Justia Labor & Employment Law Opinion Summaries

Karl Von Derhaar, an employee at the New Orleans Crime Lab, raised concerns about safety breaches and inaccuracies in a drug-testing method. Instead of addressing these concerns, the Lab mandated that all employees, including Von Derhaar, be tested using the disputed method. Von Derhaar requested unpaid leave, and his supervisor, Sergeant Michael Stalbert, attempted to contact him at home. After initially going to the wrong apartment, Stalbert returned with two armed officers. Von Derhaar, standing in his doorway, declined to speak with Stalbert, who then forcibly entered the apartment, claiming it was a wellness check. Despite no visible signs of distress, Stalbert ordered Von Derhaar out of his home, where another supervisor, Lieutenant Kim Williams, awaited. Von Derhaar was then taken to the Police Integrity Bureau (PIB) headquarters against his will.The United States District Court for the Eastern District of Louisiana reviewed the case. The court granted summary judgment to the City of New Orleans and its police superintendent on all claims, finding no municipal liability. On the search claim, the court granted summary judgment to Williams and Officer Khalid Watson but denied it to Stalbert. On the seizure claim, the court denied summary judgment to Stalbert, Williams, and Khalid Watson. These decisions led to the current appeals and cross-appeals.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court dismissed the appeals regarding the denial of summary judgment to Stalbert on punitive damages, the summary judgment to Khalid Watson on the search claim, and the summary judgment to the City and superintendent. The court affirmed the denial of summary judgment to Stalbert on the search and seizure claims, finding material fact disputes. However, it reversed the denial of summary judgment to Williams and Khalid Watson on the seizure claim, concluding that they acted under orders and did not violate clearly established law. The case was remanded for further proceedings. View "Von Derhaar v. Watson" on Justia Law

Irma Leibas, a correctional officer at the Cook County Department of Corrections (DOC), has pre-existing medical conditions requiring workplace accommodations, including up to three additional breaks per shift. After the DOC denied her request for these accommodations, Leibas sued, alleging violations of the Americans with Disabilities Act (ADA).The United States District Court for the Northern District of Illinois initially denied the defendants' motion for summary judgment on Leibas’s accommodation and discrimination claims. However, upon reconsideration and after both parties supplemented the record, the district court granted summary judgment in favor of the defendants, concluding that Leibas was not a qualified individual under the ADA.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The appellate court examined whether Leibas could perform the essential functions of her position with or without reasonable accommodation. The court found that maintaining the safety and security of the DOC is an essential function of a correctional officer. Leibas’s requested accommodation of additional breaks, including rest periods, was deemed unreasonable given the unpredictable and violent environment of the DOC, which requires officers to be able to stand for long periods and respond to emergencies without delay. The court also noted that the DOC’s staffing shortages and the need for continuous coverage further complicated the feasibility of Leibas’s requested accommodations.The Seventh Circuit affirmed the district court’s judgment, holding that Leibas did not provide sufficient evidence to create a genuine dispute of material fact that she could perform the essential functions of her position with the requested accommodations. View "Leibas v. Dart" on Justia Law

Timothy Mullins, a coal miner, suffered an ankle stress fracture in 2015 while working as a Section Supervisor at a coal mine owned by CONSOL Energy, Inc. He initially received long-term disability benefits under CONSOL's ERISA-governed Long-Term Disability Plan, administered by Lincoln Financial Group. However, his benefits were terminated in 2020 after Lincoln determined, based on medical evaluations and a vocational assessment, that Mullins did not demonstrate "total disability" as required under the Plan. Lincoln's decision was based on a vocational report that incorrectly listed Mullins's job as "Mine Superintendent" rather than Section Supervisor.The United States District Court for the Western District of Pennsylvania upheld Lincoln's decision to terminate Mullins's benefits, granting summary judgment in favor of the Plan. The District Court found that Lincoln's decision was supported by substantial medical and vocational evidence and was not arbitrary and capricious. Mullins appealed the decision, arguing that Lincoln's reliance on the incorrect job title in the vocational report led to an erroneous termination of his benefits.The United States Court of Appeals for the Third Circuit reviewed the case and found that Lincoln's reliance on the incorrect vocational report was arbitrary and capricious. The court noted that the error in the job title led to an incorrect assessment of Mullins's qualifications and experience, which in turn resulted in the wrongful termination of his benefits. The Third Circuit vacated the District Court's judgment and remanded the case for reinstatement of Mullins's long-term disability benefits. The court also instructed the District Court to consider Mullins's claim regarding the improper offset of benefits due to Social Security disability benefits. View "Mullins v. Consol Energy Inc Long Term Disability Plan" on Justia Law

Christine Bube and Connie Hedrington, both registered nurses, worked for Aspirus, Inc., a non-profit hospital system. In response to the COVID-19 pandemic, Aspirus mandated that all employees receive the COVID vaccine, allowing exemptions for religious reasons. Bube and Hedrington applied for religious exemptions, citing their Catholic faith and beliefs about bodily integrity and health. Aspirus denied their requests and terminated their employment in December 2021.The United States District Court for the Western District of Wisconsin dismissed Bube and Hedrington’s Title VII claim, reasoning that their accommodation requests did not sufficiently tie their objections to specific religious beliefs or practices. The court concluded that their objections were primarily about personal autonomy and vaccine safety, rather than religious beliefs.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that an employee seeks accommodation because of their religion when their request is plausibly based at least in part on some aspect of their religious belief or practice. Applying this standard, the court found that Bube’s and Hedrington’s requests were indeed based in part on their religious beliefs. The court emphasized that Title VII’s broad definition of religion requires a hands-off approach to defining religious exercise. The court reversed the district court’s dismissal and remanded the case for further proceedings. View "Bube v. Aspirus Hospital, Inc" on Justia Law

In May 2019, the City of Sunnyvale Department of Public Safety imposed a 44-hour suspension on Officer David Meinhardt, which was upheld by the City of Sunnyvale Personnel Board. Meinhardt challenged the suspension by filing a petition for writ of administrative mandate in the Santa Clara County Superior Court. On August 6, 2020, the court issued an order denying the petition. Subsequently, on September 25, 2020, a formal judgment was entered, and Meinhardt filed a notice of appeal on October 15, 2020.The Fourth Appellate District, Division One, dismissed the appeal as untimely, concluding that the August 6 order was the final judgment from which Meinhardt should have appealed. The court reasoned that the order denied the petition in its entirety and did not contemplate further action, thus starting the 60-day period for filing an appeal.The Supreme Court of California reviewed the case to resolve the uncertainty about when the time to appeal starts in writ of administrative mandate proceedings. The court held that the time to appeal begins with the entry of a "judgment" or the service of notice of entry of "judgment," rather than with the filing of an "order" or other ruling. This decision was based on the plain language of relevant statutes and rules, which contemplate the entry of a "judgment," and the policy of providing clear jurisdictional deadlines to avoid inadvertent forfeiture of the right to appeal. The court reversed the judgment of the Court of Appeal, concluding that Meinhardt's notice of appeal was timely filed within 60 days of the entry of the September 25 judgment. View "Meinhardt v. City of Sunnyvale" on Justia Law

Twanda Bailey, an African-American employee, sued the San Francisco District Attorney’s Office, former District Attorney George Gascon, and the City and County of San Francisco for racial harassment and retaliation under the California Fair Employment and Housing Act (FEHA). Bailey alleged that a coworker called her the N-word, and after reporting the incident, the human resources manager obstructed her complaint, engaged in intimidating conduct, and threatened her.The San Francisco City and County Superior Court granted summary judgment for the City, finding that Bailey failed to make a prima facie case for her FEHA claims. The trial court concluded that a single racial slur by a coworker did not constitute severe or pervasive harassment and that Bailey did not suffer an adverse employment action. The Court of Appeal affirmed the trial court’s decision.The Supreme Court of California reviewed the case and held that an isolated act of harassment, such as the use of an unambiguous racial epithet like the N-word, can be actionable if it is sufficiently severe under the totality of the circumstances. The Court emphasized that the severity of harassment should be judged from the perspective of a reasonable person in the plaintiff’s position. The Court also held that a course of conduct that effectively withdraws an employee’s means of reporting and addressing racial harassment can constitute an adverse employment action. The Court found that there were triable issues of fact regarding both Bailey’s harassment and retaliation claims and reversed the judgment of the Court of Appeal, remanding the case for further proceedings. View "Bailey v. San Francisco District Attorney's Office" on Justia Law

Two healthcare workers, Megan Passarella and Sandra Dottenwhy, employed by Aspirus Health in Wisconsin, sought religious exemptions from the company's COVID-19 vaccination mandate. Passarella cited her Christian belief that her body is a temple of the Holy Spirit and expressed concerns about the vaccine's safety. Dottenwhy also referenced her Christian faith, stating that her body is a temple and expressing distrust in the vaccine's development and long-term effects. Both were denied exemptions and subsequently terminated.The United States District Court for the Western District of Wisconsin dismissed their Title VII claims, ruling that their objections were based on medical judgment rather than religious conviction. The court found that the plaintiffs did not articulate any religious belief that would prevent them from taking the vaccine if they believed it was safe.The United States Court of Appeals for the Seventh Circuit reversed the district court's decision. The appellate court held that an employee's request for accommodation is based on religion if it is plausibly connected to their religious beliefs or practices, even if it also includes non-religious reasons. The court emphasized that Title VII's definition of religion is broad and includes all aspects of religious observance and practice. The court found that both Passarella's and Dottenwhy's exemption requests were at least partially based on their religious beliefs, making them sufficient to survive a motion to dismiss. The case was remanded for further proceedings to determine the sincerity of the plaintiffs' beliefs and whether Aspirus could reasonably accommodate them without undue hardship. View "Dottenwhy v. Aspirus, Inc." on Justia Law

Rachel Spivack, an employee at the Philadelphia District Attorney’s Office (DAO), was subject to a COVID-19 vaccine mandate. The DAO denied her request for a religious exemption, leading to her termination. Spivack then sued the City of Philadelphia and District Attorney Lawrence Krasner, alleging that the mandate violated her constitutional right to the free exercise of religion.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the defendants, holding that the vaccine mandate was neutral and generally applicable, thus subject to rational basis review. The court found that the mandate was rationally related to the DAO’s interests in curtailing the spread of COVID-19, avoiding staffing shortages, and reducing the risk of death and serious illness among DAO staff and the public. The court also held that the mandate satisfied strict scrutiny as an alternative ruling. Spivack appealed the decision.The United States Court of Appeals for the Third Circuit reviewed the case and found that there were disputes of material fact that needed to be resolved by a jury. Specifically, the court noted that it was unclear whether Spivack’s exemption request was evaluated under the August 2021 policy, which allowed for individualized, discretionary religious exemptions, or the January 2022 policy, which categorically denied religious exemptions. Additionally, the court found that comments made by Krasner during his deposition could be interpreted as showing hostility toward religious beliefs, which would undermine the neutrality of the policy.The Third Circuit vacated the District Court’s order and remanded the case for trial, instructing that a jury must resolve these factual disputes to determine the applicable standard of scrutiny. If the policy is found to be neutral and generally applicable, it would be subject to rational basis review. If not, it would be subject to strict scrutiny. View "Spivack v. City of Philadelphia" on Justia Law

Samuel Amos fell from the roof of a shop building he was helping David Tidwell construct on property owned by Travis and Tabitha Plambeck. Tidwell had promised to pay Amos for his work. Amos filed a workers’ compensation claim against Tidwell and the Alaska Workers’ Compensation Benefits Guaranty Fund for his injuries. Tidwell requested the Alaska Workers’ Compensation Board dismiss Amos’s claim, alleging he had not hired Amos. The Board found that Amos had an employment contract with Tidwell but determined Tidwell was not an “employer” under the Alaska Workers’ Compensation Act, reasoning that the employment was based on friendship and thus fell within consumptive uses exempt from the Act’s coverage.The Alaska Workers’ Compensation Appeals Commission affirmed the Board’s decision, agreeing that Tidwell’s activities were consumptive rather than productive. The Commission also speculated that Amos’s work might fall under the statutory exemption for “harvest help and similar part-time or transient help,” although the Board had not made findings on this issue. Amos appealed, arguing that the Commission and the Board incorrectly construed the law and that there is no “buddy” exemption to the employer-employee relationship under the Act.The Supreme Court of the State of Alaska reviewed the case. The Court held that the Commission erred by creating an implicit exemption for “buddies” and by applying the productive/consumptive distinction to Tidwell’s employment of Amos. The Court clarified that the productive/consumptive distinction applies only to householders and not to individuals like Tidwell who hire others for work on third-party properties. The Court also found that the Commission improperly speculated about the applicability of the statutory exemption for part-time or transient help without proper findings. The case was reversed and remanded for further proceedings consistent with the opinion. View "Amos v. Tidwell" on Justia Law

A group of non-convicted individuals detained in Alameda County’s Santa Rita Jail filed a lawsuit against Aramark Correctional Services, LLC, Alameda County, and Sheriff Gregory J. Ahern. The plaintiffs claimed they were entitled to minimum wage and overtime pay under California’s Labor Code for work performed without pay for Aramark while detained. The defendants moved to dismiss these claims, arguing that the plaintiffs' compensation was governed by the California Penal Code, which allows counties to pay prisoners at rates below minimum wage.The United States District Court for the Northern District of California denied the defendants' motion to dismiss the minimum wage and overtime claims, holding that the California Penal Code did not preclude non-convicted detainees working for a private company from the protections of the Labor Code. The district court allowed the plaintiffs' claims to proceed, leading the defendants to file an interlocutory appeal.The United States Court of Appeals for the Ninth Circuit reviewed the case and certified a question to the California Supreme Court regarding whether non-convicted detainees working for a private company in county jails have a claim for minimum wages and overtime under the California Labor Code. The California Supreme Court responded that such detainees do not have a claim for minimum wages and overtime under Section 1194 of the California Labor Code. The court clarified that section 4019.3 of the California Penal Code applies broadly to all county inmates, including pretrial detainees, and does not depend on the identity of the employer.Based on the California Supreme Court's response, the Ninth Circuit reversed the district court's order denying the motion to dismiss the plaintiffs' minimum wage and overtime claims. The court held that the plaintiffs' claims failed under the current law and reversed the district court's decision. View "RUELAS V. COUNTY OF ALAMEDA" on Justia Law