Justia Labor & Employment Law Opinion Summaries

Taiwo Ayorinde sued his former employer, Team Industrial Services Incorporated, alleging various employment discrimination claims. Ayorinde was initially employed by Team from 2016 to 2018 and rehired in 2022. During his second tenure, his supervisor expressed concerns about his work quality and demoted him, resulting in a pay cut. While on bereavement leave, Ayorinde discovered the pay cut, which was later reversed by Team. Ayorinde resigned, citing a hostile work environment and discrimination, and subsequently filed a discrimination charge with the EEOC.The United States District Court for the Western District of Texas granted summary judgment in favor of Team on all claims and denied Ayorinde’s motion for partial summary judgment. The court found that Ayorinde failed to establish a prima facie case for his claims, including race discrimination, retaliation, constructive discharge, and hostile work environment. Ayorinde appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo and affirmed the district court’s decision. The appellate court agreed that Ayorinde did not provide sufficient evidence to support his claims. Specifically, Ayorinde failed to show that he was treated less favorably than similarly situated employees outside his protected group, which is necessary to establish a prima facie case of race discrimination. Additionally, the court found no evidence of retaliatory adverse employment action based on protected activity, and Ayorinde did not exhaust his administrative remedies regarding his constructive discharge and hostile work environment claims. The court also noted that Ayorinde abandoned his claims under the Lilly Ledbetter Fair Pay Act and the Age Discrimination in Employment Act by not adequately briefing them on appeal. View "Ayorinde v. Team Industrial" on Justia Law

Miko Thomas, an employee of JBS Green Bay, filed a lawsuit under Title VII of the Civil Rights Act of 1964, alleging racial discrimination. He claimed that his employer delayed his training for three years, denied his vacation requests while approving similar requests for others, and transferred him to a different shift despite knowing it caused childcare issues. Thomas argued these actions were discriminatory based on his color.The United States District Court for the Eastern District of Wisconsin dismissed Thomas's complaint under Rule 12(b)(6) for failure to state a claim. The court found that the alleged events were not serious enough to be actionable under Title VII and that Thomas's complaint did not include all necessary elements to prove his case. After Thomas amended his complaint, the district court dismissed the suit outright, maintaining that the complaint lacked sufficient detail and did not meet the required legal standards.The United States Court of Appeals for the Seventh Circuit reviewed the case and found the district court's dismissal to be mistaken. The appellate court held that the district court incorrectly required the complaint to allege significant or material injury, which is not necessary under Title VII as clarified by the Supreme Court in Muldrow v. St. Louis. The appellate court also noted that the district court improperly demanded that the complaint include every element of proof needed for summary judgment, contrary to the notice pleading standard established by the Federal Rules of Civil Procedure and reaffirmed in Swierkiewicz v. Sorema N.A.The Seventh Circuit reversed the district court's dismissal and remanded the case for further proceedings, allowing it to move to the summary-judgment stage and potentially to trial. View "Thomas v. JBS Green Bay, Inc." on Justia Law

Julian Rodriguez, a former employee of Lawrence Equipment, Inc., filed a lawsuit alleging various wage-and-hour violations under the California Labor Code. Rodriguez claimed that Lawrence failed to pay for all hours worked, including overtime, did not provide adequate meal and rest breaks, issued inaccurate wage statements, and did not pay all due wages upon termination. He also sought civil penalties under the Private Attorneys General Act (PAGA). Rodriguez had signed an arbitration agreement with Lawrence, which led to the arbitration of his non-PAGA claims.The Superior Court of Los Angeles County ordered arbitration for Rodriguez’s wage-and-hour claims and stayed the PAGA claim. The arbitrator ruled in favor of Lawrence, finding that Rodriguez failed to prove any of the alleged Labor Code violations. The trial court confirmed the arbitration award and entered judgment for Lawrence. Subsequently, Lawrence moved for judgment on the pleadings, arguing that the arbitration award precluded Rodriguez from pursuing his PAGA claim due to lack of standing as an aggrieved employee. The trial court granted this motion and dismissed the PAGA claim.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the arbitration award, which found no Labor Code violations, precluded Rodriguez from establishing standing under PAGA. The court applied the doctrine of issue preclusion, determining that the issues litigated in arbitration were identical to those required to establish PAGA standing. Since Rodriguez could not prove any Labor Code violations, he lacked standing to pursue the PAGA claim. The court affirmed the trial court’s judgment of dismissal. View "Rodriguez v. Lawrence Equipment, Inc." on Justia Law

The case involves the termination of a police chief, Erica Barga, by the Village Council of St. Paris. Barga was placed on administrative leave by the mayor, who filed charges against her for insubordination and neglect of duty. Barga requested a public hearing to address these charges. The village council conducted the hearing in public but deliberated in executive session before voting to terminate Barga's employment.The Champaign County Court of Common Pleas upheld the village council's decision, concluding that Barga did not have a substantive or procedural right to have the entire disciplinary hearing open to the public. The court also found that the village council's decision was presumed valid and that Barga had not overcome this presumption.The Second District Court of Appeals affirmed the lower court's decision regarding the Open Meetings Act, relying on a federal district court decision that exempted quasi-judicial proceedings from the Act. However, it found that the common pleas court had applied the wrong standard of review and remanded the case for a de novo review.The Supreme Court of Ohio reversed the court of appeals' decision, holding that the village council violated the Open Meetings Act by deliberating in executive session after Barga requested a public hearing. The court emphasized that the plain terms of the Act required the council to consider the charges in a public hearing. The court remanded the case to the village council for a public hearing in compliance with the Open Meetings Act. View "Barga v. St. Paris Village Council" on Justia Law

MaChelle Joseph, a former head women’s basketball coach at Georgia Tech, and Thomas Crowther, a former art professor at Augusta University, filed separate complaints alleging sex discrimination and retaliation under Title IX and other laws. Joseph claimed that Georgia Tech provided fewer resources to the women’s basketball team compared to the men’s team and retaliated against her for raising these issues. Crowther alleged that he was retaliated against after being accused of sexual harassment and participating in the investigation.The United States District Court for the Northern District of Georgia dismissed Joseph’s Title IX claims, ruling that Title VII precluded them, and granted summary judgment against her remaining claims. For Crowther, the district court denied the motion to dismiss his Title IX claims, allowing them to proceed.The United States Court of Appeals for the Eleventh Circuit reviewed these consolidated appeals. The court held that Title IX does not provide an implied right of action for sex discrimination in employment, reversing the district court’s decision to allow Crowther’s Title IX claims and affirming the dismissal of Joseph’s Title IX claims. The court also ruled that Crowther’s retaliation claim under Title IX, based on his participation in the investigation, did not state a valid claim. Additionally, the court found that Joseph’s claims of sex discrimination under Title VII, based on her association with the women’s team, were not viable. Finally, the court affirmed the summary judgment against Joseph’s retaliation claims under Title VII, Title IX, and the Georgia Whistleblower Act, concluding that she failed to show that the reasons for her termination were pretextual. View "Joseph v. Board of Regents of the University System of Georgia" on Justia Law

Leroy Williams, a special police officer with the D.C. Department of General Services (DGS), was terminated in August 2019 for conduct related to unauthorized traffic stops. He was given three options to appeal: filing an appeal with the Office of Employee Appeals, having his union (Fraternal Order of Police, FOP) file a grievance, or filing a grievance personally. Williams chose the second option, and FOP filed a grievance on his behalf. When the grievance could not be settled, it was advanced to arbitration, where the arbitrator upheld Williams's termination.FOP then sought review from the Public Employee Relations Board (PERB), which upheld the arbitrator's decision. FOP subsequently petitioned the Superior Court of the District of Columbia for review, which affirmed PERB's decision. After FOP's counsel withdrew, Williams filed an appeal to the District of Columbia Court of Appeals on his own.The District of Columbia Court of Appeals reviewed whether Williams had standing to bring the appeal. The court noted that the collective bargaining agreement granted the union the sole authority to arbitrate grievances and, consequently, the sole authority to appeal arbitration decisions. The court found that Williams lacked standing to appeal because only the union could pursue such an appeal unless the union breached its duty of fair representation, which was not argued in this case.The court dismissed Williams's appeal for lack of standing, concluding that he could not independently challenge the arbitration award under the terms of the collective bargaining agreement. View "Williams v. Department of General Services" on Justia Law

Plaintiffs, former officers of the City of Perris Police Department or their surviving spouses, claimed that the closure of the Perris PD and their subsequent hiring by the Riverside County Sheriff’s Department resulted in a merger of the two departments under Government Code section 20508. They argued that this merger required Riverside County and the Public Employees Retirement System (CalPERS) to credit their service with the Perris PD as service with the Sheriff’s Department, entitling them to a more generous pension.The Superior Court of Riverside County found that section 20508 only applies when there is a merger of contracts between successive employing agencies and CalPERS. The court concluded that no such merger occurred because Riverside County did not assume any of the City’s municipal functions. Consequently, the service pensions for the Perris PD officers and the Sheriff’s Department deputies were calculated and paid out by CalPERS under separate contracts with the City and County, respectively. The court ruled in favor of the defendants, Riverside County and CalPERS.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court held that section 20508 requires an actual merger of the contracting agencies’ CalPERS contracts before the succeeding agency assumes any statutory obligations. The court found that the County did not assume the City’s municipal obligations but merely contracted to provide law enforcement services. Therefore, the requirements for a contract merger under section 20508 were not met. The court affirmed the trial court’s judgment, concluding that the County and CalPERS were not required to treat the former police officers’ service as service with the Sheriff’s Department. View "Petree v. Public Employees' Retirement System" on Justia Law

Alfreida Hogan, an African-American woman, was employed by the Department of Veterans Affairs (VA) as a nurse practitioner from July 2012 until March 2019, when she was demoted to staff nurse and subsequently resigned. She alleged that her immediate supervisor harassed her and gave her false, negative performance reviews due to her race, leading to her demotion. In April 2019, Hogan contacted her agency counselor, claiming racial discrimination. On July 3, 2019, the counselor informed her that informal resolution efforts had ended and that she could file a formal administrative complaint. Hogan's counsel claimed to have emailed the complaint on July 19, 2019, but the VA never received it. Hogan's counsel did not follow up until April 2020, when he learned the VA had not received the complaint. The VA dismissed the complaint due to the missed 15-day filing deadline.The district court dismissed Hogan's Title VII claims for race discrimination and retaliation, citing the Eleventh Circuit's decision in Crawford v. Babbitt, which held that failure to exhaust administrative remedies was a jurisdictional bar. The district court concluded it lacked subject-matter jurisdiction due to Hogan's untimely filing of her administrative complaint.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court determined that the 15-day deadline to file a formal administrative complaint, set by EEOC regulation 29 C.F.R. § 1614.106(b), is a claims-processing rule subject to equitable tolling, not a jurisdictional requirement. The court noted that Crawford did not control this case because it involved a different issue. The court also referenced the Supreme Court's decision in Fort Bend County v. Davis, which held that Title VII's charge-filing requirement is not jurisdictional. Despite this, the court affirmed the district court's dismissal, concluding that Hogan did not demonstrate due diligence to warrant equitable tolling of the 15-day deadline. View "Hogan v. Secretary, U.S. Department of Veterans Affairs" on Justia Law

Jeannine Bedard, a Los Angeles Police Department (LAPD) officer, refused to comply with the City of Los Angeles’s COVID-19 vaccination mandate and did not sign a notice enforcing the mandate. Consequently, the Chief of Police sought to terminate her employment. The LAPD Board of Rights reviewed the proposed discipline, found Bedard guilty of failing to comply with conditions of employment, and upheld her discharge. The Board also found that the City violated Bedard’s due process rights by not providing sufficient time to respond to the charges and awarded her back pay, which the City did not pay.Bedard filed a petition for a writ of mandate in the Superior Court of Los Angeles County, arguing that the disciplinary action was procedurally and legally invalid and seeking reinstatement and back pay. The trial court found the termination justified but agreed that the City violated Bedard’s due process rights by giving her insufficient time to respond. The court awarded her back pay.The California Court of Appeal, Second Appellate District, Division Three, reviewed the case. Bedard argued that her termination was improper because it was based on her refusal to sign an allegedly illegal contract, was too harsh a penalty, and violated her due process rights under Skelly v. State Personnel Board. The appellate court affirmed the trial court’s decision, holding that Bedard’s refusal to comply with the vaccination mandate justified her termination. The court found substantial evidence supporting the trial court’s conclusion that Bedard’s termination was not solely based on her refusal to sign the notice but also on her refusal to comply with the vaccination requirement. The court also held that the appropriate remedy for the due process violation was back pay, not reinstatement. View "Bedard v. City of Los Angeles" on Justia Law

A group of current and former employees of Professional Transportation, Inc. filed a collective action under the Fair Labor Standards Act (FLSA) in 2014, alleging overtime and minimum-wage violations. The district court conditionally certified the collective action, and approximately 3,500 workers opted in. However, the court later decertified the collective action, deeming it overbroad, and the suit was abandoned without an appeal. Subsequently, a second collective action was filed in a different district court on behalf of over 1,400 workers, including a new claim regarding the company's commute-time adjustment formula. This case was transferred to the Southern District of Indiana, which conditionally certified a collective action on the commute-time claim but later decertified it due to the formula's inconsistent application across locations.The Southern District of Indiana severed the claims, leaving Joseph Miller as the sole plaintiff, and determined that the statute of limitations barred Miller's claim. The plaintiffs' lawyers filed a notice of appeal. However, the main issue on appeal was the lack of an appellant, as the named plaintiffs did not file written consents to join the suit as required by 29 U.S.C. §216(b). The court found that the consents from the earlier suit could not be recycled for the new case, and the forms authorizing counsel to represent the plaintiffs were not sufficient consents to join the lawsuit.The United States Court of Appeals for the Seventh Circuit dismissed the appeal due to lack of jurisdiction, as the plaintiffs' lawyers prosecuted the appeal on behalf of individuals who were not parties to the case. The court emphasized that without proper written consents, the named plaintiffs were not parties and could not appeal. The court also noted that the district court's ruling on the statute of limitations for Miller's claim was not adequately contested on appeal. View "Ghafoor v. Professional Transportation, Inc." on Justia Law