Justia Labor & Employment Law Opinion Summaries

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

Paula Emerson, a former Cook County Corrections Officer, was terminated in 2019 after being on disability leave since 2012 due to anxiety, depression, and PTSD. Emerson claimed her termination was in retaliation for filing a workers' compensation claim in 2014 and a Title VII lawsuit against Cook County and its employees, which she lost. She alleged that the same attorneys represented the County in both her workers' compensation proceedings and the Title VII case, and discussed her cases with those responsible for her termination.The United States District Court for the Northern District of Illinois dismissed Emerson's initial complaint for failure to state a claim, allowing her to amend it. Emerson's amended complaint was also dismissed with prejudice for failing to cure deficiencies. The court found that filing a workers' compensation claim was not a protected activity under the ADA and that Emerson did not adequately allege that her workers' compensation claim caused her termination. Emerson's request for limited discovery was denied due to lack of specific allegations.The United States Court of Appeals for the Seventh Circuit affirmed the district court's dismissal. The appellate court held that Emerson's complaint did not plausibly allege that her workers' compensation claim caused her termination, noting the five-year gap between the claim and her firing. The court also upheld the denial of Emerson's discovery request, deeming it speculative, and found no abuse of discretion in denying her Rule 59(e) motion for reconsideration, as she presented no new evidence or manifest error of law or fact. The judgment of the district court was affirmed. View "Emerson v. Dart" on Justia Law

A Catholic priest, Andrew J. Syring, sued the Archdiocese of Omaha, alleging defamation, tortious interference with prospective employment, slander per se, breach of fiduciary duty, and intentional infliction of emotional distress. His claims stemmed from the Archdiocese publishing his name on a list of clergy with substantiated claims of sexual misconduct and a subsequent phone conversation where a church official referenced this list when discussing Syring's potential employment as a hospital chaplain.The District Court for Cuming County granted summary judgment for the Archdiocese on Syring's defamation claim, finding it barred by Nebraska’s one-year statute of limitations. The court ruled that the initial publication of the list in 2018 started the limitations period, and subsequent updates to the list did not constitute republication. The court also granted summary judgment on Syring's intentional infliction of emotional distress claims, concluding that Syring failed to provide medical evidence of severe emotional distress.The Nebraska Supreme Court reviewed the case de novo and affirmed the lower court's decisions. The court held that the single publication rule applied to the Archdiocese's list, meaning the statute of limitations began with the initial publication. The court also found that the Archdiocese's conduct did not meet the high threshold for extreme and outrageous behavior required for an intentional infliction of emotional distress claim.Additionally, the court upheld the dismissal of Syring's claims for tortious interference, slander per se, and breach of fiduciary duty, citing the ministerial exception. This doctrine prevents courts from interfering with the employment relationship between a religious institution and its ministers, thus barring Syring's claims related to his employment and the Archdiocese's internal governance decisions. The Nebraska Supreme Court affirmed the judgment, dismissing all of Syring's claims. View "Syring v. Archdiocese of Omaha" on Justia Law

The case involves a dispute between the law firm Abraham Watkins Nichols Agosto Aziz & Stogner and its former associate, Edward Festeryga. Abraham Watkins terminated Festeryga’s employment after discovering that he attempted to take clients and firm files to a new firm. Abraham Watkins sued Festeryga in Texas state court for conversion, breach of fiduciary duty, and tortious interference with contract. Festeryga moved to dismiss the suit under Texas’s anti-SLAPP statute, the Texas Citizens Participation Act (TCPA), which stayed the expedited discovery sought by Abraham Watkins. Despite agreeing to produce certain documents, Festeryga filed a notice of removal to federal court, claiming diversity jurisdiction as a Canadian citizen.The United States District Court for the Southern District of Texas remanded the case back to state court. The district court did not address whether Festeryga had shown diversity of citizenship but concluded that Festeryga waived his right to remove by participating in state court proceedings, specifically by filing a TCPA motion to dismiss. The district court found that this action demonstrated an intent to invoke the jurisdiction of the state court.The United States Court of Appeals for the Fifth Circuit reviewed the case to determine if it had appellate jurisdiction over the remand order. The court concluded that it did not have jurisdiction, citing its precedent in In re Weaver, which held that waiver-based remand orders are jurisdictional under 28 U.S.C. § 1447(c) and thus unappealable under § 1447(d). The court noted that although it disagreed with the reasoning in Weaver, it was bound by the rule of orderliness to follow the precedent. Consequently, the Fifth Circuit dismissed the appeal for lack of appellate jurisdiction. View "Abraham Watkins Nichols Agosto Aziz & Stogner v. Festeryga" on Justia Law

Michele Tourangeau filed a complaint against her former employer, Nappi Distributors, alleging nine employment-related claims. Nappi moved for summary judgment on all claims, but the District Court denied the motion for all but one claim, leading to a jury trial. The jury found in favor of Nappi on all claims. Tourangeau then filed a motion for a new trial, citing juror bias and errors in jury instructions, which the District Court denied.Tourangeau appealed the District Court's decision to the United States Court of Appeals for the First Circuit. She argued that the District Court erred in not disqualifying a juror who allegedly displayed bias and failed to answer voir dire questions truthfully. The District Court had previously determined that the juror's conduct and Facebook activity did not demonstrate bias sufficient to warrant disqualification. The appellate court found no abuse of discretion in the District Court's handling of the juror bias allegations, noting that the District Court had appropriately assessed the juror's behavior and responses.Tourangeau also challenged the jury's verdict on one of her Equal Pay Act (EPA) claims, arguing that the verdict was against the great weight of the evidence and that the District Court erred in not giving a specific jury instruction. The appellate court upheld the District Court's decision, finding that Nappi had provided sufficient evidence that the pay differential was based on a business decision unrelated to sex. The court also agreed with the District Court's refusal to give the requested jury instruction, as there was no evidence of a prior illegal practice of gender discrimination in hiring.The United States Court of Appeals for the First Circuit affirmed the District Court's judgment, concluding that there was no reversible error in the handling of the juror bias allegations or the EPA claim. View "Tourangeau v. Nappi Distributors" on Justia Law

Peter Quach filed a lawsuit against California Commerce Club (Commerce Club) after being terminated from his job at the casino where he had worked for nearly 30 years. Quach's complaint included claims of wrongful termination, age discrimination, retaliation, and harassment, and he demanded a jury trial. Commerce Club had previously provided Quach with a signed arbitration agreement from 2015, which mandated binding arbitration for employment-related disputes. Instead of moving to compel arbitration, Commerce Club answered the complaint and engaged in extensive discovery, including propounding interrogatories and taking Quach’s deposition.The Los Angeles County Superior Court denied Commerce Club’s motion to compel arbitration, finding that Commerce Club had waived its right to arbitrate by engaging in litigation for 13 months. The court noted that Commerce Club had actively participated in discovery and requested a jury trial, actions inconsistent with an intent to arbitrate. Commerce Club appealed, and the Second Appellate District, Division One, reversed the trial court’s decision, holding that Quach had not shown sufficient prejudice from Commerce Club’s delay in seeking arbitration.The Supreme Court of California reviewed the case and abrogated the state’s arbitration-specific prejudice requirement, aligning with the U.S. Supreme Court’s decision in Morgan v. Sundance, Inc. The court held that under California law, as under federal law, courts should apply the same principles to determine waiver of the right to compel arbitration as they do for other contracts. The court concluded that Commerce Club had waived its right to compel arbitration by engaging in litigation conduct inconsistent with an intent to arbitrate. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings consistent with this decision. View "Quach v. Cal. Commerce Club, Inc." on Justia Law

The case involves Business and Professions Code section 7451, enacted through Proposition 22, which classifies app-based drivers for companies like Uber, Lyft, and DoorDash as independent contractors rather than employees, provided certain conditions are met. This classification exempts these drivers from California workers’ compensation laws, which typically apply to employees. Plaintiffs, including several individuals and unions, argue that section 7451 conflicts with article XIV, section 4 of the California Constitution, which grants the Legislature plenary power to create and enforce a complete system of workers’ compensation.The Alameda County Superior Court found Proposition 22 unconstitutional, reasoning that it improperly limited the Legislature’s power to govern workers’ compensation, a power deemed "unlimited" by the state Constitution. The court held that the people must amend the Constitution through an initiative constitutional amendment, not an initiative statute, to impose such limitations. Consequently, the court invalidated Proposition 22 in its entirety.The California Court of Appeal reversed the lower court’s decision, holding that article XIV, section 4 does not preclude the electorate from using its initiative power to legislate on workers’ compensation matters. The court reasoned that the Legislature’s power under article XIV, section 4 is not exclusive and that Proposition 22 does not conflict with this constitutional provision. The court did, however, affirm the invalidation of certain severable provisions of Proposition 22 not at issue in this appeal.The California Supreme Court affirmed the Court of Appeal’s judgment, agreeing that section 7451 does not conflict with article XIV, section 4. The court held that the Legislature’s plenary power under article XIV, section 4 is not exclusive and does not preclude the electorate from enacting legislation through the initiative process. The court did not address whether other provisions of Proposition 22 improperly constrain the Legislature’s authority, as those issues were not presented in this case. View "Castellanos v. State of California" on Justia Law

A staff psychologist at a federal prison discovered that a corrections lieutenant operated an Instagram account with sexually offensive content, some of which targeted her. When she reported this to prison leadership, her complaints were dismissed, and the lieutenant's posts became more aggressive. Despite her repeated complaints, the prison's response was slow and ineffective, leading her to feel unsafe and eventually leave her job.The United States District Court for the Central District of California granted summary judgment in favor of the government, concluding that the psychologist had not shown an objectively hostile work environment and that the prison had taken reasonable remedial actions. The court limited its consideration to five specific posts and determined that these did not occur within the physical workplace.The United States Court of Appeals for the Ninth Circuit reversed the district court's decision. The appellate court held that the district court erred by not considering the totality of the circumstances, including the broader context of the harassment and the prison's inadequate response. The Ninth Circuit reaffirmed that evidence of sexually harassing conduct, even if not expressly targeting the plaintiff, and non-sexual conduct that could be seen as retaliatory or intimidating, should be considered. The court also rejected the notion that only conduct occurring inside the physical workplace is actionable, especially given the prevalence of social media. The court found that the plaintiff had raised triable issues of fact regarding the hostile work environment and the prison's failure to take prompt and effective remedial measures. The case was reversed and remanded for further proceedings. View "OKONOWSKY V. GARLAND" on Justia Law

Allan Sanders, a foreman general at Union Pacific Railroad Company, sued his employer under the Americans with Disabilities Act (ADA). Sanders claimed that Union Pacific discriminated against him by imposing work limitations due to perceived cardiovascular health issues and by failing to provide a reasonable accommodation during a cardiovascular test. Sanders had suffered a brief cardiac arrest due to complications from a bleeding ulcer but had fully recovered. Union Pacific required him to undergo a fitness-for-duty evaluation, including a treadmill test, which he could not complete due to knee pain from osteoarthritis. Sanders requested an alternative test on a bicycle, which Union Pacific denied, leading to work restrictions that prevented him from returning to his job.The United States District Court for the District of Nebraska denied Union Pacific’s renewed motion for judgment as a matter of law after a jury found in favor of Sanders on both claims and awarded him damages. Union Pacific appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that there was sufficient evidence for a reasonable jury to conclude that Union Pacific regarded Sanders as disabled due to perceived cardiovascular issues and that Sanders was qualified to perform his job. The court also found that Union Pacific’s refusal to allow an alternative test constituted a failure to provide reasonable accommodation. The court rejected Union Pacific’s “direct threat” defense, concluding that the company’s decision was not objectively reasonable or based on the best available evidence. The appellate court upheld the jury’s verdict on both the disparate treatment and failure-to-accommodate claims. View "Sanders v. Union Pacific Railroad Co." on Justia Law