Justia Labor & Employment Law Opinion Summaries

Aramark, a company that self-funds employee health benefit plans governed by ERISA, contracted with Aetna to serve as third-party administrator for these plans. Under the agreement, Aetna was responsible for processing claims, managing provider networks, and handling various administrative tasks. Aramark alleged that Aetna breached its fiduciary duties by paying improper or fraudulent claims, retaining undisclosed fees, providing inadequate subrogation services, making post-adjudication adjustments detrimental to Aramark, and commingling plan assets.Aramark filed suit in the United States District Court for the Eastern District of Texas, asserting ERISA claims for breach of fiduciary duty and prohibited transactions. Aetna responded by seeking to compel arbitration in a Connecticut federal district court, relying on the arbitration clause in the parties’ Master Services Agreement (MSA), and moved to stay the Texas proceedings pending arbitration. The district court denied the stay, holding that the parties had not “clearly and unmistakably” delegated the threshold question of arbitrability to an arbitrator. The court found that the MSA's arbitration clause carved out disputes seeking equitable relief—such as Aramark’s ERISA claims—from arbitration and that these claims were equitable in nature.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of a motion to stay litigation pending arbitration de novo. It held that the threshold issue of arbitrability was not clearly and unmistakably delegated to an arbitrator under the terms of the MSA, especially given the placement of the carve-out for equitable relief. The Fifth Circuit further held that Aramark’s ERISA claims constituted equitable, not legal, relief under Supreme Court and Fifth Circuit precedent. The Fifth Circuit affirmed the district court’s orders, finding no error or abuse of discretion. View "Aramark Services v. Aetna Life Insurance" on Justia Law

A former professional football player sought disability benefits from a retirement plan administered under the Employee Retirement Income Security Act (ERISA), arguing that he qualified for the highest tier of benefits due to multiple concussions suffered during his career. The plan granted him some benefits but denied the top category. He filed suit, claiming improper denial of benefits and lack of a full and fair review.The United States District Court for the Northern District of Texas ruled in favor of the plaintiff, ordering the plan to award the higher benefits and granting approximately $1.2 million in attorney’s fees, plus $600,000 in conditional fees. On appeal, however, a panel of the United States Court of Appeals for the Fifth Circuit reversed the district court’s judgment, holding that the plaintiff was not entitled to reclassification to the highest benefits tier due to his failure to immediately appeal the denial, making any further review futile. The panel remanded for entry of judgment for the plan.On remand, the district court nonetheless reaffirmed its prior fee award, reasoning that the plaintiff’s success in exposing flaws in the plan’s review process, as reflected in favorable factual findings, constituted sufficient success to support attorney’s fees.The United States Court of Appeals for the Fifth Circuit, reviewing the fee award for abuse of discretion, reversed the district court’s decision. The Fifth Circuit held that under 29 U.S.C. § 1132(g)(1), attorney’s fees may only be awarded if a party achieves “some degree of success on the merits,” which requires more than favorable factual findings or moral victories. Because the plaintiff received no relief—monetary, injunctive, or declaratory—the award of attorney’s fees was improper. The court reversed the fee award. View "Cloud v. NFL Player Retirement Plan" on Justia Law

A physician contracted with two medical staffing companies to provide emergency medicine services at certain hospitals. After raising concerns in late 2020 about allegedly fraudulent billing practices and the mismanagement of federal COVID-19 relief funds, the physician was told in early 2021 that her contracts would not be renewed unless she accepted a significant pay cut. In March 2021, she discovered that she was no longer scheduled for work. Attempts to seek clarification were unsuccessful, and in June 2021, she received a letter confirming her employment was considered terminated as of March 3, 2021.She filed suit in the Henrico County Circuit Court on April 1, 2022, alleging, among other claims, a violation of the Virginia Whistleblower Protection Act (VWPA) for retaliatory termination. The staffing companies demurred and then filed a plea in bar, arguing that her claim was time barred because the alleged retaliatory act occurred more than one year before she filed suit. The circuit court denied the plea in bar, and on interlocutory appeal, the Court of Appeals of Virginia affirmed. The Court of Appeals distinguished the case from Rivera v. Mantech International Corporation, reasoning that the physician was not given explicit notice of a definitive adverse employment action, and thus the statute of limitations did not begin to run in March 2021.The Supreme Court of Virginia reviewed the case and held that under the VWPA, the statute of limitations begins to run when the employer commits a prohibited retaliatory action—not when the employee feels its full impact or receives definitive notice. The Court found that removal from the work schedule in March 2021 constituted the prohibited action. As a result, the physician’s claim, filed more than one year later, was time barred. The Supreme Court of Virginia reversed the judgment of the Court of Appeals and remanded the case. View "Ingleside v. Hollis" on Justia Law

A fast-casual restaurant chain hired an individual with arthritis in her knees for a cashier/service-team member position. Prior to starting, she requested to be allowed to sit for five minutes after every ten minutes of standing, due to her medical condition. The restaurant required employees in her role to multitask and maintain mobility throughout their shifts, handling various duties such as operating the register, restocking, cleaning, and serving customers. The employer concluded that her requested accommodation would prevent her from performing essential job functions and did not permit her to begin work until the accommodation issue was resolved.The United States District Court for the Eastern District of Kentucky reviewed the case after the employee sued under the Americans with Disabilities Act (ADA) and the Kentucky Civil Rights Act (KCRA), alleging failure to accommodate her disability and failure to engage in the interactive process. The district court granted summary judgment to the employer, holding that the requested accommodation was not reasonable as a matter of law, and that her claim regarding the interactive process could not proceed without a viable accommodation claim.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the district court’s grant of summary judgment de novo. The appellate court affirmed, holding that the employee’s proposed accommodation—sitting for five minutes after every ten minutes of standing—was not objectively reasonable because it would fundamentally alter essential functions of the cashier/service-team member position, which required continuous mobility and multitasking. The court further held that, because no reasonable accommodation was shown, the claim arising from the employer’s alleged failure to engage in the interactive process also failed as a matter of law. The judgment of the district court was therefore affirmed. View "Bowles v. SSRG II, LLC" on Justia Law

An employee was hired by a security services company in 2012 and, as a condition of employment, signed an arbitration agreement requiring that any employment-related disputes be resolved through arbitration under the Federal Arbitration Act (FAA). In 2023, the employee was assigned to work at Oracle Park, where he was subjected to hostile and derogatory conduct by supervisors and coworkers based on his perceived sexual orientation, including intrusive questioning, mocking, and reduction of work hours. After formally complaining about this treatment, the employee was terminated. He then filed a lawsuit against his employer and two individuals, asserting multiple claims, including sexual harassment under California’s Fair Employment and Housing Act.The defendants sought to compel arbitration based on the prior agreement, arguing that all claims fell within its scope and that both federal and state law required enforcement. The plaintiff opposed the motion, challenging the agreement’s validity but not specifically referencing the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA). The Superior Court of the City and County of San Francisco issued a tentative ruling, later adopted as final, finding that the EFAA rendered the arbitration agreement unenforceable because the plaintiff stated a valid sexual harassment claim. The court further found that the EFAA barred arbitration of the entire case, not just the sexual harassment claim, and that the plaintiff’s conduct showed he elected to pursue his claims in court.On appeal, the California Court of Appeal, First Appellate District, Division Three, affirmed the trial court’s denial of the motion to compel arbitration. The court held that the EFAA applies to cases involving sexual harassment claims and bars enforcement of predispute arbitration agreements for the entire case at the plaintiff’s election, without requiring an explicit invocation of the EFAA. The court also held that the trial court properly considered the EFAA’s applicability and provided due process, even without supplemental briefing. View "Quilala v. Securitas Security Services USA" on Justia Law

Two individuals worked as delivery drivers for a transportation company for over a decade, primarily out of the company’s New Jersey terminal. Their work mainly involved picking up and delivering goods in New Jersey, with occasional deliveries in neighboring states. Each driver had a contract with the company that included a forum-selection clause requiring any disputes to be litigated in Memphis, Tennessee, and a choice-of-law clause providing that Tennessee law would govern any disputes. The company is incorporated in Delaware, headquartered in Illinois, and has operations nationwide, including in Tennessee, but neither the drivers nor the company’s relevant activities were based in Tennessee.The drivers filed a putative class action in the United States District Court for the District of New Jersey, alleging that the company violated New Jersey wage laws by withholding earnings and failing to pay overtime, among other claims. The case was transferred to the United States District Court for the Western District of Tennessee pursuant to the forum-selection clause. The company then moved to dismiss the complaint, arguing that the Tennessee choice-of-law provision applied and that Tennessee law did not recognize the claims brought under New Jersey statutes. The district court agreed, upheld the choice-of-law provision, and dismissed the case.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the enforceability of the choice-of-law provision under Tennessee’s choice-of-law rules. The court held that the contractual choice-of-law clause was unenforceable because there was no material connection between Tennessee and the transactions or parties. As a result, the Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. The court did not reach the question of whether Tennessee law was contrary to the fundamental policies of New Jersey. View "Andujar v. Hub Group Trucking, Inc." on Justia Law

The case centers on an employee who brought multiple claims against her former employer, including several for violations of California’s Labor Code and a representative claim under the Private Attorneys General Act (PAGA). The employee had signed an arbitration agreement at the start of her employment. As a result, all non-PAGA claims were compelled to arbitration, while the PAGA claims (both individual and representative) were stayed. The arbitrator found in favor of the employer on all Labor Code violations, concluding that the alleged violations did not occur.Following the arbitration, the Superior Court of San Bernardino County confirmed the arbitrator’s award and granted judgment on the pleadings against the employee on her PAGA claim, ruling that the arbitration results established she was not an “aggrieved employee” under PAGA, and therefore lacked standing to pursue the PAGA claim. When the employee appealed, the California Court of Appeal, Fourth Appellate District, Division Two, affirmed the denial of her motion to vacate the arbitration award but reversed the judgment on the pleadings as to the PAGA claim, holding that the arbitration did not preclude her from pursuing PAGA penalties.Subsequently, the employer filed a renewed motion for judgment on the pleadings, arguing that subsequent appellate court decisions and the California Supreme Court’s decision in Adolph v. Uber Technologies, Inc., constituted an intervening change in the law, rendering the law of the case doctrine inapplicable. The trial court denied this motion, finding that its prior ruling remained law of the case. Reviewing this denial, the California Court of Appeal, Fourth Appellate District, Division Two, held that the law of the case doctrine properly applied because there had been no controlling intervening change in the law. The court denied the employer’s writ petition, confirming that the arbitrator’s findings on non-PAGA claims did not preclude judicial determination of the employee’s standing under PAGA. View "Prime Healthcare Management v. Super. Ct." on Justia Law

A Black male employee worked as a sales representative for an insurance company, where he was required to obtain and maintain licenses to sell insurance in various states, including New York. He applied for a New York license but failed to respond to requests for information from the New York Department of Financial Services, resulting in the denial of his application. The denial was not timely communicated to the employer due to an internal error, which eventually led to corrective actions by the company. After the denial was discovered, the employee was informed that his continued employment in sales required the New York license. He was offered a chance to transfer to another department but was not selected for that position. Separately, the employee requested and was approved for intermittent FMLA leave, but he missed work for an extended period beyond what was approved. He was ultimately terminated for failing to obtain the required New York license and for not informing the company about the denial.The employee filed suit in the United States District Court for the District of Kansas, alleging retaliation under the FMLA and ADAAA, and race discrimination under Title VII and 42 U.S.C. § 1981. The district court granted summary judgment to the employer on all claims. It found the employee had not established a prima facie case of race discrimination and that he failed to provide sufficient evidence of pretext to support his retaliation claims, concluding the employer’s nondiscriminatory reason for termination was not shown to be false or a pretext for unlawful conduct.On appeal, the United States Court of Appeals for the Tenth Circuit agreed that the district court erred in its analysis of the prima facie case of race discrimination but found this error harmless. The appellate court held the employee failed to create a genuine issue of material fact as to pretext regarding both his discrimination and retaliation claims. Accordingly, the Tenth Circuit affirmed the district court’s grant of summary judgment in favor of the employer on all claims. View "Plump v. Government Employees Insurance Company" on Justia Law

The plaintiff was hired as a “Full Time Jewish Educator” at a religious institution and was responsible for teaching in religious classrooms, planning and attending religious events, and supporting the synagogue’s mission to develop a strong Jewish identity. Soon after starting her job, the plaintiff was confronted by a rabbi about her co-authorship of a blog post that was critical of Israel and Zionism. Although she assured the rabbi she would not share her personal views at work and was told her teaching abilities were not in question, she was terminated less than a week later.The plaintiff filed suit in New York Supreme Court, alleging that her dismissal violated Labor Law § 201-d(2)(c), which prohibits employers from taking adverse action against employees for engaging in legal recreational activities outside of work. The defendants moved to dismiss, arguing the claim failed because the activity was not protected, there was a material conflict with the employer’s interests, and the ministerial exception barred the claim. The Supreme Court granted the motion to dismiss, holding that the complaint failed to state a cause of action because the termination was for the content of the blog post, not the act of blogging itself, and did not address the other grounds for dismissal. The Appellate Division affirmed on the same basis and declined to reach the alternative arguments.The New York Court of Appeals affirmed the Appellate Division’s order, but on a different ground. The Court of Appeals held that, regardless of whether the plaintiff’s activity was protected under Labor Law § 201-d, the ministerial exception—which bars application of employment discrimination laws to the employment relationship between a religious institution and its ministers—applied. The plaintiff’s offer letter conclusively established that her core duties were religious in nature, and thus her claim was barred as a matter of law. View "Sander v. Westchester Reform Temple" on Justia Law

A firefighter employed by a county for over two decades reported safety violations concerning the maintenance of fire extinguishers on county fire engines. After raising these concerns with his superiors, he was barred from working in fire prevention, which he believed was retaliation for his whistleblowing activities. Although he filed internal complaints with the county’s Office of Human Resources and the Civil Service Commission, he withdrew his appeal after assurances that his concerns would be addressed. Later, he was investigated for alleged misconduct and ultimately terminated for violations of county rules. He then filed a claim under the Government Claims Act, which the county rejected.The Superior Court of Kern County granted the county’s motion for judgment on the pleadings, finding that the plaintiff’s failure to exhaust the internal administrative remedies—specifically, by not appealing his dismissal to the Civil Service Commission—barred his whistleblower retaliation lawsuit. The court denied the plaintiff’s request for leave to amend his complaint, holding that he could not allege exhaustion of remedies.The Court of Appeal of the State of California, Fifth Appellate District, reviewed the case. It held that the plaintiff was not required to exhaust the county’s internal administrative remedies before bringing his whistleblower retaliation claims because the county’s ordinances and rules did not provide a clearly defined process for submitting, evaluating, and resolving such claims. The court distinguished between general disciplinary appeals and procedures for discrimination or harassment claims, noting that there was no specific administrative remedy for whistleblower retaliation. Consequently, the appellate court reversed the judgment and remanded the matter with instructions to deny the county’s motion for judgment on the pleadings. The holding clarifies that, where an internal administrative process does not address a particular type of claim, exhaustion of that process is not required before filing suit. View "Romero v. County of Kern" on Justia Law