Justia Labor & Employment Law Opinion Summaries

A police sergeant in Dermott, Arkansas, was terminated from his position after being charged with tampering with physical evidence and abuse of office. The charges stemmed from an incident in which the sergeant received a bag of quarters, believed to be stolen, from another officer following a robbery investigation. The sergeant’s documentation of the evidence was inconsistent, and the quarters were not turned in to the department. During a subsequent investigation, the sergeant admitted he may have used the quarters for personal purposes. Although the charges were later dismissed, the sergeant maintained that his termination was solely due to the criminal charges. He also previously reported another officer’s excessive use of force, which he claimed was a motivating factor in his firing.The United States District Court for the Eastern District of Arkansas granted summary judgment and judgment on the pleadings in favor of the defendants, including the police chief, the officer involved, and the city. The court found that the sergeant failed to establish a genuine dispute of material fact regarding whether his termination was motivated by his protected speech, as the firing occurred long after his report and the criminal charges provided an obvious alternative explanation. The court also determined that the sergeant was not seized under the Fourth Amendment, negating his malicious prosecution claim, and that he lacked a property interest in his employment under Arkansas law, defeating his due process claims. The court exercised supplemental jurisdiction over the state law claims and found them lacking on the merits, including claims under the Arkansas Whistle-Blower Act, malicious prosecution, abuse of process, and defamation.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court held that the sergeant failed to present sufficient evidence to support his federal constitutional claims or his state law claims, and that the district court did not abuse its discretion in retaining and resolving the state law claims. View "Brown v. City of Dermott Arkansas" on Justia Law

The plaintiff, a former police officer in Dermott, Arkansas, alleged that he was forced to resign in retaliation for reporting a fellow officer’s excessive use of force. The incident in question involved the other officer grabbing an arrestee by the neck while the arrestee was restrained. Subsequently, the officer accused the plaintiff of taking money from a parolee, which the parolee confirmed in a statement. The police chief referred the matter to a prosecutor, who initiated a state police investigation. During this period, the plaintiff’s employment status became unclear, with conflicting statements about whether he was fired or resigned. The plaintiff ultimately resigned after a job offer from another police department was rescinded due to the ongoing investigation. He was later charged with abuse of office and witness bribery, but the charges were dismissed when the parolee could not be located.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants on all claims. The court found that the plaintiff had voluntarily resigned and had not suffered an adverse employment action, which was necessary for his First Amendment retaliation claim. The court also determined that the plaintiff was not “seized” within the meaning of the Fourth Amendment for his malicious prosecution claim, as a summons to appear in court did not constitute a seizure. The court exercised supplemental jurisdiction over the state law claims and found that they failed on the merits, including claims under the Arkansas Whistle Blower Act, malicious prosecution, abuse of process, and defamation.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that the plaintiff’s voluntary resignation did not amount to an adverse employment action, and that he was not seized under the Fourth Amendment. The court also agreed that the state law claims failed as a matter of law. View "Brown v. City of Dermott Arkansas" on Justia Law

Dean Naylor served as the jail administrator for the Muscatine County Sheriff’s Office from 2010 until his termination in May 2020. His firing followed public controversy over religious commentary he posted online, including a document and YouTube videos expressing post-tribulation Rapture beliefs and making inflammatory statements about Muslims and the gay community. After a local newspaper article highlighted these views, public officials and community members raised concerns about the treatment of detainees at the jail, and representatives from Johnson County and the United States Marshals Service questioned whether they would continue housing overflow inmates at the facility.Naylor sued Muscatine County in the United States District Court for the Southern District of Iowa, alleging his termination violated Title VII by discriminating against him based on his religion. The district court granted summary judgment to Muscatine County, finding that retaining Naylor would impose an undue hardship on the County, specifically citing potential harm to the jail’s public image and the risk to business relationships with outside entities that contract for overflow detainee housing.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment ruling de novo. The appellate court held that Muscatine County had not provided sufficient evidence to establish, as a matter of law, that retaining Naylor would cause an undue hardship under Title VII. The court found that the evidence of reputational harm and threatened business relationships was speculative and did not eliminate genuine disputes of material fact. Accordingly, the Eighth Circuit reversed the district court’s grant of summary judgment and remanded the case for further proceedings. View "Naylor v. County of Muscatine" on Justia Law

Eugene Hudson, a long-time member and leader within the American Federation of Government Employees (AFGE), was twice removed from his position as National Secretary-Treasurer after he criticized the union’s leadership and use of resources while campaigning for union president. Hudson’s communications, including a letter and an email sent to union officers using union resources, led to internal disciplinary proceedings. The AFGE’s National Executive Council found that Hudson’s actions violated the union’s constitution, resulting in his removal in August 2017. After a preliminary injunction reinstated him, a second investigation led to his removal again in February 2018. Hudson amended his lawsuit to challenge both removals, alleging they were acts of retaliation for his protected speech under section 101(a)(2) of the Labor-Management Reporting and Disclosure Act (LMRDA).The United States District Court for the District of Columbia presided over a jury trial, where the jury found that AFGE unlawfully retaliated against Hudson in the first removal but not the second, awarding no damages. Hudson moved for a new trial, arguing that the jury instructions misstated the causation standard and the burden of proof. The district court denied the motion, holding that Hudson had not properly preserved his objections and that the instructions were not plainly erroneous.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that a retaliation claim under LMRDA section 101(a)(2) requires proof of but-for causation, not merely that protected speech was a motivating factor. The court also found that Hudson could not challenge the burden of proof instruction because he had proposed the language used. The court affirmed the district court’s judgment, denying Hudson’s request for a new trial. View "Hudson v. American Federation of Government Employees" on Justia Law

In this case, a group of pensioners from a multiemployer retirement fund governed by ERISA challenged the reduction of their pension benefits following the enactment of the Multiemployer Pension Reform Act of 2014 (MPRA). The MPRA allowed plan administrators to reduce benefits for current and future beneficiaries in order to prevent plan insolvency, subject to certain procedural safeguards and approval by the U.S. Department of the Treasury. The plaintiffs, who had vested rights to their pension benefits, argued that these reductions constituted an uncompensated taking under the Fifth Amendment.The United States Court of Federal Claims granted summary judgment in favor of the government. The Claims Court found that while the plaintiffs had a cognizable property interest in their vested pension benefits, the reduction of those benefits did not amount to a physical taking. Instead, the court analyzed the claim as a regulatory taking under the Penn Central framework and concluded that the economic impact, interference with investment-backed expectations, and the character of the government action did not support a finding of a taking.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the Claims Court’s decision. The Federal Circuit held that the MPRA’s reduction of pension benefits was not a physical taking because the plaintiffs had only a contractual right to payment, not a property interest in the plan’s assets, and the government did not appropriate any specific property for itself or a third party. The court further held that, under the Penn Central test, the reduction did not constitute a regulatory taking, as the economic impact was not severe, the plaintiffs’ expectations were not unduly interfered with given the heavily regulated nature of pension plans, and the government action served a substantial public purpose. The judgment for the government was affirmed. View "KING v. US " on Justia Law

Four former employees of grocery store chains, who participated in a defined contribution 401(k) retirement plan, brought a putative class action under the Employee Retirement Income Security Act of 1974 (ERISA). They alleged that the plan’s fiduciaries mismanaged the plan by failing to prudently select and monitor investment options, failing to act solely in the interest of plan participants, and allowing excessive fees and improper compensation arrangements. The plaintiffs sought monetary and injunctive relief on behalf of themselves, the plan, and a proposed class of similarly situated participants.The United States District Court for the Northern District of New York dismissed several of the plaintiffs’ claims for lack of Article III standing, finding that the plaintiffs had not alleged any concrete injury to their individual accounts from the alleged mismanagement of certain investment options or from the plan’s compensation arrangements. The district court concluded that because the plaintiffs had not invested in the specific funds they challenged, or had not shown that the alleged breaches affected their own accounts, they lacked standing to pursue those claims. The court did find standing for some claims related to funds in which the plaintiffs had invested, but ultimately dismissed those claims for failure to state a claim and denied leave to amend.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s dismissal of the claims for lack of standing. The Second Circuit held that participants in a defined contribution plan must plausibly allege a concrete, individualized financial injury to establish Article III standing for monetary relief under ERISA. Because the plaintiffs did not allege that they suffered losses in their own accounts from the challenged conduct, they lacked both individual and class standing for those claims. The court affirmed in part and vacated in part the district court’s judgment, remanding for further proceedings consistent with its opinion. View "Collins v. Ne. Grocery, LLC" on Justia Law

A white male lieutenant who had worked for the Louisiana State Police since 1995 applied for promotion to captain 31 times between 2008 and 2021 but was never selected. He alleged that, on at least two occasions, he was the most qualified candidate but was passed over in favor of non-white applicants. The two specific promotions at issue involved positions in specialized divisions where the selected candidates, both non-white, had prior experience in those divisions, while the plaintiff did not. The plaintiff claimed he had higher test scores, more time in grade, and more commendations than the selected candidates. Instead of promotion, he was offered opportunities to gain broader experience and interview advice, but he chose to retire and then filed suit alleging racial discrimination under Title VII and 42 U.S.C. § 1981, as well as constructive discharge and retaliation.The United States District Court for the Eastern District of Louisiana dismissed the § 1981, constructive discharge, and retaliation claims, finding the § 1981 claim time-barred by Louisiana’s one-year statute of limitations for such actions. After discovery, the district court granted summary judgment to the employer on the Title VII claim, holding that the plaintiff failed to rebut the employer’s legitimate, nondiscriminatory reasons for its promotion decisions—namely, the selected candidates’ relevant experience in the specific divisions. The court found no evidence that race was a motivating factor in the decisions.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the summary judgment de novo and affirmed the district court’s rulings. The Fifth Circuit held that the plaintiff failed to present evidence sufficient to create a genuine dispute of material fact regarding pretext or mixed-motive discrimination under Title VII. The court also affirmed the dismissal of the § 1981 claim, agreeing that the one-year limitations period applied because the promotion would have created a new and distinct employment relationship. View "Stelly v. Dept of Public Safety" on Justia Law

An attorney formerly employed by the Federal Public Defender’s Office (FDO) for the Western District of North Carolina alleged that her supervisor sexually harassed her. After she reported the harassment, the FDO’s Unit Executive took steps to separate her from the supervisor, including changing reporting lines, authorizing telework, and offering her a promotion. The attorney also initiated proceedings under the judiciary’s Employee Dispute Resolution (EDR) Plan, which provided for both investigation and mediation. During this process, she alleged additional retaliation and discrimination by the Unit Executive. She ultimately left her position and withdrew from the EDR process before a formal hearing could occur.The United States District Court for the Western District of North Carolina conducted a six-day bench trial and issued a lengthy decision. The court found that, while there were procedural missteps and some insensitive comments by supervisors, the FDO’s response to the harassment was not deliberately indifferent, retaliatory, or discriminatory. The court also found that the attorney’s due-process rights were not violated, as she was not coerced to abandon the EDR process based on a reasonable belief that the Unit Executive would be the final decisionmaker. The court granted summary judgment to two other officials, finding no evidence of discriminatory intent or deliberate indifference, and excluded certain “Me Too” evidence as inadmissible.The United States Court of Appeals for the Fourth Circuit, with a panel of judges from outside the circuit due to recusals, reviewed the case. The court affirmed the district court’s rulings, holding that the attorney failed to prove a due-process violation or equal-protection claim. The court found that the EDR process, while imperfect, was not fundamentally unfair or coercive, and that the FDO’s response to the harassment was not clearly unreasonable. The court also held that any error in excluding the “Me Too” evidence was harmless, denied the attorney’s motions to unseal certain materials and for summary reversal, and declined to consider a new constitutional challenge to Title VII’s exclusion of judiciary employees. View "Strickland v. Moritz" on Justia Law

A former federal employee alleged that her union mishandled an arbitration proceeding and discriminated against her based on sex and disability. She claimed that the union’s local president made unwanted sexual advances, disparaged her status as a nursing mother, and ultimately withdrew union support for her grievance against her employer. The employee filed several unfair labor practice (ULP) charges with the Federal Labor Relations Authority (FLRA), some of which were dismissed as untimely, and also filed a discrimination charge with the Equal Employment Opportunity Commission (EEOC), which issued her a right-to-sue letter. She then brought two lawsuits in federal district court: one alleging violations of Title VII and the Americans with Disabilities Act (ADA) against the union and its local, and another, pro se, alleging retaliation under the Fair Labor Standards Act (FLSA) against the union, its local, and two union officials.The United States District Court for the District of Columbia dismissed both lawsuits for lack of subject matter jurisdiction. The court reasoned that the Federal Service Labor-Management Relations Statute (FSLMRS) precluded the employee’s claims, holding that her allegations were essentially claims for breach of the union’s duty of fair representation, which must be pursued exclusively through the FLRA’s administrative process.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the dismissals de novo. The court held that the FSLMRS does not preclude federal employees from bringing Title VII and ADA claims against their unions in federal district court, even when the alleged conduct could also constitute a ULP. The court reasoned that Congress did not intend to displace these specific statutory discrimination remedies with the FSLMRS’s more limited scheme. However, the court affirmed the dismissal of the FLSA retaliation claim, finding no indication that Congress intended for such claims against unions to proceed in district court alongside the FSLMRS process. The case was remanded for further proceedings on the Title VII and ADA claims. View "Lucas v. American Federation of Government Employees" on Justia Law

A former employee of a Defense Commissary Agency store at Offutt Air Force Base alleged that he was denied reasonable accommodations for his disabilities, harassed, and discriminated against based on his race and gender. The employee’s father initially raised concerns with management about the employee’s need for support and mentioned a disability, but neither the employee nor his father specified the nature of the disability at that time. The employee later complained about work assignments, leave requests, and comments from supervisors, believing these actions were motivated by discriminatory animus. After resigning, he sought to engage in the reasonable accommodation process, submitting a form that listed several diagnoses, but it was later revealed that his father, not a medical professional, had completed the relevant sections.The United States District Court for the District of Nebraska granted summary judgment to the Secretary of Defense on all claims. The court found that the employee failed to provide sufficient evidence of a disability or to show that he had requested or been denied a reasonable accommodation. The court also determined that there was no evidence connecting alleged harassment to the employee’s race or gender, nor was there evidence of conduct severe or pervasive enough to constitute a hostile work environment.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo and affirmed the district court’s judgment. The appellate court held that the employee did not produce sufficient evidence to establish that he was disabled within the meaning of the Rehabilitation Act, nor did he make a facial showing necessary for a failure-to-accommodate claim. Additionally, the court concluded that the conduct alleged did not meet the threshold for a hostile work environment under Title VII, as it was not sufficiently severe or pervasive. The judgment in favor of the Secretary of Defense was affirmed. View "Yelder v. Hegseth" on Justia Law