Justia Labor & Employment Law Opinion Summaries

David Steele filed a lawsuit against his employer, Johnson Controls, Inc. (JCI), alleging that the company had violated § 287.780 by retaliating and discriminating against him for filing a workers' compensation claim. Steele sought compensatory and punitive damages, arguing that JCI had acted with willful, deliberate, and reckless disregard for his rights. JCI did not file an answer or responsive pleading, and Steele subsequently filed a motion for default judgment and damages. The circuit court held a hearing regarding damages, during which Steele testified about his injuries and the discriminatory treatment he received from JCI. The court entered a default judgment for Steele, awarding him $300,000 in compensatory damages and $600,000 in punitive damages.JCI filed a motion to set aside the default judgment, citing Rules 75.01, 74.05(d), and 74.06(b)(1). JCI alleged that it had good cause for the default because its registered agent mislabeled the service documents and routed them to the incorrect section of JCI's legal department. The circuit court held a hearing on JCI's motion and subsequently overruled it, concluding that JCI failed to show good cause, a meritorious defense, or excusable neglect. JCI then filed a motion for a new trial, which the circuit court also overruled. JCI appealed the decision.The Supreme Court of Missouri affirmed the circuit court's judgment. The court found that JCI had failed to prove good cause for its default as required to set aside the default judgment pursuant to Rule 74.05(d). The court also found that JCI's reliance on Rules 75.01 and 74.06(b)(1) as alternate bases to set aside the default judgment was incorrect. Finally, the court ruled that JCI's defaulted claims asserting the circuit court plainly erred by awarding punitive damages in violation of § 510.2612 were not reviewable. View "Steele v. Johnson Controls, Inc." on Justia Law

The case involves Ramon Dejesus Cedeno, an employee of Strategic Financial Solutions, LLC, and a participant in its Strategic Employee Stock Ownership Plan. Cedeno sued the company, its trustee Argent Trust Company, and other defendants under the Employee Retirement Income Security Act (ERISA), alleging that a transaction caused the Plan to incur substantial losses and that Argent breached fiduciary duties owed to Plan participants. The defendants moved to compel arbitration under the Federal Arbitration Act (FAA), pointing to a provision in the Plan’s governing document that required Plan participants to resolve any claims related to the Plan in arbitration.The United States District Court for the Southern District of New York denied the motion, reasoning that the agreement was unenforceable because it would prevent Cedeno from effectuating rights guaranteed by Congress through ERISA, namely, the plan-wide relief available under Section 502(a)(2) to enforce the rights established in ERISA Section 409(a).On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court held that the arbitration provision is unenforceable because it would prevent Cedeno from pursuing the Plan-wide remedies Sections 409(a) and 502(a)(2) unequivocally provide. The court concluded that the entire arbitration provision is null and void due to a non-severability clause in the Plan. View "Cedeno v. Sasson" on Justia Law

The case revolves around a dispute over workers' compensation. The appellant, Brian Caldwell, was injured while working for the appellee, Whirlpool Corporation. After a successful initial workers’ compensation claim, Caldwell sought coverage for additional conditions a few years later. However, his claim for these additional conditions was denied after administrative hearings before the commission. Caldwell then appealed to a court of common pleas under R.C. 4123.512. The trial court and the court of appeals, in granting and affirming summary judgment in favor of Whirlpool, determined that Caldwell’s claim had expired as a matter of law because a separate statute, R.C. 4123.52, limited the commission’s continuing jurisdiction to five years from the date of the last payment of compensation on Caldwell’s initial claim and that five years had passed.The Supreme Court of Ohio disagreed with the lower courts' interpretation. The court held that when a workers’ compensation claimant perfects an appeal under R.C. 4123.512, the subsequent expiration of the commission’s five-year period of continuing jurisdiction under R.C. 4123.52 does not cause the claim that is pending in court to expire as a matter of law. The court reasoned that R.C. 4123.52, which establishes the continuing jurisdiction of the commission, does not affect R.C. 4123.512 court proceedings once they have been properly initiated. Therefore, the Supreme Court of Ohio reversed the judgment of the Third District Court of Appeals and remanded the case to the trial court for further proceedings. View "Caldwell v. Whirlpool Corp." on Justia Law

Monica Rongere, a former Diversity Procurement Officer for the City of Rockford, Illinois, sued the city after her employment was terminated. Rongere claimed that she was overworked and underpaid compared to her male colleagues, and that her termination was due to her complaints about this disparity. She brought claims under the Equal Pay Act, Title VII of the Civil Rights Act of 1964, the Illinois Human Rights Act, the Illinois Whistleblower Act, and Illinois common law, alleging equal pay, sex discrimination, hostile work environment, and retaliation.The district court ruled in favor of the City on the Equal Pay Act, Title VII, and Illinois Human Rights Act claims, and relinquished jurisdiction over the remaining state-law claims. Rongere appealed this decision.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that Rongere failed to identify adequate comparators for her equal pay and sex discrimination claims, did not show that she engaged in protected activity based on an objectively reasonable belief for her retaliation claim, did not present sufficient evidence of a hostile work environment, and did not explain how the district court abused its discretion in relinquishing jurisdiction over the remaining claims. The court also found that Rongere did not hold an objectively reasonable belief that the City paid male employees more than female employees for the same work, which was necessary for her retaliation claims. View "Rongere v. City of Rockford" on Justia Law

The case involves Duke Bradford, Arkansas Valley Adventure (AVA), and the Colorado River Outfitters Association (CROA) who appealed against the District of Colorado’s order denying their motion to preliminarily enjoin a Department of Labor (DOL) rule. The rule required federal contractors to pay their employees a $15.00 minimum hourly wage. The DOL promulgated the rule pursuant to a directive in Executive Order (EO) 14,026, issued by President Biden. The EO imposed the minimum wage requirement on most federal contractors and rescinded an exemption for recreational services outfitters operating on federal lands.The appellants argued that the district court erred in concluding that the Federal Property and Administrative Services Act (FPASA) authorizes the minimum wage rule as applied to recreational services permittees because the government does not procure any services from them or supply anything to them. They also argued that the DOL acted arbitrarily and capriciously in promulgating the minimum wage rule without exempting recreational service permittees.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court concluded that the appellants have not shown a substantial likelihood of success on the merits that the DOL’s rule was issued without statutory authority. The court held that FPASA likely authorizes the minimum wage rule because the DOL’s rule permissibly regulates the supply of nonpersonal services and advances the statutory objectives of economy and efficiency. The court also held that the appellants have not shown a substantial likelihood of success on the merits that the DOL’s rule is arbitrary and capricious. View "Bradford v. U.S. Department of Labor" on Justia Law

The Supreme Court of Alaska affirmed a lower court's decision that the Copper River Native Association (CRNA), a non-profit corporation formed by federally recognized Alaska Native tribes, is an arm of its member tribes and thus entitled to tribal sovereign immunity. The case arose when a former employee sued CRNA over her termination. The superior court dismissed her complaint, concluding that CRNA was an arm of its member tribes and therefore entitled to sovereign immunity. The former employee appealed, arguing that CRNA was not entitled to tribal immunity. The Supreme Court of Alaska agreed with CRNA that the legal landscape defining the contours of tribal sovereign immunity has shifted significantly since its 2004 decision in Runyon ex rel. B.R. v. Association of Village Council Presidents. The court adopted a multi-factor inquiry to determine whether an entity is entitled to “arm-of-the-tribe” immunity. Applying this multi-factor inquiry, the court concluded that CRNA is an arm of its member tribes and affirmed the superior court's decision. View "Ito v. Copper River Native Association" on Justia Law

The plaintiff, an adjunct professor at New York University (NYU), experienced offensive and demeaning conduct from her colleagues, including unsolicited offensive mail and online impersonation. She reported these incidents to NYU, which conducted investigations and took measures to limit the impact on her. However, dissatisfied with NYU's response, she filed a lawsuit in the United States District Court for the Southern District of New York against NYU and certain administrators, as well as the individuals she claimed were responsible for the conduct against her. The lawsuit alleged discrimination, hostile work environment, retaliation, and intentional infliction of emotional distress.The federal court granted summary judgment to the defendants, finding that the plaintiff failed to present evidence that NYU responded negligently or that her termination was a pretext for discrimination. The court declined to exercise supplemental jurisdiction over the plaintiff's claims under the New York State Human Rights Law (State HRL) and the New York City Human Rights Law (City HRL), dismissing those claims without prejudice. The plaintiff appealed the dismissal of her hostile work environment and retaliation claims, and the Second Circuit affirmed.While her appeal was pending, the plaintiff filed a nearly identical suit in the Supreme Court, Bronx County, alleging violations of the State and City HRLs, renewing her intentional infliction of emotional distress claim, adding another NYU administrator as a defendant, and asserting a new protected category of disability. The Supreme Court dismissed the plaintiff's complaint as barred by collateral estoppel and for failing to state a claim. The Appellate Division affirmed the dismissal, and the plaintiff appealed to the New York Court of Appeals.The New York Court of Appeals affirmed the lower courts' decisions, holding that the plaintiff's claims were barred by collateral estoppel based on the findings of the federal district court. The court also held that the individual defendants, who were the plaintiff's co-workers rather than her supervisors, could not be held liable under the City HRL. The court noted that while the City HRL provides for individual liability, it does so only for those who have a role in administering the compensation, terms, conditions, or privileges of the plaintiff's employment. View "Russell v New York Univ." on Justia Law

Rick Milteer, a disabled veteran and an observant African American Messianic Jewish believer, was employed by Navarro County, Texas, in its Texoma High Intensity Drug Trafficking Area (HIDTA) division as an Information Technology (IT) manager. Milteer alleged that he faced discrimination, retaliation, and failure to accommodate in violation of Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act of 1990, and the Texas Commission on Human Rights Act. His claims were based on his supervisor's refusal to allow him to work remotely while recovering from surgery and during the Covid-19 pandemic, and his subsequent suspension and termination after he discovered a data breach and reported it.The district court granted summary judgment in favor of Navarro County, dismissing all of Milteer's claims. The court found that Navarro County was Milteer's employer and that the County had provided a legitimate, non-discriminatory reason for terminating Milteer's employment. The court also found that Milteer had failed to produce any evidence that he had informed the County of his disabilities or requested an accommodation from the County.The United States Court of Appeals for the Fifth Circuit vacated the district court's judgment and remanded the case for further proceedings. The appellate court found that the district court erred in treating Navarro County and the Texoma HIDTA as separate entities and in failing to impute the actions of Milteer's supervisor to the County. The court held that the Texoma HIDTA was not a legal entity capable of employing individuals, and that the actions and inactions of Milteer's supervisor could be imputed to the County. The court concluded that this error impacted the district court's analysis of Milteer's claims, necessitating a remand for further proceedings. View "Milteer v. Navarro County" on Justia Law

The case involves William Schmidt, an employee of Tesoro Logistics, who was injured while working at a site owned and operated by Hess Corporation. Schmidt claimed that Hess required him to use breathing air equipment, installed by Basin Safety Consulting Corporation, which caused him to trip and fall, injuring his arm and shoulder. He filed negligence and premises liability claims against both Hess and Basin Safety.The District Court of McKenzie County dismissed Schmidt’s claims on summary judgment, ruling that neither Hess nor Basin Safety owed him a duty of care. The court determined that while Hess required Schmidt to wear an air hose, it did not specify the method of using it, thus Hess did not retain control over Schmidt. The court also ruled that Basin Safety did not owe a duty of care to Schmidt as it did not provide training regarding the air hose or have any control over the worksite.Upon appeal, the Supreme Court of North Dakota affirmed the judgment in favor of Basin Safety but reversed the judgment in favor of Hess. The court found that there were genuine issues of material fact regarding whether Hess owed Schmidt a duty of care. The court concluded that evidence indicating Hess required the use of the air hose and prohibited its use in a manner preferred by the workers could be seen as Hess retaining control over the work. The case was remanded for further proceedings. View "Schmidt v. Hess Corp." on Justia Law

This case revolves around an employment dispute where Renee Vines sued his former employer, O’Reilly Auto Enterprises, LLC, for violations of the Fair Employment and Housing Act (FEHA), alleging causes of action for race- and age-based discrimination, harassment, and retaliation. A jury found in his favor on his causes of action for retaliation and failure to prevent retaliation, but against him on his other causes of action. Vines moved for statutory attorneys’ fees, which the trial court granted but awarded only a portion of the requested amount. Vines appealed, and the appellate court reversed, holding that the trial court erred in its determination of the fees.The trial court had initially awarded Vines a reduced amount of attorneys’ fees, based on its determination that Vines's unsuccessful discrimination and harassment causes of action were not closely related to or factually intertwined with his successful retaliation causes of action. Vines appealed this decision, and the appellate court reversed, holding that the trial court erred in its determination. On remand, the trial court awarded Vines a significantly larger amount in fees.O’Reilly Auto Enterprises, LLC, appealed from the order denying its motion to vacate the renewal of judgment, challenging only the amount of interest on the award of attorneys’ fees. O’Reilly argued that, because the appellate court's decision in the prior appeal was a reversal, not a modification, of the trial court’s initial order, interest on the amount of attorneys’ fees awarded should run from the date of the second order, not the first. The appellate court agreed with O’Reilly, reversed the order denying O’Reilly’s motion to vacate the renewed judgment, and directed the trial court to grant the motion. View "Vines v. O'Reilly Auto Enterprises" on Justia Law