Justia Labor & Employment Law Opinion Summaries

Two male Los Angeles Police Department officers were investigated after allegations arose that a suspect in their custody had been mistreated. While a thorough internal affairs investigation failed to determine who was responsible for the alleged misconduct, both male officers were subjected to disciplinary actions that included removal from field duties, searches of their personal belongings, and, ultimately, being relieved from duty pending a potential termination hearing. Their female partners, who were present during some of the events but received less scrutiny, were not similarly disciplined. A union representative eventually relayed a remark from a high-ranking official suggesting that the nature of the alleged misconduct was something “guys would do, not females.”Following the internal proceedings, the officers received official reprimands, but the chief of police ultimately stopped the termination process. The officers then filed suit against the City of Los Angeles in the Superior Court of Los Angeles County, bringing claims under California’s Fair Employment and Housing Act for gender discrimination and retaliation. At trial, the jury found for the officers, awarding substantial noneconomic and economic damages. The City moved for a new trial, arguing that the noneconomic damages were excessive. The trial court agreed, conditionally granting a new trial unless the officers accepted dramatically reduced awards. The officers declined, and both sides appealed.The California Court of Appeal, Second Appellate District, Division Two, reviewed the case. It held that the trial court abused its discretion by capping “garden-variety” emotional distress damages and excluding admissible testimony regarding future economic harm. The appellate court found the jury’s damages awards were supported by substantial evidence and not excessive as a matter of law. It reversed the trial court’s order for a new trial, reinstated the original judgment, and affirmed the jury’s awards. View "Glick v. Los Angeles" on Justia Law

A former employee brought suit against her previous employer and associated fiduciaries, alleging that they mismanaged the employer's retirement savings plan, which is a defined contribution plan governed by the Employee Retirement Income Security Act of 1974 (ERISA). She claimed that the fiduciaries retained underperforming investment options in the plan’s menu to generate transaction fees, in violation of their duties of prudence and loyalty, and sought plan-wide monetary and equitable relief on behalf of the plan.Previously, the United States District Court for the Central District of California reviewed the case. The defendants moved to compel arbitration, relying on provisions in the plan requiring arbitration of disputes and waiving participants’ rights to bring claims on a “class, collective, or representative basis.” The plaintiff argued that this waiver impermissibly precluded her from enforcing statutory rights under ERISA, which allow participants to sue on behalf of the plan for plan-wide relief. The district court denied the motion to compel arbitration, finding the waiver unenforceable under the effective-vindication doctrine and holding that the waiver provision was expressly non-severable, thus requiring the claims to proceed in court.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s denial of the motion to compel arbitration. The Ninth Circuit held that the plan’s waiver provision was unenforceable because it prevented the plaintiff from asserting her right under ERISA to bring representative claims for plan-wide relief—a right that ERISA expressly provides. The court further held that, under the plan’s own terms, once the waiver was found unenforceable, any representative claim must be adjudicated in court, not arbitration. Thus, the plaintiff’s breach-of-fiduciary-duty claims would proceed before the district court. View "POVER V. THE CAPITAL GROUP COMPANIES, INC." on Justia Law

The plaintiff, a lead engineer employed by JanCo FS3, LLC (doing business as Velociti Services), worked at UMB Bank's Technology Operations Center in Kansas City and later at the 1010 Grand Building. He had a permanent disabled parking placard due to an ankle replacement, which affected his mobility. After his building assignment changed, he requested to park in a handicap spot at 1010 Grand, rather than his assigned spot at the Tech Center. Velociti requested updated medical documentation to support his accommodation request, but the plaintiff only provided his handicap placard renewal paperwork, which did not explain his disability or limitations. Despite repeated requests and deadline extensions from Velociti, he did not submit the required medical certification. He continued to park in the unassigned garage, received disciplinary warnings, and was ultimately fired for insubordination.The United States District Court for the Western District of Missouri granted summary judgment in favor of the defendants, finding that the plaintiff failed to provide sufficient medical documentation to support his accommodation request and did not demonstrate that the defendants’ actions were motivated by discriminatory animus. The court held that the employer’s enforcement of its parking policy and subsequent termination of the plaintiff for insubordination constituted legitimate, non-discriminatory reasons for the adverse action.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The Eighth Circuit affirmed the district court’s decision, holding that any breakdown in the interactive process was due to the plaintiff’s failure to provide necessary medical information, not the employer’s refusal to accommodate. The court also held that the plaintiff did not present direct or indirect evidence of disability discrimination or retaliation, and that the employer’s stated reason for termination was not pretextual. The judgment for the defendants was affirmed. View "Hibbert v. MC Realty Group, LLC" on Justia Law

Five individuals obtained over $1.8 million in workplace sexual harassment judgments against various related business entities and individuals. When these judgments went unpaid, they brought a civil suit under the Racketeer Influenced and Corrupt Organizations Act (RICO) against fifteen defendants, alleging a scheme to evade collection of the judgments. The plaintiffs claimed that the defendants orchestrated fraudulent asset transfers and used a sham consignment scheme involving false customs forms to prevent the plaintiffs from seizing assets to satisfy their judgments.Previously, the United States District Court for the Southern District of Iowa dismissed the plaintiffs’ RICO claims based on predicate acts of bankruptcy crimes, money laundering, and obstruction of justice, as well as their claim for declaratory relief regarding alter ego liability. However, the court allowed the RICO claims predicated on wire fraud related to the consignment scheme to proceed. After discovery, the defendants moved for summary judgment. The district court granted summary judgment for the defendants, holding that the plaintiffs failed to show proximate causation between the alleged wire fraud and their inability to collect on their judgments, and that they were not entitled to adverse inference sanctions for alleged discovery misconduct.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court’s judgment. The Eighth Circuit held that the plaintiffs failed to establish that the consignment scheme was a but-for cause of their injury, as they did not show that any assets subject to seizure belonged to the judgment debtors. The court further concluded that claims based on other predicate offenses failed due to insufficient evidence and lack of particularity. The appellate court also found no error in the district court’s refusal to draw adverse inferences or to allow amendment of the complaints at this stage. The court affirmed summary judgment for all defendants on all claims. View "Rennenger v. Aquawood, LLC" on Justia Law

A neurosurgeon, age 75 at the time of hire, was employed by a physician group affiliated with two hospitals. He worked primarily as an assistant to another neurosurgeon, with responsibilities and compensation more in line with advanced practice professionals (APPs) than with other neurosurgeons, and did not independently cover on-call duties at both hospitals. Over time, the physician group moved toward a staffing model that relied more on APPs and expected neurosurgeons to independently manage full surgical and on-call responsibilities. During the onset of the COVID-19 pandemic, the neurosurgeon was required to work from home, with comments from supervisors referencing his age and vulnerability to COVID-19. Several months later, he was informed his employment would be terminated, with the group citing operational changes and a desire to hire a neurosurgeon able to fully cover both hospitals.The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the case after the neurosurgeon brought suit alleging age discrimination under the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment for the employer, determining that no reasonable jury could find in favor of the plaintiff. The court found the employer’s stated reasons for termination were not pretextual and that evidence did not support a causal link between age and the termination.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s grant of summary judgment. The court held that, even under the correct “but-for” causation standard required by Gross v. FBL Financial Services, Inc., the record did not contain sufficient evidence for a reasonable jury to find that age was the but-for cause of the termination. The court concluded that the employer’s nondiscriminatory reasons for termination were supported by the record, and no inference of age discrimination arose from the available evidence. View "Richardson v Northwestern Memorial Healthcare" on Justia Law

Anthony Knight was employed by Cambria Company, LLC as a process engineering technician, primarily assisting with production line functionality. In late 2022, Knight’s father passed away, leading Knight to struggle with depression. He subsequently requested and was granted leave under the Family and Medical Leave Act (FMLA) from February to April 2023. In mid-March 2023, while Knight was on FMLA leave, Cambria terminated his employment, citing elimination of his position due to a reduction in force. Cambria stated that Knight was selected for termination because of his shorter period of employment compared to other employees, and his job responsibilities were shifted to other departments without hiring a replacement.Knight filed suit in the United States District Court for the District of Minnesota, alleging that Cambria discriminated against him and interfered with his FMLA entitlements. During discovery, Cambria asserted that the decision to terminate Knight was based solely on seniority and the need to reduce headcount due to production slowdowns. The district court granted summary judgment in favor of Cambria, finding that Knight had not produced sufficient evidence of discriminatory intent or pretext, and that Cambria provided legitimate, nondiscriminatory reasons for his termination.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The Eighth Circuit held that Knight failed to raise a genuine dispute as to whether Cambria’s stated reasons for termination were pretextual or connected to his FMLA leave. The court found that Cambria’s reduction in force and reliance on seniority were legitimate reasons, and Knight’s evidence did not show intentional discrimination or unlawful interference with FMLA rights. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "Knight v. Cambria Company, LLC" on Justia Law

A physician assistant was employed at a medical spa operated by a corporation in Vermont, with the president as a co-defendant. The plaintiff worked part-time initially, then full-time beginning in 2018. Her employment agreement was amended that year to provide an annual salary, a bonus formula based on the employer’s gross sales for each calendar year, and paid vacation. She received bonuses in 2018 and 2019 but was terminated in December 2020 without receiving a bonus or payment for unused paid time off for that year.The plaintiff sued in the Vermont Superior Court, Chittenden Unit, Civil Division, alleging breach of contract for underpaid bonuses in 2018 and 2019, failure to pay the 2020 bonus and unused PTO, and statutory wage violations. The trial was split, with contractual claims presented to a jury and wage claims to the court. After the plaintiff’s case, the court granted judgment as a matter of law to the defendants on the 2020 claims, finding insufficient evidence for breach or violation of the implied covenant of good faith and fair dealing. The jury found for the plaintiff on her bonus claims for 2018 and 2019, awarding damages, which the court doubled under Vermont’s wage statutes. Defendants moved for judgment as a matter of law post-trial, arguing insufficient evidence of gross sales, and the trial court ultimately granted their motion after reconsideration, entering judgment for defendants on all counts.On appeal, the Vermont Supreme Court reviewed the trial court’s grant of judgment as a matter of law de novo. The Court affirmed the trial court’s decision, finding the plaintiff presented insufficient evidence that the employer’s gross sales exceeded the thresholds required for higher bonuses in 2018 and 2019. The Court also affirmed judgment for defendants on the 2020 bonus and PTO claims, holding there was no evidence of bad faith or intent to deprive the plaintiff of accrued benefits. The Court reversed the denial of attorney’s fees for defendants and remanded for reconsideration of that request. View "Rossetti v. Bare, Ltd." on Justia Law

A correctional officer with almost nineteen years of service was terminated by the state corrections department after he disclosed information about an upcoming search (“shakedown”) to his son, who was incarcerated at a different facility. The department conducted an investigation following a recorded phone call and statements gathered from both the officer and his son. The officer’s son allegedly boasted about receiving advance notice of the search, while the officer admitted in the investigation that he inadvertently shared information. After the investigation, the officer was fired for violating departmental policy. The officer attempted to appeal his termination, but filed his grievance with the wrong agency and did not follow up for over two years.The United States District Court for the Eastern District of Wisconsin dismissed the son’s First Amendment retaliation claim at the screening stage and later granted summary judgment in favor of the corrections department on the officer’s First Amendment retaliation and Fourteenth Amendment procedural due process claims. The district court determined that the officer’s speech was not protected because it did not address a matter of public concern, and that adequate pre- and post-termination procedures were available to the officer, despite his procedural missteps.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decisions. The appellate court held that the officer’s statement about the shakedown was not protected speech under the First Amendment, as it was private and not of public concern. It also found that the officer received sufficient notice and opportunity to respond before termination, and that adequate avenues for post-termination review were available, even if he failed to properly use them. The court further concluded that the son’s claim did not state a constitutional violation. The district court’s dismissal and summary judgment orders were affirmed. View "Felton v Johnson" on Justia Law

The plaintiff worked as a Sterile Processing Technician for the defendant, a health system, and was compensated with a base hourly wage, shift differentials, weekend differentials, extra pay for additional hours, and bonuses for on-call time. The dispute centered on how overtime and holiday pay were calculated. The defendant included shift and weekend differentials and extra pay in the regular rate calculation, but excluded holiday premiums. The plaintiff, representing a certified class, alleged that the defendant’s method improperly credited regular-rate compensation toward overtime premiums and wrongly excluded holiday pay from the regular rate, in violation of the Fair Labor Standards Act (FLSA) and Wisconsin law.The United States District Court for the Eastern District of Wisconsin granted summary judgment to the defendant on all class-wide claims. The court found that the defendant’s approach to overtime calculations—using total remuneration (excluding statutory exclusions) divided by total hours worked, and then applying a 0.5 multiplier to the regular rate for overtime hours—was consistent with federal and state law. The court also concluded that statutory exclusions in § 207(e)(6) of the FLSA permitted the exclusion of holiday premiums from the regular rate. The plaintiff’s motion for reconsideration was denied, and the case was dismissed with prejudice.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the summary judgment de novo. The court held that the defendant’s methodologies for calculating overtime and excluding holiday premiums complied with both the FLSA and Wisconsin law. The court affirmed the district court’s judgment and denied the plaintiff’s request to certify a question to the Wisconsin Supreme Court regarding holiday pay exclusions. The district court’s decisions granting summary judgment and denying reconsideration were affirmed. View "Lutz v Froedtert Health, Inc." on Justia Law

David Krzesni was employed by Wellpinit School District (WSD) as Project Director for a federally funded Native Youth Community Project Grant. Prior to Krzesni’s hiring, WSD had planned a trip to Hawaii for students and staff, believing it would further the grant’s objectives. After Krzesni started, he helped facilitate funding for the trip using grant money. However, federal approval for the trip was not obtained, and the grant’s federal contact later indicated such funding would not be approved. Krzesni participated in the trip, prepared an Annual Performance Report describing it, and later learned the trip expenses had already been paid from grant funds. He also contemplated leaving his position and discussed grant compliance concerns with colleagues and the federal grant contact.The United States District Court for the Eastern District of Washington reviewed Krzesni’s claims for whistleblower retaliation under the National Defense Authorization Act (NDAA), 41 U.S.C. § 4712, and wrongful discharge under Washington law. Krzesni alleged that his contract was not renewed in reprisal for disclosures regarding the unauthorized use of grant funds for the Hawaii trip. The district court granted summary judgment for WSD and its superintendent, reasoning that Krzesni did not make protected disclosures under the NDAA and was not “discharged” under Washington law, as his contract simply expired without renewal.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The court held that Krzesni’s reporting of the Hawaii trip in the performance report and a rhetorical question to a supervisor did not constitute protected disclosures, as they did not objectively indicate misconduct. Additionally, even if a protected disclosure occurred during Krzesni’s call with the federal grant contact, WSD had already decided not to renew his contract beforehand, so no reprisal could be shown. The court further held that the nonrenewal of Krzesni’s contract was not considered a discharge under Washington law, thus defeating his wrongful discharge claim. View "KRZESNI V. WELLPINIT SCHOOL DISTRICT" on Justia Law