Justia Labor & Employment Law Opinion Summaries

Jeremy Hitt, a Remote Control Operator for CSX Transportation, Inc., was terminated after receiving three workplace violations within a three-year period. Hitt's first violation occurred in 2017 for failing to leave unattended train cars at a specified location. In the summer of 2018, Hitt refused to work during a lightning storm, citing safety concerns, and later refused to operate the train at a speed he considered unsafe. His second violation was in November 2018 for failing to secure his train properly. The third violation occurred in January 2019 when Hitt failed a banner test by using the emergency brake to stop the train.The United States District Court for the Northern District of Alabama granted summary judgment to CSX, concluding that Hitt failed to provide sufficient evidence of causation to support his claim under the Federal Railroad Safety Act (FRSA). The court found that Hitt could not establish that his protected activity (refusing to work during the lightning storm) was a contributing factor to his termination.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that Hitt failed to establish causation, as there was no evidence that his protected activity contributed to his termination. The court noted that the decision-makers who terminated Hitt were unaware of his protected activity and that Hitt's supervisor, who allegedly retaliated against him, had no influence over the termination decision. The court also found that the temporal gap between the protected activity and the adverse action was too long to establish causation based on temporal proximity alone. Thus, the court concluded that Hitt could not prove the elements of his FRSA claim. View "Hitt v. CSX Transportation Inc" on Justia Law

A group of drivers sued their employer, Owl, Inc., for breach of contract and violations of the Fair Labor Standards Act (FLSA). They claimed they were not paid the correct hourly rate under their employment contract or overtime wages under the FLSA. The district court granted summary judgment for Owl on the breach of contract claim and limited the damages available to the drivers for the FLSA claim. The parties then settled the FLSA claim for $350,000, and the drivers appealed the district court’s rulings.The district court for the Middle District of Florida granted summary judgment on the breach of contract claim, reasoning that the drivers had agreed to a specific hourly rate, and enforcing a higher rate under the Service Contract Act (SCA) would create a private right of action under the SCA, which does not exist. The court also granted Owl’s motion in limine, limiting the FLSA damages to one-and-a-half times the rate the drivers were actually paid. The drivers settled the FLSA claim but reserved the right to appeal the district court’s rulings.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that it had jurisdiction under 28 U.S.C. § 1291 because the district court entered a final judgment on all claims. The court also held that the drivers had standing to challenge the district court’s rulings despite the settlement. On the merits, the Eleventh Circuit affirmed the district court’s summary judgment on the breach of contract claim, holding that the SCA wage was not incorporated into the employment contracts. However, it reversed the district court’s ruling on the FLSA claim, holding that the “regular rate” under the FLSA should include the prevailing wage required by the SCA. The case was remanded for further proceedings consistent with this opinion. View "Perez v. Owl, Inc." on Justia Law

The case involves a class of current and former Home Depot employees who alleged that Home Depot failed to prudently manage its 401(k) retirement plan, resulting in excessive fees and subpar returns. The plaintiffs argued that Home Depot did not adequately monitor the fees charged by the plan’s financial advisor and failed to prudently evaluate four specific investment options, leading to financial losses for the plan participants.The United States District Court for the Northern District of Georgia found that there were genuine disputes of material fact regarding whether Home Depot had complied with its duty of prudence in monitoring plan fees and three of the four challenged funds. However, the court concluded that the plaintiffs had not met their burden of proving loss causation for any of their claims. The court also found no genuine dispute regarding the prudence of Home Depot’s monitoring process for the Stephens Fund and ruled that the plaintiffs had forfeited their requests for equitable relief by not arguing them at the summary judgment stage.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The court held that the plaintiffs bear the burden of proving loss causation in ERISA breach-of-fiduciary-duty claims. The court found that the plaintiffs failed to show that the fees charged by the financial advisors were objectively imprudent, given the size and complexity of Home Depot’s plan. The court also determined that the plaintiffs did not provide sufficient evidence to prove that the four challenged funds were objectively imprudent investments. Additionally, the court agreed with the district court that the plaintiffs had forfeited their claims for equitable relief by not raising them at the summary judgment stage. Therefore, the court affirmed the district court’s grant of summary judgment in favor of Home Depot. View "Pizarro v. The Home Depot, Inc." on Justia Law

The case involves two brothers, Levi and Benjamin Goldfarb, who sought payment of a $500,000 claim under an Accidental Death & Dismemberment insurance policy after their father, Dr. Alexander Goldfarb, died while mountain climbing in Pakistan. The insurer, Reliance Standard Life Insurance Company, denied the claim because the cause of Dr. Goldfarb’s death was unknown, and therefore, his beneficiaries could not show that he died by accident. The Goldfarb brothers challenged the denial in district court under the Employee Retirement Security Act.The district court ruled in favor of the Goldfarbs, stating that Dr. Goldfarb’s death was accidental and that Reliance Standard’s failure to pay the Accidental Death & Dismemberment claim was arbitrary and capricious. The court granted summary judgment to the Goldfarbs and denied Reliance Standard’s cross motion for summary judgment. Reliance Standard appealed this decision.The United States Court of Appeals for the Eleventh Circuit disagreed with the district court's decision. The appellate court found that Reliance Standard’s decision that Dr. Goldfarb’s death was not accidental under the insurance policy was supported by reasonable grounds, and the denial of the Goldfarbs’ claim for benefits was not arbitrary and capricious. Therefore, the court reversed the district court’s grant of summary judgment to the Goldfarbs and directed the court to enter judgment in Reliance Standard’s favor. View "Goldfarb v. Reliance Standard Life Insurance Co." on Justia Law

The case revolves around William Spears, a front desk clerk at hotels operated by Rick Patel Sr. and his son, Rick “Sunny” Patel Jr. Spears was compensated with monthly paychecks and onsite lodging. He sued the Patels and the hotel entities under the Fair Labor Standards Act for wages owed and unpaid overtime. The district court ruled that Sunny was an employer individually liable for the violations. In calculating Spears’s damages, the court considered the stipulated value of Spears’s lodging for unpaid overtime but declined to include it in the minimum-wage calculation.The case went to a bench trial before a magistrate judge. The judge found that Spears was not paid the legally required minimum wage or overtime. The judge ruled that Rick and Sunny were employers under the Act individually liable for those violations. The judge also found that Spears was entitled to damages for unpaid overtime and minimum wages. The judge included the stipulated $630 lodging value to determine Spears’s overtime pay rate but did not give the Patels credit for the value of Spears’s lodging when calculating Spears’s unpaid minimum wages.The United States Court of Appeals for the Eleventh Circuit affirmed the ruling that Sunny was an employer under the Act due to his involvement in the day-to-day operation of the hotels and some financial control. However, the court vacated and remanded for recalculation of damages. The court held that the magistrate judge erred in excluding the stipulated value of Spears’s lodging from the calculation of his unpaid minimum wages but including it for the calculation of Spears’s overtime damages. The court reasoned that the stipulation to the value of Spears’s lodging relieved the Patels of the burden to prove at trial the reasonable cost of lodging. View "Spears v. Patel" on Justia Law

The case involves Tristan Tanner, an employee of Stryker Corporation of Michigan, who appealed against the district court's decision granting summary judgment in favor of Stryker. Tanner had filed claims for interference with his rights under the Family and Medical Leave Act (FMLA) and for retaliation for his exercise of those rights. Tanner had requested paternity leave for the birth of his child and had taken time off work before the birth of his child, during which he accrued "occurrence points" under Stryker's attendance policy. He was terminated after accruing more than the allowed number of points.The district court had granted summary judgment in favor of Stryker, finding that Tanner was not entitled to FMLA leave for his absences before his child's birth. The court also found that Stryker had legitimate, non-discriminatory reasons for terminating Tanner, namely his accrual of eight occurrence points due to repeated unexcused absences.In the United States Court of Appeals for the Eleventh Circuit, the court affirmed the district court's decision. The court held that the days Tanner spent in Connecticut waiting for his child to be born were not covered under FMLA. The court also found that Tanner had not provided evidence to create a genuine issue of material fact as to whether Stryker's reason for his termination was pretextual. Therefore, the court concluded that summary judgment in Stryker's favor was appropriate for both Tanner's FMLA retaliation and interference claims. View "Tanner v. Stryker Corporation of Michigan" on Justia Law

The case involves Cynthia Allen and Kristine Webb, who filed a class action lawsuit against their employer, AT&T Mobility Services, LLC, alleging pregnancy discrimination under Title VII. The district court denied their motion for class certification, and the plaintiffs settled with AT&T and voluntarily dismissed their case. The following day, Amanda Curlee, who claimed she would have been a member of the proposed class, sought to intervene in the case to appeal the denial of class certification. The district court allowed her to intervene, and she immediately appealed.The district court had denied the original plaintiffs' motion for class certification, and the plaintiffs subsequently settled with AT&T and voluntarily dismissed their case. The court had not addressed the merits of any plaintiff's discrimination claims. Amanda Curlee, who claimed she would have been a member of the proposed class, sought to intervene in the case to appeal the denial of class certification. The district court allowed her to intervene.The United States Court of Appeals for the Eleventh Circuit dismissed Curlee's appeal for lack of jurisdiction. The court found that there was no final decision as required by 28 U.S.C. § 1291 because the district court had not resolved the merits of any plaintiff's discrimination claims. The court held that Curlee, as an intervenor, must litigate her claims on the merits before she can appeal the denial of class certification. The court concluded that it lacked jurisdiction to hear Curlee's appeal because there was no final judgment in the case. View "Curlee v. AT&T Mobility Services, LLC" on Justia Law

The case revolves around an employment discrimination suit filed by Dr. Tara Loux against her former employers, BayCare Medical Group and St. Joseph’s Hospital. Dr. Loux sought to discover BayCare’s internal documents about the performance of other doctors who were not fired despite also committing errors. BayCare objected to disclosing certain documents, such as its “quality files” and “referral logs,” arguing that they were privileged under the Patient Safety and Quality Improvement Act of 2005. The Act creates a statutory privilege for work product prepared for or reported to patient safety organizations.The district court ordered BayCare to produce the disputed documents, concluding that the Act does not privilege documents if they have a “dual purpose,” only one of which relates to making reports to a patient safety organization. The court held that these documents were not privileged because BayCare used information in the documents for other purposes, such as internal safety analysis and peer review.The United States Court of Appeals for the Eleventh Circuit disagreed with the district court's interpretation of the Act. The appellate court found that the district court had applied an incorrect "sole purpose" standard to assess whether BayCare’s quality files and referral logs fell under the privilege. The court held that the Act does not require that privileged information be kept solely for provision to a Patient Safety Organization. The court granted BayCare's petition for a writ of mandamus, directing the district court to vacate its orders compelling the disclosure of the privileged documents and reconsider BayCare’s assertion of privilege consistent with the appellate court's opinion. View "In re: Baycare Medical Group, Inc." on Justia Law

Angela Poer, a white woman, was employed as an Administrative Services Manager by the Jefferson County Commission. She alleged that her supervisor, a black woman, discriminated against her based on her race. Poer claimed that her request for a lateral transfer or reassignment was denied and that she was ultimately terminated due to her race. She sought damages including reinstatement and back pay.The district court granted summary judgment in favor of the Commission, finding that Poer failed to present any evidence showing that she was terminated or discriminated against because of her race. The court also declined to consider Poer’s argument that the Commission’s employment decisions were forms of retaliation in response to her grievances, as this argument was raised for the first time at summary judgment.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The court found that Poer had not presented a convincing mosaic of circumstantial evidence that would support even an inference at summary judgment, let alone a jury finding at trial, that the Commission terminated her because of her race. The court also agreed with the district court that Poer could not raise a retaliation claim for the first time at summary judgment. View "Poer v. Jefferson County Commission" on Justia Law

The plaintiff, Tammie Terrell, an African-American nurse, applied for a Chief Nurse position at the James A. Haley Veterans’ Hospital but was not selected. She sued the Secretary of Veterans Affairs under Title VII, alleging race and national-origin discrimination, retaliation, and a discriminatory and retaliatory hostile work environment. The district court granted summary judgment for the Secretary on all counts.The United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court found that Terrell failed to provide evidence that her race or national origin was a but-for cause of her non-selection or that it tainted the hiring process. The court also found that Terrell did not engage in any protected Equal Employment Opportunity (EEO) activity that could form the basis for a retaliation claim. Furthermore, the court found that Terrell did not provide evidence that she experienced a hostile work environment due to her race, national origin, or EEO activity.Finally, the court affirmed the district court's denial of Terrell's Rule 60(b) motion for relief from judgment, finding that Terrell was attempting to relitigate her case and present evidence that she could have raised at the summary-judgment stage. View "Terrell v. Secretary, Department of Veterans Affairs" on Justia Law