Justia Labor & Employment Law Opinion Summaries

Armando Guevara worked as a domestic service employee for Robert and Maria Zamora for over a decade, performing various tasks such as cleaning, car maintenance, and grocery shopping. Occasionally, he also provided services for the Zamoras' businesses, Lafise Corporation and Latin American Financial Services, Inc. (LAFS). Guevara was paid $1,365.88 biweekly, but there was no written employment agreement, and the parties disagreed on whether this amount represented a salary or an hourly wage. The Zamoras claimed they paid him an hourly rate with overtime, while Guevara asserted he was paid a salary without proper overtime compensation.Guevara filed a putative class action against the Zamoras, Lafise, and LAFS for unpaid overtime wages under the Fair Labor Standards Act (FLSA). The United States District Court for the Southern District of Florida granted summary judgment in favor of the defendants, finding that Guevara was not covered by the FLSA through either "enterprise coverage" or "individual coverage." The court also found that Guevara was fully compensated for all his overtime work hours based on the Zamoras' testimony and calculations.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found that the district court erred in granting summary judgment. The appellate court determined that there was a genuine dispute regarding Guevara's regular hourly rate and, therefore, his overtime rate. The court noted that the Zamoras did not maintain accurate records, and the evidence presented created a genuine issue of fact that should be determined by a jury. The appellate court also vacated the district court's ruling on whether Lafise was a joint employer, as the lower court failed to provide sufficient reasoning and did not address the relevant factors. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Guevara v. Lafise Corp." on Justia Law

A national news reporter employed by a prominent newspaper sued her employer and six of its editors in Superior Court, alleging violations of the D.C. Human Rights Act and the common law tort of negligent infliction of emotional distress. She claimed that the defendants discriminated against her based on her status as a sexual assault victim and her gender, took adverse employment actions against her, subjected her to a hostile work environment, and retaliated against her for protesting their discriminatory actions.The defendants moved to dismiss the complaint under Superior Court Civil Rule 12(b)(6) for failure to state a claim and filed a special motion to dismiss under the D.C. Anti-SLAPP Act, arguing that the claims arose from acts in furtherance of the right of advocacy on issues of public interest. The Superior Court denied the special motion to dismiss, finding that the claims did not arise from speech protected by the Anti-SLAPP Act, but granted the Rule 12(b)(6) motion, concluding that the complaint failed to plausibly allege unlawful discrimination or retaliation.The District of Columbia Court of Appeals reviewed the case and affirmed the denial of the special motion to dismiss, agreeing that the Anti-SLAPP Act did not apply. The court reversed the dismissal of the counts alleging adverse action discrimination, finding that the complaint plausibly alleged that the defendants took certain adverse employment actions against the reporter in violation of the Human Rights Act. However, the court affirmed the dismissal of the hostile work environment and retaliation claims, concluding that the allegations did not meet the necessary legal standards. The court also noted that it was premature to decide whether the defendants' actions were protected by the First Amendment, leaving that issue open for further proceedings. View "Sonmez v. WP Company, LLC" on Justia Law

A registered nurse, Alexandra Melino, sued her former employer, Boston Medical Center (BMC), alleging violations of Title VII of the Civil Rights Act and Massachusetts General Laws by denying her request for a religious exemption from BMC's COVID-19 vaccination mandate. Melino's primary duties involved direct patient care in critical units. During the pandemic, BMC converted several units to COVID-19 units and faced significant staffing challenges due to the virus. BMC implemented a vaccination policy based on CDC recommendations to mitigate the risk of COVID-19 transmission among staff and patients.The United States District Court for the District of Massachusetts granted summary judgment to BMC, holding that Melino's requested exemption would impose undue hardship on the hospital. The court found that Melino could not work remotely, could not work in-person unvaccinated without risking patient safety, and that any feasible accommodation would impose substantial costs on BMC. Melino's motion to strike portions of an affidavit submitted by BMC was also denied due to her failure to comply with local procedural rules.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court affirmed the district court's decision, agreeing that BMC had demonstrated undue hardship by showing that allowing Melino to work unvaccinated would increase the risk of COVID-19 transmission. The court noted that Melino did not provide any medical evidence to contradict BMC's reliance on CDC recommendations. Additionally, Melino's argument that BMC should have considered alternative accommodations was waived as it was not raised in the lower court. The court upheld the district court's rulings, affirming the grant of summary judgment in favor of BMC. View "Melino v. Boston Medical Center" on Justia Law

Dr. Jabeen N. Abutalib, a physician with the Veterans Health Administration (VHA), sought corrective action from the Merit Systems Protection Board (MSPB) for alleged retaliatory personnel actions following her Equal Employment Opportunity (EEO) complaint. Dr. Abutalib claimed that her EEO complaint, which was settled in January 2020, led to adverse actions including a reduction in pay and reassignment. She filed a whistleblower complaint with the Office of Special Counsel (OSC) and subsequently appealed to the MSPB.The MSPB dismissed Dr. Abutalib’s appeal for lack of jurisdiction, stating that she failed to make a nonfrivolous showing of whistleblowing or other protected activity. The administrative judge noted that as a VHA physician, Dr. Abutalib could not appeal adverse agency actions under chapter 75 of title 5. Additionally, the judge found that her claims of retaliation for filing an EEO complaint did not constitute whistleblowing under 5 U.S.C. § 2302(b)(8) or protected activity under § 2302(b)(9)(A)(i).The United States Court of Appeals for the Federal Circuit reviewed the case and affirmed the MSPB’s decision. The court held that Dr. Abutalib did not present her argument regarding the settlement agreement as evidence of whistleblowing to the administrative judge, and thus could not raise it for the first time on appeal. Furthermore, the court found that the matters addressed in the settlement agreement were not the subjects of her OSC complaint, indicating a failure to exhaust administrative remedies. The court concluded that Dr. Abutalib did not make a nonfrivolous showing of a qualifying whistleblowing disclosure and upheld the MSPB’s dismissal of her appeal. View "ABUTALIB v. MSPB " on Justia Law

Caroline Retzios was terminated by Epic Systems Corporation after she refused to be vaccinated against COVID-19, citing religious objections. She filed a lawsuit under Title VII of the Civil Rights Act of 1964, claiming that Epic was required to accommodate her religious beliefs. Epic requested the district court to compel arbitration based on an agreement Retzios had signed, which the court granted, subsequently dismissing the suit.The United States District Court for the Northern District of Illinois dismissed the case after referring it to arbitration, despite Epic's request for a stay. According to the Federal Arbitration Act, a stay should have been issued instead of a dismissal when arbitration is requested. This dismissal allowed Retzios to appeal the decision.The United States Court of Appeals for the Seventh Circuit reviewed the case and determined that the district court erred in dismissing the suit instead of staying it. However, the appellate court proceeded with the case due to the district court's actions. The appellate court found that Retzios's claims fell within the scope of the arbitration agreement she had signed with Epic. The court rejected Retzios's arguments against the enforceability of the arbitration agreement, including her claims of promissory estoppel and waiver. The court also found her objections to arbitration to be frivolous and granted Epic's motion for sanctions, directing Retzios to reimburse Epic for its legal expenses incurred on appeal. The decision of the district court was affirmed, with sanctions imposed on Retzios. View "Retzios v Epic Systems Corp." on Justia Law

Rodney Martin worked for B.F. Goodrich Company from 1966 to 2012 and was exposed to vinyl chloride monomer until 1974. He was diagnosed with angiosarcoma of the liver in December 2019 and died in July 2020. His widow, Candice Martin, filed a civil action in November 2021, alleging that Rodney’s occupational exposure caused his illness and death. She invoked the exception in section 1.1 of the Workers’ Occupational Diseases Act to avoid its exclusivity provisions.PolyOne filed a motion to dismiss for lack of personal jurisdiction, and Goodrich filed a motion to dismiss under the exclusivity provisions, arguing that section 1.1 did not apply and that using it would infringe on their due process rights. The district court denied these motions and certified two questions for interlocutory appeal to the United States Court of Appeals for the Seventh Circuit, which then certified three related questions to the Illinois Supreme Court.The Illinois Supreme Court reviewed the case and answered the certified questions. The court held that section 1(f) of the Workers’ Occupational Diseases Act is a period of repose for purposes of section 1.1. The court also determined that section 1.1 applies prospectively under section 4 of the Statute on Statutes, meaning it applies to new actions filed after the amendment was enacted. Finally, the court found that applying section 1.1 prospectively does not violate Illinois’s due process guarantee, as defendants did not have a vested right in an exclusivity defense before the employee’s injury was discovered. View "Martin v. Goodrich Corp." on Justia Law

The plaintiffs, Carmen Mercado and Jorge Lopez, filed a class action complaint against their former employer, S&C Electric Company, in the circuit court of Cook County. They alleged that S&C underpaid their overtime wages by excluding certain performance bonuses from the "regular rate" of pay used to calculate overtime. S&C argued that the bonuses were statutorily excluded from the regular rate of pay and that they had made adjusted payments to cover any alleged unpaid wages.The circuit court granted S&C's motion to dismiss the complaint with prejudice, finding that the adjusted payments satisfied the alleged underpayment. The appellate court affirmed the circuit court's judgment, agreeing that the bonuses were properly excluded from the regular rate of pay and that the adjusted payments fully compensated the plaintiffs.The Supreme Court of Illinois reviewed the case and reversed the lower courts' judgments. The court held that the performance bonuses should have been included in the regular rate of pay for calculating overtime wages. The court found that the bonuses were not gifts but compensation for services performed, and thus did not fall under the exclusion in section 210.410(a) of the regulations. Additionally, the court held that the adjusted payments did not fully compensate the plaintiffs for their statutory damages, including treble damages, monthly interest, and attorney fees, as required by section 12(a) of the Minimum Wage Law.The Supreme Court of Illinois remanded the case to the circuit court for further proceedings consistent with its opinion. View "Mercado v. S&C Electric Co." on Justia Law

Freedom Vans LLC, a company that converts and customizes vans into mobile houses, hired Jeremy David and Mark Springer. David, a self-taught carpenter, was hired in 2019 and later promoted to foundations manager. Springer, an automotive and maritime mechanic, was hired in 2020 as an electrician. Both employees earned less than twice the minimum wage and signed a noncompete agreement prohibiting them from engaging in any business that competed with Freedom Vans. They claimed they declined additional work offers due to fear of termination and legal action. They stopped working for Freedom Vans in 2021.David and Springer filed a class action lawsuit in 2022, alleging the noncompete agreement violated chapter 49.62 RCW, which regulates noncompete clauses in employment contracts. They sought damages and injunctive and declaratory relief. The superior court granted summary judgment to Freedom Vans, reasoning that RCW 49.62 does not restrict an employer’s right to require employee loyalty and avoidance of conflicts of interest. The court denied Freedom Vans' request for attorney fees. Both parties appealed.The Washington Supreme Court reviewed the case. The court held that noncompete agreements for employees earning less than twice the minimum wage must be reasonable and narrowly construed in light of the legislature’s intent to protect low wage workers and promote workforce mobility. The court reversed the Court of Appeals' decision, concluding that prohibiting employees from providing any kind of assistance to competitors exceeds a narrow construction of the duty of loyalty. The case was remanded to the superior court to determine the reasonableness of the noncompete agreement and assess damages and attorney fees. View "Springer v. Freedom Vans LLC" on Justia Law

Tara Osborn, a technical support specialist, was terminated by JAB Management Services, Inc., which provides prison healthcare. Osborn sued her former employer, alleging violations of state and federal employment law, including a claim that JAB Management failed to compensate her for overtime work as required by the Fair Labor Standards Act (FLSA). JAB Management moved for summary judgment on the overtime claim.The United States District Court for the Central District of Illinois granted summary judgment in favor of JAB Management. The court found that Osborn failed to comply with local rules in her response to the summary judgment motion, leading to her amended response being struck. Consequently, the court deemed JAB Management's facts as admitted and found that Osborn did not provide sufficient evidence to show she worked overtime.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the district court's decision, holding that Osborn did not meet her initial burden of proving she worked uncompensated overtime. The court noted that Osborn's evidence was vague, conclusory, and lacked specificity regarding her work hours. Additionally, her claims were inconsistent with other evidence in the record. The court also found that even under the relaxed just and reasonable inference standard for proving damages, Osborn's evidence was insufficient to establish the amount and extent of her overtime work. Therefore, the Seventh Circuit affirmed the district court's grant of summary judgment in favor of JAB Management. View "Osborn v JAB Management Services, Inc." on Justia Law

Jennifer Jackiw, while working for Soft Pretzel Franchise, sustained an injury that led to the amputation of her right forearm. The employer acknowledged liability, and at the time of the injury, Jackiw's average weekly wage was $322.05. The parties agreed that the injury was a "specific loss" under the Pennsylvania Workers' Compensation Act, entitling her to a healing period of up to 20 weeks followed by 370 weeks of compensation. However, they disagreed on how to calculate the weekly benefit amount for the 370 weeks.A workers' compensation judge (WCJ) concluded that Jackiw's benefit should be calculated according to the formula for total disability under Section 306(a) of the Act. The Workers' Compensation Appeal Board (WCAB) affirmed this decision, despite acknowledging arguments that the specific-loss benefits should be calculated differently. The WCAB felt bound by the Commonwealth Court's decision in Walton v. Cooper Hosiery Co., which had interpreted the Act to harmonize benefits for specific loss and total disability.The Commonwealth Court, in a divided en banc panel, affirmed the WCAB's decision, applying the rule of stare decisis and agreeing with the interpretation in Walton. The dissenting judges argued that the statutory text provided more generous benefits for specific-loss injuries than for total disability without the loss of a body part.The Supreme Court of Pennsylvania reviewed the case to determine the correct statutory formula for calculating workers' compensation benefits for the loss of a body part. The court concluded that the plain text of the statute indicated that specific-loss benefits should be calculated under Section 306(c), not Section 306(a). The court vacated the Commonwealth Court's order and remanded the case for further proceedings consistent with this interpretation. View "Jackiw v. Soft Pretzel Franchise" on Justia Law