Justia Labor & Employment Law Opinion Summaries

NCR Corporation established five “top hat” retirement plans to provide supplemental life annuity benefits to senior executives. Each plan promised participants a fixed monthly payment for life, with language allowing NCR to terminate the plans so long as no action “adversely affected” any participant’s accrued benefits. In 2013, NCR terminated the plans and paid participants lump sums it claimed were actuarially equivalent to the promised annuities, using mortality tables, actuarial calculations, and a 5% discount rate. NCR knew that, statistically, about half of the participants would outlive the lump sums if they continued to withdraw the same monthly benefit, resulting in some participants receiving less than they would have under the original annuity.Participants filed a class-action lawsuit in the United States District Court for the Northern District of Georgia, alleging breach of contract and seeking either replacement annuities or sufficient cash to purchase equivalent annuities. The district court certified the class and granted summary judgment for the participants, finding that NCR’s lump-sum payments adversely affected the accrued benefits of at least some participants, in violation of the plan language. The court ordered NCR to pay the difference between the lump sums and the cost of replacement annuities, plus prejudgment and postjudgment interest.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the district court’s summary judgment order de novo. The Eleventh Circuit held that the plan language was unambiguous and did not permit NCR to unilaterally replace life annuities with lump sums that reduced the value of accrued benefits for any participant. The court affirmed the district court’s judgment, including the remedy of requiring NCR to pay the cost of replacement annuities and awarding prejudgment interest. View "Hoak v. NCR Corp." on Justia Law

An employee at a meatpacking plant in Texas died after contracting COVID-19, allegedly from a coworker who continued working after testing positive. The decedent’s family sued the plant manager, the safety manager, and the coworker in Texas state court, claiming negligence and gross negligence due to unsafe working conditions and inadequate precautions against COVID-19. The complaint alleged that the employer, Tyson Foods, failed to protect employees, and that the managers were responsible for workplace safety. The coworker was accused of coming to work and failing to take precautions after testing positive.The defendants removed the case to the United States District Court for the Eastern District of Texas, arguing that the Texas-based managers were improperly joined to defeat diversity jurisdiction. The district court agreed, dismissed the claims against the managers with prejudice, and denied the plaintiffs’ motion to remand. Tyson Foods was later added as a defendant. The district court then dismissed the claims against Tyson on the grounds that they were preempted by the Poultry Products Inspection Act (PPIA), and dismissed the claims against the coworker for failure to state a claim, finding no individual duty to prevent the spread of disease under Texas law. The court denied leave to amend the complaint as futile and entered final judgment.The United States Court of Appeals for the Fifth Circuit reviewed the case. It affirmed the district court’s denial of the motion to remand and the dismissal of the coworker, holding that the managers were improperly joined and that Texas law does not impose an individual duty on coworkers to prevent the spread of disease. However, the Fifth Circuit reversed the dismissal of the claims against Tyson, holding that the PPIA does not preempt state law negligence claims based on workplace safety unrelated to food adulteration. The court vacated the denial of leave to amend and remanded for further proceedings. View "Williams v. Wingrove" on Justia Law

Two employees of a debt-collection firm, one of whom was out sick with COVID-19, collaborated to resolve an urgent licensing issue for their employer. The employee at home, unable to access her work computer, asked her colleague to log in using her credentials and retrieve a spreadsheet containing passwords for various company systems. The colleague, with express permission, accessed the computer and emailed the spreadsheet to the employee’s personal and work email accounts. Both actions violated the employer’s internal computer-use policies. Separately, the employee at home had, over several years, moved accounts into her workgroup to receive performance bonuses, believing she was eligible for them. Both employees also alleged persistent sexual harassment at work, which led to internal complaints, one employee’s resignation, and the other’s termination.After these events, the employer, National Recovery Agency (NRA), sued both employees in the United States District Court for the Middle District of Pennsylvania, alleging violations of the Computer Fraud and Abuse Act (CFAA), federal and state trade secrets laws, civil conspiracy, breach of fiduciary duty, and fraud. The employees counterclaimed for sexual harassment and related employment claims. On cross-motions for summary judgment, the District Court entered judgment for the employees on all claims brought by NRA, finding no violations of the CFAA or trade secrets laws, and stayed the employees’ harassment claims pending appeal.The United States Court of Appeals for the Third Circuit reviewed the case. It affirmed the District Court’s judgment in full. The Third Circuit held, first, that the CFAA does not criminalize violations of workplace computer-use policies by employees with authorized access, absent evidence of hacking or code-based circumvention. Second, it held that passwords protecting proprietary business information do not, by themselves, constitute trade secrets under federal or Pennsylvania law. The court also affirmed the dismissal of the state-law tort claims. View "NRA Group LLC v. Durenleau" on Justia Law

Four individuals who worked as drivers for a ride-sharing company alleged that the company misclassified them as independent contractors rather than employees, resulting in violations of federal and Illinois wage laws. The drivers claimed they were denied minimum wage, overtime pay, and reimbursement for business expenses. Each driver had entered into agreements with the company that included arbitration provisions, but these agreements also allowed drivers to opt out of arbitration within a specified period. One driver, Ken Zurek, opted out of the arbitration provision in a later agreement after not opting out of an earlier one.Before joining the federal lawsuit, Zurek had filed a separate case in Illinois state court, where the company sought to compel arbitration based on the earlier agreement. The state court found that Zurek’s opt-out from the later agreement meant he was not bound to arbitrate claims arising during the period covered by that agreement, even if he had not opted out of the earlier one. The state court did not decide whether Zurek had actually agreed to the earlier arbitration provision, finding it unnecessary for the resolution of the case. The parties later settled the state court case.In the United States District Court for the Northern District of Illinois, the company again moved to compel arbitration for all four drivers. The district court granted the motion for three drivers but denied it for Zurek, holding that the state court’s decision precluded relitigation of whether Zurek was bound by the earlier arbitration agreement. The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s denial of the motion to compel arbitration as to Zurek, holding that issue preclusion applied because the state court had already decided the relevant issue. View "Agha v. Uber Technologies, Inc." on Justia Law

In 2023, the Maine Legislature enacted the Paid Family and Medical Leave (PFML) program, requiring employers to remit quarterly premiums into a state fund beginning January 1, 2025. The program allows covered individuals to take up to twelve weeks of leave for qualifying reasons, with benefits paid from the fund. Employers may apply to substitute an approved private plan that provides substantially equivalent benefits, which exempts them from further premium payments. The Maine Department of Labor adopted rules implementing the PFML program, including a provision that all employers must pay nonrefundable premiums for the first quarter of 2025, even if they later obtain approval for a private plan. Employers could begin applying for private plan approval after April 1, 2025, due to the time needed for insurers to develop compliant policies.The Maine State Chamber of Commerce and Bath Iron Works challenged the Department’s rule requiring nonrefundable premiums, arguing it conflicted with the PFML Act and constituted an unconstitutional taking under both the Maine and U.S. Constitutions. The Kennebec County Superior Court accepted a consented-to motion to report three legal questions to the Maine Supreme Judicial Court: whether the rule conflicted with the Act or was arbitrary and capricious, and whether it constituted a taking under state or federal law.The Maine Supreme Judicial Court accepted the report and held that the Department’s rules do not conflict with the PFML Act and are not arbitrary, capricious, or otherwise unlawful. The Court found that the statute unambiguously requires employers to remit premiums until a private plan is approved, and the rules reasonably implement the legislative intent. Additionally, the Court determined that the obligation to pay premiums does not constitute a cognizable taking of private property under either the Maine or U.S. Constitution. The Court answered all three reported questions in the negative and remanded the case for further proceedings. View "Maine State Chamber of Commerce v. Department of Labor" on Justia Law

A high school social studies teacher with a history of disciplinary issues was terminated after posting inflammatory messages on her Facebook account, which was followed primarily by former students. The posts, made during nationwide protests following the killing of George Floyd, included comments and memes that were perceived as racially insensitive and vulgar. Although the teacher had set her account to private and did not accept friend requests from current students, the posts quickly circulated within the school community, prompting complaints from students, parents, staff, and widespread media attention. The school district cited her prior suspensions for similar conduct, the disruption caused by her posts, and her failure to appreciate the impact of her comments as reasons for her dismissal.After her termination, the teacher requested a review hearing before the Illinois State Board of Education, where she argued that her Facebook posts were protected by the First Amendment. The hearing officer applied the Pickering balancing test and found that her dismissal did not violate her constitutional rights. Subsequently, the teacher filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against the school district and associated individuals under 42 U.S.C. § 1983, alleging a First Amendment violation. The district court granted summary judgment for the defendants, finding that she was collaterally estopped from bringing her claim and, alternatively, that her claim failed on the merits.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that the teacher failed to present sufficient evidence for a reasonable juror to find in her favor on her First Amendment claim. Applying the Pickering balancing test, the court concluded that the school district’s interest in addressing actual and potential disruption outweighed the teacher’s interest in free expression, and her posts were not entitled to First Amendment protection. View "Hedgepeth v Britton" on Justia Law

Frankie Nelson worked at Provident Hospital, part of the Cook County Health and Hospital System, from 1997 until her voluntary retirement in 2010. She held union positions, first as Environmental Services Supervisor and later as Building Custodian I. Between 2002 and 2005, Nelson and a male colleague, Henry White, shared the duties of Acting Assistant Director of Environmental Services, each handling different aspects of the role in addition to their regular jobs. Nelson later alleged that, during this period, she was paid less than similarly situated male employees due to sex discrimination, focusing her claim on the pay disparity between herself and White, as well as two Directors, Nate Gordon and Jerry Brown.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of Cook County on both Nelson’s Title VII and Equal Pay Act claims. On appeal, Nelson challenged only the summary judgment on her Title VII claim, arguing that the district court failed to apply the correct legal standard and erred in determining that White was not a valid comparator. The district court had found that Nelson did not provide evidence of White’s compensation to support her claim of pay disparity and further concluded that White, Gordon, and Brown were not similarly situated to Nelson due to differences in job duties, qualifications, and supervisory roles.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court applied the correct legal standards, including both the McDonnell Douglas framework and the totality of the evidence approach. The court concluded that Nelson failed to provide sufficient evidence of pay disparity with White and that none of the alleged comparators were similarly situated to her. Therefore, summary judgment for the defendant was properly granted. View "Nelson v County of Cook" on Justia Law

A former dancer at two adult entertainment clubs in Manhattan filed a class charge with the Equal Employment Opportunity Commission (EEOC), alleging pervasive sexual harassment and a hostile work environment affecting herself and other female dancers. She claimed that the clubs’ policies and practices fostered this environment, including being forced to change in open areas monitored by video and being pressured to engage in sexual acts with customers. After receiving the charge, the EEOC requested information from the clubs, including employee “pedigree” data such as names, demographics, and employment details. The clubs objected, arguing the requests were irrelevant and burdensome, but the EEOC issued subpoenas for the information.The United States District Court for the Southern District of New York granted the EEOC’s petition to enforce the subpoenas, finding the requested information relevant to the investigation and not unduly burdensome for the clubs to produce. The clubs appealed and, while the appeal was pending, the EEOC issued a right-to-sue letter to the charging party, who then filed a class action lawsuit in the same district court. The clubs argued that the EEOC lost its authority to investigate and enforce subpoenas once the right-to-sue letter was issued and the lawsuit commenced.The United States Court of Appeals for the Second Circuit held that the EEOC retains its statutory authority to investigate charges and enforce subpoenas even after issuing a right-to-sue letter and after the charging party files a lawsuit. The court also found that the employee information sought was relevant to the underlying charge and that the clubs had not shown compliance would be unduly burdensome. The Second Circuit therefore affirmed the district court’s order enforcing the subpoenas. View "EEOC v. AAM Holding Corp." on Justia Law

The plaintiff, a mail clerk with sickle cell anemia, was employed by the United States Postal Service (USPS) and had a history of attendance issues, some of which were covered by the Family Medical Leave Act (FMLA). To avoid termination, he entered into a Last Chance Agreement (LCA) that limited unscheduled absences and specified that FMLA-approved absences would not count against him if properly documented. After several disputed absences, some of which the plaintiff claimed were FMLA-protected, USPS terminated his employment for violating the LCA.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of USPS on most of the plaintiff’s claims, finding that he failed to establish FMLA coverage for all but one disputed date and did not sufficiently notify USPS of a need for accommodations under the Rehabilitation Act. The court also held that the plaintiff’s FMLA medical certification, which estimated two days of intermittent leave per month, created a hard cap on his FMLA leave. The plaintiff’s claims regarding one date were settled, and his motion for reconsideration was denied.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court affirmed the district court’s decision regarding the December 26, 2018 absence and the Rehabilitation Act claim, finding no evidence of a request for accommodation. However, it reversed the district court’s holding that the FMLA medical certification imposed a strict monthly limit on unforeseeable intermittent leave, clarifying that such certifications provide only estimates, not hard caps. The court remanded for further proceedings to determine whether the plaintiff gave proper notice for FMLA leave on certain dates and vacated the district court’s summary judgment on FMLA interference and retaliation claims related to the LCA, pending resolution of factual disputes. View "Jackson v. Postal Service" on Justia Law

A worker in Humboldt County performed maintenance and other services for several years on property managed by his employers, in exchange for free rent but without additional pay or benefits. After the arrangement ended, he filed claims with the Labor Commissioner, asserting he was an employee entitled to unpaid wages, liquidated damages, and penalties, including under California’s Paid Sick Leave law. The employers contended he was an independent contractor, but the Labor Commissioner found he was an employee and awarded him compensation.The employers appealed the Labor Commissioner’s decision to the Humboldt County Superior Court, which conducted a de novo bench trial. The court agreed that the worker was an employee and awarded unpaid wages, penalties, and interest. However, it denied liquidated damages, finding the employers acted in good faith based on their mutual understanding with the worker that he would work for rent and not as an employee. The court also rejected the worker’s claim for penalties under the Paid Sick Leave law, concluding such claims could not be raised in court during an employer’s appeal of a Labor Commissioner ruling. The worker appealed, and the California Court of Appeal affirmed the superior court’s rulings on both the liquidated damages and Paid Sick Leave issues.The Supreme Court of California reviewed the case. It held, first, that to establish a good faith defense to liquidated damages for minimum wage violations, an employer must show it made a reasonable attempt to determine the requirements of minimum wage law; mere ignorance of the law is insufficient. Second, the court held that an employee may raise a claim under the Paid Sick Leave law in the context of an employer’s appeal to the superior court of a Labor Commissioner ruling. The Supreme Court reversed the Court of Appeal’s judgment and remanded for further proceedings. View "Iloff v. LaPaille" on Justia Law