Justia Labor & Employment Law Opinion Summaries

Amanda Jackson, a healthcare worker, filed a lawsuit against her former employer, Methodist Health Services, after being placed on unpaid leave and subsequently discharged for refusing to be vaccinated for Covid-19 or undergo weekly testing. Jackson claimed that Methodist discriminated against her based on her religion, violating Title VII of the Civil Rights Act of 1964, by not accommodating her religious objections to the vaccine.The United States District Court for the Central District of Illinois dismissed Jackson's complaint for failure to state a claim. The court found that Methodist had granted Jackson a religious exemption from the vaccine requirement, conditioned on her compliance with weekly Covid-19 testing, as mandated by an executive order from Illinois Governor J.B. Pritzker. Jackson refused to comply with the testing requirement, leading to her unpaid leave and discharge. The court concluded that Methodist had reasonably accommodated Jackson's religious beliefs by granting the exemption and that the testing requirement did not burden her religious practices.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's dismissal. The appellate court held that Methodist had reasonably accommodated Jackson's religious beliefs by exempting her from the vaccine mandate and requiring weekly testing, which was consistent with the governor's executive order. The court also rejected Jackson's claim under the Illinois Department of Public Health Act, finding that Methodist, as a private employer, was not exercising powers granted to the Department and was acting within its authority to set workplace safety rules. The court concluded that Jackson failed to state a claim for relief under both Title VII and the Illinois Department of Public Health Act. View "Jackson v. Methodist Health Services Corporation" on Justia Law

The case involves the Association for Los Angeles Deputy Sheriffs (ALADS) challenging the County of Los Angeles and its Office of the Inspector General (OIG) over the implementation of Penal Code sections 13670 and 13510.8. These sections, effective January 1, 2022, mandate law enforcement agencies to prohibit participation in law enforcement gangs and cooperate with investigations into such gangs. The OIG sent letters to 35 deputies, directing them to participate in interviews about their knowledge of and involvement in law enforcement gangs, and to display and provide photographs of gang-associated tattoos.The Los Angeles County Employee Relations Commission (ERCOM) had previously ruled that the County violated the Employee Relations Ordinance (ERO) by not negotiating the effects of a new ordinance with ALADS. ALADS filed an unfair labor practice claim with ERCOM and sought injunctive relief from the trial court to enjoin the OIG from proceeding with the interviews without first meeting and conferring with ALADS under the Meyers-Milias-Brown Act (MMBA) and the ERO.The Superior Court of Los Angeles County granted a preliminary injunction, concluding that the interview directive triggered the duty to meet and confer with ALADS under the MMBA. The court found that the interviews had significant and adverse effects on working conditions, particularly concerning potential disciplinary actions, and that the County failed to demonstrate a compelling need for immediate investigation without prior negotiation.The California Court of Appeal, Second Appellate District, Division Five, affirmed the trial court's order. The appellate court agreed that the OIG's decision to conduct interviews was a managerial decision but that the effects of this decision, including potential discipline and the manner of implementation, were subject to bargaining under the MMBA. The court found no error in the trial court's balancing of the interim harm, noting the lack of evidence suggesting that effects bargaining could not be performed expeditiously. View "Assn. for L.A. Deputy Sheriffs v. County of L.A." on Justia Law

Five current and former employees of Parker-Hannifin Corporation, representing a class of participants in the Parker Retirement Savings Plan, filed a lawsuit against Parker-Hannifin Corporation and related entities. They alleged that Parker-Hannifin violated the Employee Retirement Income Security Act of 1974 (ERISA) by imprudently retaining the Northern Trust Focus Funds, providing higher-cost shares, and failing to monitor its agents in their fiduciary duties.The United States District Court for the Northern District of Ohio dismissed the plaintiffs' claims. The court found that the plaintiffs did not state a viable claim of breach of fiduciary duty because they failed to identify meaningful benchmarks for comparison, and their evidence of high turnover rates and limited performance history was insufficient. The court also found the plaintiffs' allegations regarding higher-cost shares to be speculative and conclusory. Consequently, the court dismissed the failure-to-monitor claim as it was contingent on the success of the other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's judgment. The appellate court held that the plaintiffs sufficiently pleaded facts to state a claim for imprudent retention of the Focus Funds, noting that the funds' high turnover rates and underperformance could indicate a flawed decision-making process. The court also found that the plaintiffs plausibly alleged that Parker-Hannifin failed to negotiate for lower-cost shares, which could constitute a breach of the duty of prudence. The court remanded the case for further proceedings consistent with its opinion. View "Johnson v. Parker-Hannifin Corp." on Justia Law

Marlon Quesada, a deputy sheriff with the Los Angeles County Sheriff's Department, was not promoted to sergeant despite taking the sergeant's examination in 2017 and 2019, scoring in band two and band one, respectively. Quesada had a mixed employment record, including two suspensions for misconduct and a 2015 investigation that was terminated due to a statute of limitations. Quesada claimed the Department improperly considered this time-barred investigation during the promotion process, which he argued was illegal.The Superior Court of Los Angeles County denied Quesada's petition for a writ of mandate, which sought to compel the Department to promote him and provide back pay and other damages. The trial court rejected Quesada's argument for a burden-shifting approach, similar to that used in discrimination cases, and found that Quesada did not establish that the Department's decision was illegal.The California Court of Appeal, Second Appellate District, reviewed the case. The court affirmed the trial court's decision, holding that the standard approach to civil litigation applies, where the plaintiff bears the burden of proving the elements of their claim by a preponderance of the evidence. The court declined to adopt a burden-shifting approach, noting that Quesada's case did not involve discrimination based on race or membership in a historically oppressed group. The court also found substantial evidence supporting the Department's decision, including Quesada's mediocre performance evaluations and past misconduct. The court concluded that Quesada's policy arguments did not justify a departure from the standard legal approach. View "Quesada v. County of L.A." on Justia Law

Ngozi Iweha, a Black woman born and educated in Nigeria, was hired as a staff pharmacist at Larned State Hospital (LSH) in Kansas. She alleged that she faced a hostile work environment, disparate treatment, and retaliation in violation of Title VII. Incidents included exclusion from projects, insensitive comments about Nigeria, and a confrontation with a coworker involving "slave trade beads." She was eventually placed on administrative leave and terminated following an investigation into her workplace conduct.The United States District Court for the District of Kansas granted summary judgment in favor of the defendants. The court found that the incidents described by Iweha did not amount to a hostile work environment as they were not sufficiently severe or pervasive. The court also determined that Iweha failed to show that her termination was pretextual. The court noted that the employer's progressive discipline policy was discretionary and that the investigation into Iweha's conduct was independent and thorough. Additionally, the court found that Iweha did not establish a prima facie case of retaliation, as her complaints did not specifically allege discrimination based on race or national origin.The United States Court of Appeals for the Tenth Circuit affirmed the district court's judgment. The appellate court agreed that the incidents described by Iweha were not severe or pervasive enough to create a hostile work environment. The court also found that Iweha failed to demonstrate that the reasons for her termination were pretextual. The court noted that the investigation into her conduct was independent and that the decision to terminate her was based on legitimate, non-discriminatory reasons. The court also upheld the finding that Iweha did not establish a prima facie case of retaliation. View "Iweha v. State of Kansas" on Justia Law

Gloria Cocuzzo, a long-term employee of Trader Joe's East Inc., claimed she was terminated due to age discrimination. Cocuzzo, who began working at Trader Joe's in 2003 and was promoted to Merchant in 2012, received positive performance reviews and regular pay increases. In February 2021, she purchased beer for her underage grandson, also an employee at the store. This incident was reported to her supervisor, Jennifer Gillum, who, after consulting with a regional vice president, decided to terminate Cocuzzo. Cocuzzo was given the option to retire but was ultimately terminated when she refused to sign a termination notice.The United States District Court for the District of Massachusetts granted summary judgment in favor of Trader Joe's and Gillum, finding no evidence of age discrimination. The court held that Trader Joe's had a legitimate, non-discriminatory reason for terminating Cocuzzo, namely her violation of the store's alcohol policy by purchasing alcohol for an underage individual. The court also found that Cocuzzo failed to provide sufficient evidence to show that this reason was a pretext for age discrimination.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Trader Joe's had a legitimate reason for terminating Cocuzzo and that she did not provide adequate evidence to prove that this reason was a pretext for age discrimination. The court also found that the evidence presented by Cocuzzo, including her positive performance reviews and the treatment of other employees, did not support her claims of disparate treatment or discriminatory animus. Consequently, the court upheld the summary judgment in favor of Trader Joe's and Gillum. View "Cocuzzo v. Trader Joe's East Inc." on Justia Law

A Transportation Security Officer (TSO) claimed she was terminated due to her disability, gender, and parental status, and alleged retaliation for filing complaints with the Equal Employment Opportunity Commission (EEOC). Her employer, the Transportation Security Administration (TSA), attributed her termination to her erratic attendance, including numerous tardies and unscheduled absences, despite multiple warnings.The United States District Court for the District of Puerto Rico granted summary judgment in favor of TSA on all claims. The court found that the plaintiff failed to provide sufficient evidence to support her claims of discrimination and retaliation. Specifically, the court noted that the plaintiff's attendance issues persisted even when she was on a modified work schedule and that TSA had legitimate, nondiscriminatory reasons for its actions.On appeal, the United States Court of Appeals for the First Circuit reviewed the case de novo. The court assumed, without deciding, that the plaintiff could establish a prima facie case of discrimination and retaliation. However, it found that TSA had provided legitimate, nondiscriminatory reasons for its actions, including the plaintiff's chronic absenteeism and failure to follow leave procedures. The court concluded that the plaintiff failed to show that these reasons were pretextual or that TSA's actions were motivated by discriminatory or retaliatory animus.The First Circuit affirmed the district court's grant of summary judgment for TSA on all counts, holding that the plaintiff did not meet her burden to create a genuine issue of material fact regarding pretext and discriminatory or retaliatory intent. View "Serrano-Colon v. Dep't of Homeland Security" on Justia Law

Amanda Shrewsbury, the respondent, was employed as a teacher’s aide in a pre-kindergarten classroom at Cumberland Heights Elementary School during the 2018-2019 school year. She reported witnessing abuse and neglect of students by the classroom teacher, Alma Belcher, to the school principal, Steve Hayes, and later to the superintendent, Dr. Deborah Akers. Following her complaints, Shrewsbury alleges that her employment was terminated. She subsequently filed a lawsuit against the Mercer County Board of Education, Dr. Akers, and others, claiming wrongful discharge and other related grievances.The Circuit Court of Mercer County reviewed the case and denied the petitioners' motion for summary judgment, which was based on the assertion of qualified immunity. The court found that the petitioners were not entitled to qualified immunity under the circumstances presented.The Supreme Court of Appeals of West Virginia reviewed the case and affirmed the lower court's decision. The court held that the petitioners, as a political subdivision and an employee of a political subdivision, were not entitled to qualified immunity solely because the claims against them fell within the exceptions to statutory immunity set forth in the West Virginia Governmental Tort Claims and Insurance Reform Act. The court clarified that the mere inapplicability of the Tort Claims Act due to specific exemptions does not permit the petitioners to claim qualified immunity. Therefore, the circuit court's denial of the motion for summary judgment on the basis of qualified immunity was upheld. View "Mercer County Board of Education v. Shrewsbury" on Justia Law

Donna Glaesener, a black woman, has worked at the Port Authority Trans-Hudson Corporation for nearly thirty years. In April 2018, she complained to the human-resources department about a lack of diversity and alleged discrimination in promotional decisions. She subsequently applied for several promotions but was not selected. In December 2018, she filed a formal EEOC complaint alleging discrimination. In November 2019, she sued the Port Authority, claiming she was denied promotions due to her race and in retaliation for her complaints and lawsuit.The United States District Court for the District of New Jersey granted summary judgment in favor of the Port Authority. The court applied the Title VII burden-shifting framework from McDonnell Douglas Corp. v. Green and found that the Port Authority had legitimate, non-discriminatory, and non-retaliatory reasons for not promoting Glaesener. The court concluded that Glaesener failed to show these reasons were pretexts for discrimination or retaliation.The United States Court of Appeals for the Third Circuit reviewed the case de novo, considering all facts and reasonable inferences in Glaesener's favor. The court found no evidence supporting Glaesener's claims of discrimination or retaliation. For the Safety Manager position, the successful candidate had significantly more relevant experience. For the Chief Operations Examiner position, the successful candidate had a higher interview score, and the interview process was deemed legitimate and job-related. Similarly, for the Principal Programs & Training Coordinator and Superintendent of Transportation positions, the successful candidates were more qualified and performed better in interviews.The Third Circuit affirmed the District Court's decision, holding that the Port Authority's reasons for not promoting Glaesener were legitimate and not pretextual. View "Glaesener v. New York & New Jersey Port Authority" on Justia Law

Angelo Brock, an independent distributor for Flowers Baking Co. of Denver, LLC, filed a class-action lawsuit alleging wage and hour violations under the Fair Labor Standards Act and Colorado labor law. Brock claimed that Flowers misclassified its delivery drivers as independent contractors to avoid paying proper wages. Flowers moved to compel arbitration based on an Arbitration Agreement within the Distributor Agreement between Brock and Flowers. The district court denied the motion, leading to this appeal.The United States District Court for the District of Colorado found that Brock fell within the "transportation workers exemption" under § 1 of the Federal Arbitration Act (FAA), which exempts certain transportation workers from arbitration. The court concluded that Brock's class of workers, who deliver Flowers goods intrastate, are engaged in interstate commerce because they play a direct and necessary role in the flow of goods across state lines. The court also determined that the Arbitration Agreement did not allow for arbitration under Colorado law, as it was inconsistent with the FAA.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The Tenth Circuit agreed that Brock's class of workers is engaged in interstate commerce, as their intrastate deliveries are part of a continuous interstate journey of goods. The court found that Flowers retains significant control over Brock's operations, indicating that the goods' delivery to retail stores is the final leg of an interstate route. The court declined to review Flowers's argument that the Distributor Agreement is not a contract of employment, as it was not raised in the lower court. Additionally, the court determined it lacked jurisdiction to review the district court's denial of arbitration under Colorado law. View "Brock v. Flowers Foods" on Justia Law