Justia Labor & Employment Law Opinion Summaries

Articles Posted in US Court of Appeals for the Seventh Circuit
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The Equal Employment Opportunity Commission (EEOC) brought a Title VII employment discrimination action on behalf of black employees of Village at Hamilton Pointe, LLC, a long-term care facility in Indiana. The EEOC alleged that Hamilton Pointe and Tender Loving Care Management, LLC (TLC), which provides services to Hamilton Pointe, subjected the employees to racial harassment. The district court granted TLC’s motion for summary judgment with respect to some of the employees, ruling that TLC could not be considered an employer under Title VII. The court also granted Hamilton Pointe’s motion for partial summary judgment with respect to the claims of forty employees. Seven remaining employees proceeded to a jury trial, with damages awarded to one employee. The EEOC appealed the grant of summary judgment for TLC and Hamilton Pointe, and the jury’s verdict.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The court found that the EEOC failed to establish that the employees were subjected to a racially hostile work environment that was so severe or pervasive as to alter the conditions of their employment. The court also found that the EEOC failed to establish that TLC was a joint employer of the claimants. The court emphasized that the federal law governing racial harassment proscribes conduct that is so severe or pervasive as to change the conditions of the victim’s employment, but does not ensure that the worker will have wise and skilled superiors with a sharply honed sense of social justice and a mastery of personnel management skills. View "EEOC v. Village at Hamilton Pointe LLC" on Justia Law

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Donald Artz, an electric distribution controller at WEC Energy Group, retired due to multiple sclerosis (MS) and sought long-term disability benefits from a plan administered by Hartford Life and Accident Insurance Company. Hartford denied his claim, asserting that Artz was not "disabled" within the plan's definition. Artz filed a lawsuit under the Employee Retirement Income Security Act, alleging that Hartford's disability determination was arbitrary and capricious because it misconstrued the plan's terms and failed to provide a reasonable explanation for its decision.The case was initially heard in the United States District Court for the Eastern District of Wisconsin. The district court upheld the denial of benefits at summary judgment, concluding that Artz had placed too much emphasis on the duties of his specific position at WEC rather than the "essential duties" of his job in the general workplace as required by the company’s plan. The court also underscored the independent medical reviews commissioned by Hartford and found the medical evidence supported the conclusion that Artz’s MS did not prevent him from working a standard 40-hour week as a power-distribution engineer.The case was then appealed to the United States Court of Appeals for the Seventh Circuit. The appellate court affirmed the district court's decision, finding that Hartford had communicated rational reasons for its decision based on a fair reading of the plan and Artz’s medical records. The court concluded that the plan administrator provided sufficient process and that the Employee Retirement Income Security Act requires no more. The court noted that while Artz's condition was serious, the evidence did not show that the severity and persistency of his symptoms resulted in functional impairment as defined by the policy. View "Artz v. Hartford Life & Accident Insurance Company" on Justia Law

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Monica Rongere, a former Diversity Procurement Officer for the City of Rockford, Illinois, sued the city after her employment was terminated. Rongere claimed that she was overworked and underpaid compared to her male colleagues, and that her termination was due to her complaints about this disparity. She brought claims under the Equal Pay Act, Title VII of the Civil Rights Act of 1964, the Illinois Human Rights Act, the Illinois Whistleblower Act, and Illinois common law, alleging equal pay, sex discrimination, hostile work environment, and retaliation.The district court ruled in favor of the City on the Equal Pay Act, Title VII, and Illinois Human Rights Act claims, and relinquished jurisdiction over the remaining state-law claims. Rongere appealed this decision.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that Rongere failed to identify adequate comparators for her equal pay and sex discrimination claims, did not show that she engaged in protected activity based on an objectively reasonable belief for her retaliation claim, did not present sufficient evidence of a hostile work environment, and did not explain how the district court abused its discretion in relinquishing jurisdiction over the remaining claims. The court also found that Rongere did not hold an objectively reasonable belief that the City paid male employees more than female employees for the same work, which was necessary for her retaliation claims. View "Rongere v. City of Rockford" on Justia Law

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The case involves Appvion, Inc., a Wisconsin-based paper company, which was sold to its employees through an Employee Stock Ownership Plan (ESOP) in 2001. The company declared bankruptcy in 2017. Grant Lyon, acting on behalf of the ESOP, filed a lawsuit against various individuals and corporations, alleging that they fraudulently inflated the price of Appvion in 2001 and that the price remained inflated until Appvion’s bankruptcy. The district court dismissed almost all the claims.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the dismissal of some claims and reversed and remanded others. The court affirmed the dismissal of claims related to actions before November 26, 2012, as they were time-barred under the Employee Retirement Income Security Act (ERISA). However, the court reversed the dismissal of claims related to actions after November 26, 2012, finding that the plaintiff had adequately alleged that the defendants breached their fiduciary duties under ERISA by failing to ensure that the company's valuations were sound. The court also reversed the dismissal of claims alleging that the defendants engaged in prohibited transactions and co-fiduciary liability. The court affirmed the dismissal of state-law claims against the defendants, finding them preempted by ERISA. View "Appvion, Inc. Retirement Savings and Employee Stock Ownership Plan v. Buth" on Justia Law

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The case involves Songie Adebiyi, a former Vice President of Student Services at South Suburban College in Illinois, who was terminated in 2019 due to alleged performance issues. Adebiyi claimed that her termination was in retaliation for filing a charge with the United States Equal Employment Opportunity Commission and the Illinois Department of Human Rights. She sued the college and its president, alleging racial discrimination and retaliation under 42 U.S.C. § 1981 and Title VII of the Civil Rights Act of 1964, as well as breach of contract.The United States District Court for the Northern District of Illinois granted summary judgment to the college and its president, ruling that Adebiyi failed to show a causal link between her charge of discrimination and her termination. The court found that the evidence did not support Adebiyi’s retaliation claim. Adebiyi appealed the decision, arguing that the district court erred in dismissing her Title VII retaliation claim and abused its discretion when it denied her motion to amend the complaint and seek more discovery.The United States Court of Appeals for the Seventh Circuit affirmed the judgment of the district court. The appellate court agreed with the lower court's finding that Adebiyi failed to demonstrate a causal link between her protected activity and the adverse employment action. The court found no evidence of pretext in the college's reasons for termination or suspicious timing between Adebiyi's filing of her EEOC and IDHR charge and her termination. The court also found no abuse of discretion in the district court's denial of Adebiyi's motion to file an amended complaint and take additional discovery. View "Adebiyi v. South Suburban College" on Justia Law

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This case involves a dispute between Zhen Feng Lin, a food delivery driver who was severely injured in a car accident, and his employer's insurance company, Hartford Accident and Indemnity Company. After the accident, Lin received a settlement from the at-fault driver's insurance company, and workers' compensation benefits from his employer's insurance carrier, Hartford Fire Insurance Company. Lin later sought additional recovery under his employer's underinsured motorist policy with Hartford Accident.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision that Lin and Hartford Accident had not entered into a "settlement agreement" as defined by the insurance policy. As a result, the court ruled that the policy limits should be reduced by the amount Lin received in workers' compensation benefits. The court also agreed with the district court that Lin should be credited for the amount he paid to settle the workers' compensation lien.Additionally, the court affirmed the district court's dismissal of Lin's counterclaims for bad faith and breach of contract. The court found no plausible claim supporting the argument that Hartford Accident unreasonably delayed settling Lin's claim. Lin's request for statutory penalties for Hartford Accident's purported delay in handling his claim was also denied.Finally, the court denied both parties' motions for sanctions. Lin's appeal was deemed frivolous in part, but the court exercised its discretion not to impose sanctions. View "Hartford Accident and Indemnity Company v. Lin" on Justia Law

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The United States Court of Appeals for the Seventh Circuit heard an appeal from Bulk Transport Corp. against Teamsters Union No. 142 Pension Fund and its Trustees. The dispute originated from two collective-bargaining agreements between Bulk Transport and Teamsters Local 142, active from 2003 to 2006. The Union insisted that Bulk Transport apply one such agreement, the Steel Mill Addendum, to non-steel mill work (LISCO work), which Bulk Transport initially did, subsequently making pension contributions on behalf of the LISCO workers. However, when Bulk Transport lost the LISCO contract, they ceased these contributions, leading to the Pension Fund assessing a withdrawal liability of about $2 million under the Multiemployer Pension Plan Amendments Act (MPPAA).After arbitration, Bulk Transport paid but demanded a review of the decision. The district court agreed with the arbitrator's ruling that Bulk Transport had adopted the Addendum by conduct, and thus the Pension Fund was entitled to the withdrawal liability. The district court also denied Bulk Transport's request for a refund.The Seventh Circuit, however, reversed the district court's decision. It held that the written agreement, not the practice or conduct, should dictate the terms of pension contributions to multi-employer plans. The written agreement in this case did not cover the LISCO work, and the court rejected the argument that Bulk Transport's conduct altered the substantive terms of the agreement. The court held that the writings were conclusive and that employers and unions could not opt-out of the requirements orally or through their course of conduct. The court affirmed the district court's denial of attorney's fees for the Pension Fund and remanded the case with instructions to order the Pension Fund to repay the withdrawal liability it collected from Bulk Transport. View "Bulk Transport, Corp. v. Teamsters Union Local 142" on Justia Law

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The case involves Janay Garrick, a former instructor at Moody Bible Institute, who alleged sex discrimination and other Title VII violations. Garrick claimed that she was subjected to hostile treatment due to her gender and the Institute's religious beliefs. Moody argued that her suit was barred by Title VII’s religious exemptions and the First Amendment doctrine of church autonomy. The district court denied Moody's motion to dismiss in part, leading to Moody's appeal.However, the United States Court of Appeals for the Seventh Circuit dismissed the appeal for lack of jurisdiction. The court reasoned that it could only review a small class of interlocutory orders under the collateral order doctrine, and Moody's appeal did not fit within this class. The court found that the district court's denial of Moody's motion to dismiss was not conclusive, did not resolve important questions separate from the merits of the case, and would not effectively be unreviewable on appeal from a final judgment.The appellate court also emphasized that Moody's defense, based on the doctrine of church autonomy, was not separate from the merits of Garrick's gender discrimination claims. Furthermore, the court noted that Moody's argument that it would experience irreparable harm without immediate review was unavailing, as the district court could limit discovery to instances of discriminatory treatment not implicated by Moody's religious beliefs. The court concluded that religious autonomy to shape and control doctrine would not be threatened by the further progression of Garrick's lawsuit. View "Garrick v. Moody Bible Institute" on Justia Law

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This case was brought before the United States Court of Appeals For the Seventh Circuit by plaintiffs John Brooks and Gregory Simmons against the City of Pekin and four of its employees. Brooks, a former police lieutenant who developed sleep apnea, claimed that the City violated the Americans with Disabilities Act by failing to reasonably accommodate his condition, discriminating against him, and retaliating against him for raising complaints. Simmons, a former police officer, alleged retaliation under Title VII of the Civil Rights Act of 1964 for reporting sexually harassing comments made by his former boss. The district court had granted summary judgment in favor of the defendants.The Court of Appeals affirmed the lower court's decision. The Court found that Brooks failed to show that the City had not offered him reasonable accommodations for his sleep apnea. The Court also ruled that Brooks could not establish disparate treatment because he failed to identify similarly situated employees who received more favorable treatment. Furthermore, Brooks was unable to prove retaliation because he lacked evidence that the City's reason for disciplining him was pretextual.Regarding Simmons, the Court found that he could not establish a claim for retaliation under Title VII because the inappropriate comments made about him were not because of his sex and were not severe or pervasive enough to create an abusive working environment. Moreover, Simmons could not show that his termination was due to his complaints against his former boss. The Court also noted that the district court did not err in denying the plaintiffs' request to amend their summary judgment response. The Court declined the City's request to impose sanctions on Brooks and Simmons, reasoning that their appeal was not frivolous. View "Brooks v. City of Pekin" on Justia Law

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In the case before the United States Court of Appeals for the Seventh Circuit, the plaintiff, Candice Martin, represented herself and the estate of her deceased husband, Rodney Martin. The defendants were Goodrich Corporation and PolyOne Corporation, both of which Rodney had worked for. Rodney had been exposed to a hazardous chemical, vinyl chloride monomer (VCM), during his employment and was later diagnosed with angiosarcoma of the liver, a disease allegedly linked to VCM exposure.The case revolved around the interpretation and application of the Illinois Workers' Occupational Diseases Act (ODA), which provides compensation for employees who contract diseases through their employment. The Act also has an exclusivity provision, which restricts employees from seeking compensation outside of the statutory scheme.The plaintiff argued that her claim was not subject to the ODA's exclusivity provisions due to an exception introduced by the Illinois legislature in 2019, which allows claims to proceed outside the ODA if they would be barred by any period of repose or repose provision. The defendants argued that this exception did not apply in this case, as Rodney's exposure to VCM had occurred decades prior to the enactment of the exception.Due to the complexity of the statutory provisions and the implications of their interpretation, the Court of Appeals decided to certify three questions to the Illinois Supreme Court. The questions pertained to whether a specific provision of the ODA constituted a period of repose, whether the 2019 exception applied retrospectively, and whether the application of this exception to past conduct would violate the due process protections of the Illinois Constitution. View "Martin v. Goodrich Corporation" on Justia Law