Justia Labor & Employment Law Opinion Summaries

In a case involving the Employee Retirement Income Security Act of 1974 (ERISA), a plan participant, Ian C., sought coverage for his son, A.C., to receive treatment at Catalyst Residential Treatment for mental health and substance abuse issues. UnitedHealthcare Insurance Company (United), the claims fiduciary for the plan, initially covered the treatment but subsequently denied coverage. Ian C. appealed this denial internally, a process in which United upheld its original decision. Ian C. then took his case to federal district court, alleging that United's denial violated his right to a "full and fair review" of his claim under ERISA. The district court ruled in favor of United.On appeal to the United States Court of Appeals for the Tenth Circuit, the court held that United's denial of benefits was arbitrary and capricious, violating ERISA regulations guaranteeing a "full and fair review" of claims. In particular, the court found that United had failed to consider A.C.'s substance abuse as an independent ground for coverage in their decision to deny benefits, in violation of their fiduciary duties under ERISA. The court therefore reversed the district court's decision. View "C., et al. v. United Healthcare Insurance Company" on Justia Law

In the case before the United States Court of Appeals for the Tenth Circuit, the plaintiff, Robert Hampton, sued his former employer, the Utah Department of Corrections (UDC), alleging violations of the Rehabilitation Act. Hampton, who was born without the second and fifth digits on both hands, claimed that UDC refused to accommodate his disability, treated him disparately based on that disability, and retaliated against him for requesting accommodation.Hampton, who had previously worked as a corrections officer in Arizona, was hired by UDC in 2016. He was required to qualify on UDC-approved firearms, including a Glock 17 handgun. Hampton requested an accommodation to use a different handgun, a Springfield 1911, due to difficulties he encountered in handling the Glock due to his disability. This request was denied, and Hampton was later terminated from his position.The Court of Appeals reversed the district court’s grant of summary judgment on Hampton's failure-to-accommodate claim and remanded for further proceedings. The court found that Hampton’s request for a different handgun could be considered a reasonable accommodation under the Rehabilitation Act, and that the district court erred in determining that using a Glock handgun was an essential function of Hampton’s job based solely on the UDC’s firearms policy.However, the court affirmed the district court’s grants of summary judgment on Hampton’s claims of disparate treatment and retaliation. It found that Hampton had not provided sufficient evidence to demonstrate that his disability was a determining factor in his termination or that his reassignment to a different position constituted an adverse employment action. View "Hampton v. Utah Department of Corrections" on Justia Law

Plaintiffs Carlie Sherman, Anna Gozun, and Amanda Nash appealed a district court’s denial of class certification in a forced labor action against Trinity Teen Solutions (“Trinity”), a residential treatment center for adolescent girls, and its owners and operators (collectively, “Defendants”). Plaintiffs, now adults, were all sent to Trinity as minors by their parents. Trinity advertised itself as offering a wide range of therapies for troubled adolescent girls in a ranch environment and as taking a "tough love" approach, with its residents living in primitive conditions and working on the ranch as part of their treatment experience. Plaintiffs alleged that, during their residence at Trinity, they were forced to work long hours without pay under threat of serious harm. Plaintiffs filed suit against Defendants, on behalf of themselves and a proposed class of former Trinity residents, bringing three forced labor claims under the Trafficking Victims Protection Reauthorization Act, and sought class certification pursuant to Federal Rule of Civil Procedure 23, proposing a putative class of “Plaintiffs, and all similarly situated persons who received treatment from [Trinity] and were subjected to the provision of ‘agricultural labor.’" The district court denied class certification, concluding Plaintiffs had failed to satisfy Rule 23’s commonality, typicality, and predominance requirements. After review, the Tenth Circuit concluded the district court erred by applying the incorrect legal standard to its analysis of Rule 23(a)’s commonality and typicality requirements and Rule 23(b)(3)’s predominance requirement. Therefore, it vacated the district court’s order denying class certification and remanded this case for further proceedings. View "Sherman, et al. v. Trinity Teen Solutions, et al." on Justia Law

Randy Quint, John Linn, and Mark Molina (“Colorado Plaintiffs”) filed a class and collective action against Vail Resorts, Inc. alleging violations of federal and state labor laws (“Colorado Action”). Different plaintiffs filed similar lawsuits against a Vail subsidiary, which were pending in federal and state courts in California. After Vail gave notice that it had agreed to a nationwide settlement with some of the other plaintiffs, Colorado Plaintiffs filed an emergency motion asking the district court to enjoin Vail from consummating the settlement. The district court denied their motion, and Colorado Plaintiffs filed this interlocutory appeal, arguing the district court erred by: (1) applying the wrong standard in reviewing the report and recommendation ("R&R"); (2) holding the Anti-Injunction Act applied to an injunction against Vail rather than the state court; (3) declining to consider one exception to the Anti-Injunction Act; (4) holding a second exception to the Anti-Injunction Act did not apply; (5) failing to enforce the first-to-file rule; and (6) abstaining under the Colorado River doctrine. Finding no reversible error, the Tenth Circuit affirmed. View "Quint, et al. v. Vail Resorts" on Justia Law

Plaintiffs brought two actions against KeyPoint Government Solutions: a collective action under the Fair Labor Standards Act (the FLSA) on behalf of KeyPoint employees nationwide, and a state-law putative class action on behalf of California employees. They alleged KeyPoint violated the FLSA through policies requiring employees to work uncompensated overtime and also violated certain provisions of California’s wage-and-hour laws. On appeal, KeyPoint argued: (1) the district court erred in denying KeyPoint’s motion to compel arbitration of California state-law claims by some California Plaintiffs; and (2) the district court erred in certifying under Fed. R. Civ. P. 23 of the California employee class. After review, the Tenth Circuit Court of Appeal reversed the district court’s denial of KeyPoint’s motion to compel arbitration, vacated the court’s certification of the Rule 23 class, and remanded for further proceedings. "The district court did not distinguish Plaintiffs’ meal- and rest-break claims from Plaintiffs’ off-the-clock claims. It analyzed only KeyPoint’s allegedly unlawful policy and assumed that the policy could 'prohibit[] Plaintiffs from taking required meal and rest breaks.' This was insufficient. ... The court abused its discretion in failing to perform claim-specific analysis. We vacate the district court’s Rule 23 class certification so that the district court can properly consider predominance." View "Brayman, et al. v. Keypoint Government Solutions" on Justia Law

Plaintiff-appellee Mark Wilson claimed his former employer, Schlumberger Technology Corporation, violated the Fair Labor Standards Act by classifying him as exempt from overtime pay for hours worked beyond the 40-hour workweek. At trial, the jury agreed with Wilson and awarded him nearly $40,000 in overtime backpay. After review, the Tenth Circuit concluded the district court should not have instructed the jury to determine whether Wilson’s salary was exempt under regulations guiding the application of the FLSA. "That was a legal issue for the court to determine." Because the instruction caused the jury to find in Wilson’s favor, the Court vacated the judgment and remanded for a new trial. View "Wilson v. Schlumberger Technology" on Justia Law

Plaintiff-appellee Gary Waetzig filed an age discrimination lawsuit against his former employer, Halliburton Energy Services, Inc. Because he was contractually bound to arbitrate his claim, he voluntarily dismissed his suit without prejudice under Federal Rule of Civil Procedure 41(a) and filed for arbitration. The arbitrator sided with Halliburton. Dissatisfied with the outcome, Waetzig returned to federal court. But instead of filing a new lawsuit challenging arbitration, he moved to reopen his age discrimination case and vacate the arbitration award. Relying on Rule 60(b), the district court concluded it had jurisdiction to consider Waetzig’s motion, reopened the case, and vacated the award. The Tenth Circuit found the district court erred: the district court could not reopen the case under Rule 60(b) after it had been voluntarily dismissed without prejudice. Under Federal Rules of Civil Procedure 41(a) and 60(b), a court cannot set aside a voluntary dismissal without prejudice because it is not a final judgment, order, or proceeding. View "Waetzig v. Halliburton Energy Services" on Justia Law

Plaintiff Alessandra Rogers worked for Chaves County in its jail. Several years into her employment, Rogers drafted a petition that criticized treatment of employees in the jail. The petition was signed by 45 current and former jail employees and was submitted to the county commissioners. Roughly a month after the petition was submitted, county employees searched the jail. During the search, employees found illegal drugs and weapons in a bag under Rogers’ desk. Rogers admitted that the bag was hers and that it contained the drugs and weapons. The county put Rogers on paid administrative leave. When the period of administrative leave ended, the county denied Rogers’ request for a promotion and imposed an unpaid five-day suspension. Rogers later quit. Rogers attributed the search to retaliation for her role in drafting the petition, claiming that the retaliation violated the First Amendment. But the district court granted summary judgment to the defendants. The court reasoned that even if the defendants had retaliated for Rogers’ role in drafting the petition, liability wouldn’t exist because the petition hadn’t involved a public concern. The Tenth Circuit concurred with the district court and affirmed. View "Rogers v. Riggs, et al." on Justia Law

Plaintiff-appellant Sharhea Wise worked as a mail carrier for the United States Postal Service. When she got pregnant, she asked to avoid handling heavy items. The Postal Service agreed to provide help when items were too heavy, but Wise needed to tell someone when she needed help. On two occasions, Wise allegedly had to handle items that were too heavy. Both times, she blamed the Postal Service for failing to accommodate her need for help. The Postal Service argued in response that Wise hadn’t asked for help. Days after Wise allegedly had to handle the heavy items, she walked off the job and the Postal Service fired her. Wise claimed retaliation, attributing the firing to her requests for help. The Postal Service denied retaliation, explaining that it had fired Wise because she walked off the job. Wise characterized this explanation as pretextual. The district court granted summary judgment to the Postal Service, and Wise challenged the rulings. The Tenth Circuit agreed with her challenge on the failure-to-accommodate claim. "On this claim, a reasonable factfinder could find that the Postal Service had failed to accommodate Ms. Wise’s need to avoid handling heavy items." But the Court agreed with the grant of summary judgment on the retaliation claim because: (1) the Postal Service presented a neutral, nonretaliatory explanation for the firing; and (2) Wise lacked evidence of pretext. View "Wise v. DeJoy" on Justia Law

Plaintiff National Nurses Organizing Committee, Missouri & Kansas/National Nurses United filed a grievance and sought arbitration under the grievance procedure set forth in the parties’ collective bargaining agreement (“CBA”). Defendant Midwest Division MMC, LLC refused to arbitrate. Although Plaintiff and Defendant agreed to arbitrate disputes under many provisions of their CBA, the Tenth Circuit Court of Appeal found "with positive assurance" the parties did not intend to arbitrate disagreements related to staffing plans. And, at its core, the dispute between Plaintiff and Defendant was about a staffing plan. The Court applied the presumption of arbitrability “only where a validly formed and enforceable arbitration agreement is ambiguous about whether it covers the dispute at hand.” The Court found parties did not consent to arbitrate the kind of dispute Plaintiff’s grievance asserted and affirmed the grant of summary judgment in favor of Defendant. View "National Nurses Organizing v. Midwest Division MMC" on Justia Law