether an employment relationship existed between Travelon and its drivers. View "Martin Walsh v. Alpha & Omega USA, Inc." on Justia Law

Appellant, a black male who was 60 years old at the time his employment was terminated, brought race, sex, and age discrimination claims under Title VII, the Age Discrimination in Employment Act (“ADEA”), and the Minnesota Human Rights Act (“MHRA”) and a retaliation claim under the Minnesota Whistleblower Act ("MWA") after the Minnesota Guardian ad Litem Board (“GALB”) terminated his employment following internal and external investigations into allegations of his misconduct. The district court granted GALB’s motion for summary judgment, finding that Appellant failed to demonstrate a prima facie case of discrimination or retaliation and, even if he had done so, he failed to demonstrate GALB’s reasons for terminating his employment were pretextual.   Appellant appealed and the Eighth Circuit affirmed. The court explained that Appellant failed to point to any direct evidence of discrimination or retaliation; thus, the McDonnell Douglas burden-shifting framework applies. The court concluded that GALB has demonstrated a legitimate, nondiscriminatory and nonretaliatory reason for terminating Appellant in March 2018: the internal and external investigations into Appellant’s alleged misconduct uncovered evidence that Appellant had engaged in gross misconduct. As such, because Appellant failed to show that GALB’s reasons for terminating his employment were pretextual, the district court did not err in granting summary judgment to GALB on his race, sex, and age discrimination claims and his retaliation claim. View "Gregory King v. MN Guardian ad Litem Board" on Justia Law

Iowa Northern Railway Company (“Iowa Northern”) and the International Association of Sheet Metal, Air, Rail and Transportation Workers (the “Union”) are both parties to a Collective Bargaining Agreement (“CBA”) that is subject to the Railway Labor Act (“RLA”). In 2019, Iowa Northern offered to increase the pay of unionized Train and Engine employees to $300 to recruit additional employees. The Union members rejected the pay increase. Subsequently, Iowa Northern served a Section 6 notice on the Union, proposing changes to the CBA. When the Union failed to respond, Iowa Northern provide notice it intended to resort to self-help, and then increased the pay rate to $300 per day.The Union then filed this case, claiming that Iowa Northern violated the RLA by unlawfully resorting to self-help and seeking a preliminary injunction to maintain the status quo prior to the pay-rate changes. The district court denied the Union's request, finding that it did not meet its burden of establishing the likelihood of success on the merits. The Union appealed.The Eighth Circuit affirmed the district court's denial of a Union's requested preliminary injunction, finding that the Defendant railway operator did not violate the Railway Labor Act when it resorted to self-help. The court explained the Union's "prolonged foot-dragging and refusal to respond on an issue of vital importance to Iowa Northern (and to the Union’s members) raise substantial doubt that the Union’s status quo claim will survive." View "Intl Assn of Sheet Metal, Air, Rail & Trans v. Iowa Northern Railway Company" on Justia Law

Plaintiff a former part-time employee of the City of Cedar Falls, brought an action against the City of Cedar Falls and certain city officials after her 2018 termination, alleging interference with and retaliation for the exercise of her rights under the Family and Medical Leave Act (FMLA) and claims of age discrimination, disability discrimination, hostile work environment, and retaliation under the Iowa Civil Rights Act (ICRA). The district court granted summary judgment in favor of Defendants on all of Plaintiff’s claims, and she appealed.
The Eighth Circuit affirmed. The court explained that it need not consider the substantive elements of the claim because Plaintiff has failed to demonstrate that she sustained any recoverable damages and it is undisputed that she did not seek any form of equitable relief.   Second, as to the retaliation claim, the court applied the McDonnell Douglas burden-shifting framework, which requires a plaintiff to make a prima facie showing of retaliation before the burden shifts back to the employer to offer a legitimate, non-discriminatory reason for its actions. Here, Plaintiff has failed to put forth any evidence of the kind that would demonstrate pretext. She offered nothing more than disagreement with the statements contained in the disciplinary reports. In the absence of any factual record demonstrating that these documented performance deficiencies were inaccurate, Plaintiff has failed to meet her burden of demonstrating pretext. Finally, Plaintiff has failed to show that the final three disciplinary reports were part of the same unlawful employment practice—harassment based on her age and disability. View "Michelle Brandt v. City of Cedar Falls" on Justia Law

Plaintiff sued her former employer, the University of Minnesota, under the Americans with Disabilities Act (“ADA”), for discrimination based on her disability, failure to provide a reasonable accommodation for her disability, and retaliation. The district court granted summary judgment to the University.The Eighth Circuit affirmed the district court’s ruling. The court first addressed whether Plaintiff met her burden to show that the University failed to provide a reasonable accommodation; specifically, whether Plaintiff qualified for any alternative positions. The court held that Plaintiff did not meet her burden, reasoning that she did not submit the job posting, the job title, or any evidence of the duties or requirements of any position.Further, the court addressed whether the University failed to engage in the interactive process. The court concluded that there is no genuine dispute of material fact about whether the University acted in good faith to make reasonable accommodations for Plaintiff. The University offered to help Plaintiff find a new job many times and considered adopting technologies to help Plaintiff perform her job duties. Once the University realized Plaintiff could not be accommodated in her current position, an employee from the job center reached out to Plaintiff to schedule a meeting about vacant positions. But Plaintiff cancelled it, and the rescheduled meeting could not take place because Plaintiff went on full-time medical leave. Moreover, even if the University did not use good-faith efforts, Plaintiff needed to show that she “could have been reasonably accommodated but for the employer’s lack of good faith.” View "Jessica Ehlers v. University of Minnesota" on Justia Law

Plaintiff, a locomotive engineer, sued Kansas City Southern Railway Company (“KCSR”) for negligence after he sustained injuries in a railcar collision. The district court granted summary judgment to KCSR. Plaintiff argued that section 287.280.1, the civil-action provision, authorizes his civil action because KCSR failed to carry workers’ compensation insurance. KCSR responded that it is not liable because Plaintiff “was insured by his immediate . . . employer,” triggering the exemption from liability for statutory employers in section 287.040.3. According to Plaintiff, however, section 287.040.3 exempts KCSR from workers’ compensation liability only, not liability from civil actions.   The Eighth Circuit affirmed the district court’s grant of summary judgment in favor of KCSR. The court held that because Plaintiff was insured by his immediate employer, KCSR is not liable and is entitled to judgment as a matter of law. The court reasoned that Missouri’s workers’ compensation statute, Mo. Rev. Stat. Section 287.120.1, imposes liability on employers for workplace injuries. However, nowhere in section 287.040 does the text differentiate between workers’ compensation liability and civil liability. Accordingly, the court interpreted “liable as in this section provided” to mean “liable as an employer”; that is, liable as a statutory employer. Thus, KCSR’s potential liability, therefore, is liability “as in [section 287.040] provided,” so it enjoys the immunity from suit. View "Nathan Blanton v. KC Southern Railway Co." on Justia Law

Plaintiff sued Defendants claiming they violated the Fair Labor Standards Act and the Arkansas Minimum Wage Act. The district court entered an order granting summary judgment to Defendants. After the court entered its order, but before the clerk had entered a separate judgment dismissing Plaintiff’s claims, Plaintiff filed a notice stating that he had accepted an offer of judgment that Defendants had extended in which they agreed to pay him four thousand dollars plus costs and reasonable attorneys' fees.   Plaintiff maintained that, under Rule 68(a), he could accept the offer anytime up to fourteen days after Defendants had served him with it, and therefore it had survived the court's grant of summary judgment. The clerk nevertheless entered judgment consistent with the summary-judgment order. Plaintiff moved the court to amend the judgment to reflect the terms in the offer of judgment. The district court, relying on Perkins, granted Plaintiff’s motion, and the clerk entered a new judgment. Defendants appealed, maintaining that the judgment should have reflected the court's summary judgment ruling rather than the offer of judgment.   The Eighth Circuit affirmed the district court’s ruling and denied Defendants' requested relief and affirmed the district court’s denial of Plaintiff’s motion for recusal and from the court’s order granting Plaintiff only one dollar in attorneys' fees. The court reasoned that only its’ en banc court may overrule a prior panel's decision. Further, the court held that the district court did not abuse its discretion in awarding only one dollar in fees. View "Stetson Skender v. Eden Isle Corporation" on Justia Law

Plaintiffs, civil detainees in the Minnesota Sex Offender Program (“MSOP”), sued the state defendants arguing that they failed to pay Plaintiffs minimum wage under the Fair Labor Standards Act, 29 U.S.C. Sec. 201. The district court granted summary judgment to Defendants.The Eighth Circuit affirmed the ruling finding that sexually dangerous civil detainees are not state employees. The court reasoned that “there is no bargained-for exchange of labor for mutual economic gain” like that which “occurs in a true employer-employee relationship.” Further detainees are under the control and supervision of the detention facility, which is not comparable to the free labor situation of true employment. Moreover, the detainees have their basic needs met by the state, which means that the FLSA’s purpose to maintain a “standard of living necessary for health, efficiency, and general well-being of workers” does not apply. View "David Gamble v. Minnesota State-Operated Svcs" on Justia Law