Justia Labor & Employment Law Opinion Summaries

The case involves an employee, Marlene Mosher, who filed a petition against her employer, Whole Foods Market, Inc., claiming she suffered an injury from a fall during her employment. Mosher alleged that she sustained injury to her right lower extremity and right ankle and developed low-back pain. She claimed that she had suffered periods of temporary disability, required reasonable and necessary medical care, incurred mileage and expenses, and had not yet reached maximum medical improvement (MMI). Mosher also alleged that Whole Foods had failed or refused to provide those benefits, thus, she was entitled to waiting-time penalties and attorney fees.The Workers’ Compensation Court found that Mosher had not yet reached MMI and was unable to return to work without restrictions. The court awarded Mosher temporary total disability benefits, payment for medical bills, future medical care, a waiting-time penalty, and attorney fees. The court found that Whole Foods had no reasonable controversy that compensation was due, which justified a waiting-time penalty. The court also found no reasonable controversy as to medical expenses.Whole Foods appealed, arguing that there was a reasonable controversy as to whether Mosher had reached MMI and, thus, as to whether its obligations to pay temporary total disability ceased and its obligations to pay permanent disability began. Whole Foods also contested the amount of the attorney fees awarded.The Nebraska Supreme Court affirmed the decision of the Workers’ Compensation Court. The court held that when there is no reasonable controversy that the employee has been injured in a workplace accident and is entitled to some indemnity benefit, the employer is not excused from timely payments thereof. The court also held that the plain meaning of a “reasonable attorney’s fee” in § 48-125(4)(a) encompasses the work of a legal assistant for the attorney. View "Mosher v. Whole Foods Market" on Justia Law

This case revolves around the denial of a disability pension application by a former state trooper, James Donnelly-Taylor. The defendants are the State of Rhode Island, Division of the State Police, and the Colonel of the State Police and Governor in their official capacities. The trooper had been involved in an incident where he assaulted an individual he had arrested. Following this incident, he reported experiencing personal and work-related stress and was placed on injured-on-duty status. Later, he was indicted on one count of simple assault. He pleaded nolo contendere to the assault charge and was ordered to perform community service. The trooper remained out of work and was later diagnosed with post-traumatic stress disorder and major depressive disorder. He applied for a disability pension, which was denied by the superintendent of the state police.The superintendent's decision was appealed to the Superior Court, which found the denial to be arbitrary and capricious. The court remanded the case back to the superintendent for further consideration. The superintendent issued a supplemental decision, maintaining the denial of the disability pension. The Superior Court again found the superintendent's decision to be arbitrary and capricious and reversed the denial, instructing the superintendent to grant the trooper's request for a disability pension.The State of Rhode Island appealed the Superior Court's decision to the Supreme Court of Rhode Island. The Supreme Court reversed the Superior Court's decision, finding that the superintendent's denial of the disability pension was neither arbitrary nor capricious. The court held that the superintendent had reasonable grounds to conclude that the trooper's assault of the individual was not in the course of performance of his duties as a state police officer, and therefore his disabling injuries were not suffered in the course of performance of his duties. The case was remanded back to the Superior Court with instructions to enter judgment in favor of the defendants. View "Rhode Island Troopers Association v. State of Rhode Island" on Justia Law

Samantha Peifer, an employee of the Pennsylvania Board of Probation and Parole, filed a lawsuit against her employer alleging pregnancy discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the Pregnancy Discrimination Act. Peifer, who was diagnosed with multiple sclerosis and later became pregnant, requested accommodations from her employer due to her inability to perform certain tasks. Her requests were initially denied, but later granted after she filed a charge with the Equal Employment Opportunity Commission (EEOC). However, she was not allowed to work from home as requested due to her high-risk pregnancy and exposure to COVID-19. Peifer eventually resigned, citing discriminatory treatment, and filed additional charges with the EEOC.The United States District Court for the Eastern District of Pennsylvania granted the Board's motion for summary judgment, concluding that Peifer could not establish a prima facie case for any of her claims. Peifer appealed this decision.The United States Court of Appeals for the Third Circuit affirmed in part and vacated in part the District Court's decision. The Court of Appeals agreed with the lower court that Peifer's claims partly failed but concluded that the District Court was best situated to analyze the impact of the Supreme Court’s recent holding in Muldrow v. City of St. Louis on whether Peifer makes out a prima facie case under an adverse employment action theory. The Court of Appeals also concluded that Peifer makes out a prima facie case of pregnancy discrimination based on the Board’s denials of her light-duty requests under a failure to accommodate theory. The case was remanded for further analysis on Peifer’s adverse employment theory and failure to accommodate theory, while the District Court’s decisions on Peifer’s constructive discharge allegation and retaliation claim were affirmed. View "Peifer v. Pennsylvania Board of Probation and Parole" on Justia Law

The case revolves around Thomas E. Hennig, Jr., who was discharged from his job at Money Metals Exchange, L.L.C. after making a controversial comment on the company's instant messaging system. Hennig referred to himself as his employer’s “good little Nazi” in a joke about enforcing the company’s time clock rules. After his termination, Hennig applied for unemployment benefits, but his application was denied by the Idaho Department of Labor (IDOL) on the grounds that he was discharged for misconduct connected with his employment. Hennig appealed this decision to the Idaho Industrial Commission, which upheld the IDOL's decision.Hennig then appealed to the Supreme Court of the State of Idaho, arguing that the Commission’s decision was unsupported by competent and substantial evidence. He contended that his use of the term "Nazi" was not objectively unprofessional and that the company had tolerated racist remarks from another employee. The Supreme Court of Idaho reversed the Commission’s decision and remanded the case for further proceedings. The court found that the Commission had failed to properly analyze whether the company's expectations of Hennig's behavior were objectively reasonable, given evidence that it had tolerated racist comments from another co-worker and then promoted him to a supervisory position. The court also found that the Commission had failed to consider Hennig's claim that the company had encouraged his unorthodox humor. View "Hennig v. Money Metals Exchange" on Justia Law

Domingo Musquiz, a former rail industry employee, petitioned for review of a decision by the U.S. Railroad Retirement Board (RRB). The RRB had adopted a hearing officer's finding that Musquiz was at fault for an overpayment of his reduced-age annuity under the Railroad Retirement Act (RRA) and denied his request for a waiver or reduction of repayment of the overpayment and penalty. Musquiz had failed to report his re-employment and additional income to the RRB, leading to the overpayment.The RRB's decision was based on the fact that Musquiz had received a booklet of regulations, including reporting requirements, when he applied for his annuity. The RRB concluded that Musquiz should have known about his reporting duties and was at fault when he did not report his change in employment and additional outside income.The United States Court of Appeals for the Ninth Circuit agreed with the RRB that Musquiz was at fault for the overpayment that occurred from August 2012 to June 2, 2013. However, the court concluded that Musquiz was without fault for the RRB’s overpayment of his annuity from June 3, 2013, onward. The court reasoned that by then, the RRB had informed Musquiz that they had taken his outside earnings into account and adjusted his annuity payments.The court granted Musquiz's petition, vacated the RRB's decision, and remanded the case to the RRB for further proceedings. The court instructed the RRB to develop a factual record and determine whether recovery of the overpayment from June 3, 2013, onward would be contrary to the purpose of the RRA, against equity, or against good conscience. View "Musquiz V. United States Railroad Retirement Board" on Justia Law

The case involves two brothers, Levi and Benjamin Goldfarb, who sought payment of a $500,000 claim under an Accidental Death & Dismemberment insurance policy after their father, Dr. Alexander Goldfarb, died while mountain climbing in Pakistan. The insurer, Reliance Standard Life Insurance Company, denied the claim because the cause of Dr. Goldfarb’s death was unknown, and therefore, his beneficiaries could not show that he died by accident. The Goldfarb brothers challenged the denial in district court under the Employee Retirement Security Act.The district court ruled in favor of the Goldfarbs, stating that Dr. Goldfarb’s death was accidental and that Reliance Standard’s failure to pay the Accidental Death & Dismemberment claim was arbitrary and capricious. The court granted summary judgment to the Goldfarbs and denied Reliance Standard’s cross motion for summary judgment. Reliance Standard appealed this decision.The United States Court of Appeals for the Eleventh Circuit disagreed with the district court's decision. The appellate court found that Reliance Standard’s decision that Dr. Goldfarb’s death was not accidental under the insurance policy was supported by reasonable grounds, and the denial of the Goldfarbs’ claim for benefits was not arbitrary and capricious. Therefore, the court reversed the district court’s grant of summary judgment to the Goldfarbs and directed the court to enter judgment in Reliance Standard’s favor. View "Goldfarb v. Reliance Standard Life Insurance Co." on Justia Law

The case revolves around the Metropolitan Washington Airports Authority (the Authority), an entity jointly created by Virginia and the District of Columbia to manage the area's two airports. The Authority disputed the Virginia Department of Labor and Industry's (the Department) power to enforce its workplace safety laws against the Authority. The Department had levied a monetary penalty against the Authority following an accident that resulted in an employee's injury. The Authority contested the Department's power to enforce these penalties, arguing that it was not subject to Virginia workplace safety regulations due to its status as an interstate compact entity.The Department's adjudicator found that the Authority was subject to Virginia workplace safety regulations, a decision adopted by the Department's Commissioner. The Authority then sued the Commissioner in federal court seeking injunctive and declaratory relief. The district court ruled in favor of the Authority, reasoning that Virginia had surrendered its ability to exercise unilateral regulatory authority over the Authority's facilities when it created the Authority.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court's decision. The court agreed with the Authority that by jointly creating the Authority with the District, Virginia relinquished its control over the Authority except as otherwise provided in the Compact. The court rejected the Department's argument that the Compact expressly reserves its power to enforce Virginia’s workplace safety regulations against the Authority. The court also dismissed the Department's contention that it can enforce its workplace safety laws against the Authority because nothing in the Compact preempts Virginia law. View "Metropolitan Washington Airports Authority v. Pan" on Justia Law

The case revolves around Tondalaya Gamble, a Black physician who worked at Cook County Health’s John Stroger Hospital for approximately eleven years. Gamble sued Cook County and her former department and division chairs, Edward Linn and Fidel Abrego, alleging race discrimination. She claimed that Cook County violated Title VII of the Civil Rights Act of 1964 and the Illinois Human Rights Act, and that Linn and Abrego violated 42 U.S.C. §§ 1981 and 1983. Gamble argued that she was paid less than similarly situated non-Black physicians.The United States District Court for the Northern District of Illinois granted summary judgment in favor of the defendants, concluding that no reasonable jury could find in Gamble’s favor on any of her claims. The court found that Gamble failed to establish that she was similarly situated to her chosen comparators, two white physicians, Bruce Rosenzweig and Karen Fish. The court noted that Rosenzweig was a part-time employee while Gamble was full-time, and that Fish had more experience and was hired to perform different duties.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court agreed that no reasonable jury could find that Gamble was similarly situated to Rosenzweig or Fish. The court noted that the part-time versus full-time distinction was not dispositive in and of itself, but that other differences, such as their different duties and experience, made them inapt comparators for Gamble’s discrimination claim. The court concluded that Gamble presented no other evidence suggesting that her pay or demanding work responsibilities were because of her race. View "Gamble v. County of Cook" on Justia Law

The case involves an Asian American federal employee, Tommy Ho, who alleged that his employer declined to promote him in retaliation for his previous activity protected by Title VII. Ho had been employed as a criminal investigator in the Bureau of Alcohol, Tobacco, Firearms, and Explosives (ATF) since 1999. He filed an Equal Employment Opportunity (EEO) complaint in 2015 alleging racial discrimination. In 2017 and 2018, he applied for three promotions but was not selected for any of them. Ho filed two more EEO complaints alleging that these non-selections were due to retaliation. The case at hand centers on Ho's application for a program manager position in 2019, for which he was not selected.The district court dismissed Ho's complaint, holding that it failed to sufficiently allege a causal connection between Ho's protected EEO activity and his non-selection for the program manager position. The court concluded that the ten-month gap between Ho's latest protected activity and his non-selection was too long to support an inference of causation.The United States Court of Appeals for the District of Columbia Circuit reversed the district court's decision. The appellate court found that, when viewed as a whole and in the light most favorable to Ho, his allegations narrowly sufficed to support a plausible inference that his protected activity was a but-for cause of his non-selection. The court noted that Ho had previously complained about the conduct of the very people responsible for filling the opening, and that he was qualified for the position. The court also noted that the alleged reason for Ho's non-selection was entirely subjective. The case was remanded for further proceedings. View "Ho v. Garland" on Justia Law

Broadway producer Garth Drabinsky alleged that the Actors’ Equity Association, a union representing theater actors and stage managers, unlawfully boycotted, defamed, and harassed him during his production of the musical Paradise Square. Drabinsky brought antitrust claims and New York state tort claims against the union.The United States District Court for the Southern District of New York held that Drabinsky’s antitrust claims were barred by the statutory labor exemption derived from the Clayton Antitrust Act of 1914 and the Norris-LaGuardia Act of 1932. The court also held that his tort claims were barred under Martin v. Curran, a New York state case that requires a plaintiff seeking to hold a union liable for tortious wrongs to allege the individual liability of every single member.The United States Court of Appeals for the Second Circuit affirmed the lower court's decision. The court concluded that an antitrust plaintiff suing a union bears the burden of proving that the statutory labor exemption does not apply. The court found that Drabinsky failed to meet this burden, as the union was acting in its self-interest and did not combine with non-labor groups. The court also agreed with the lower court that Drabinsky's state-law tort claims were barred by the Martin v. Curran rule. View "Drabinsky v. Actors' Equity Association" on Justia Law