Justia Labor & Employment Law Opinion Summaries

A locomotive engineer had longstanding concerns about her employer’s train scheduling practices, believing they led to unsafe conditions by pressuring employees to cut corners. Over a two-year period, she reported these concerns to her union, federal and state agencies, and the Governor’s office. Following a fatal train crash, she raised the issue again at a safety meeting attended by Liberty Mutual Insurance and New Jersey Transit employees. The specifics of this meeting, including which company personnel attended or knew about her participation, remained unclear.After the safety meeting, the engineer committed two significant infractions: first, she operated a train at a speed well above the limit, resulting in suspension after a disciplinary hearing. Her suspension was upheld by internal review boards. Later, she ran a train through a stop signal, leading to her termination after another disciplinary process. The identities of those responsible for the disciplinary decisions were uncertain, and testimony indicated that the signatory on her termination notice was absent at the time. A review board subsequently upheld the termination. After exhausting administrative remedies, the engineer filed suit under the Federal Railroad Safety Act, alleging retaliation for her whistleblowing. The United States District Court for the District of New Jersey granted summary judgment for the employer, finding insufficient evidence of retaliation.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the employee failed to provide evidence that any person involved in the decision to discipline or terminate her knew of her protected activity. The court clarified that, under the Federal Railroad Safety Act, a plaintiff must show knowledge of protected activity by an agent who influenced the adverse action. Because such evidence was lacking, the court affirmed the District Court’s grant of summary judgment for the employer. View "Asay v. New Jersey Transit Rail Operations Inc" on Justia Law

An employee suffered significant hand injuries while working for Wyoming Waste Systems when his hand was caught in the pinch point of a garbage truck’s lift arms. The injured employee, who was being trained by a more experienced colleague, exited the truck to vomit while the lift arms were lowered. The colleague, seated in the passenger seat, engaged the controls to raise the lift arms without knowing the injured employee’s location, resulting in the injury.The injured employee brought suit against his co-worker, alleging liability under the Wyoming Worker’s Compensation Act, claiming the co-worker acted willfully and wantonly to cause the harm. The District Court of Fremont County granted summary judgment to the defendant, finding him immune under the Act. The court determined there was insufficient evidence to show the defendant had “knowledge of the hazard or serious nature of the risk involved,” or that he acted with willful and wanton misconduct.The Supreme Court of Wyoming reviewed the district court’s summary judgment order de novo. It applied established precedent and the statutory standard for co-employee liability, requiring proof of intentional or reckless conduct with knowledge of a specific, high-probability risk. The Supreme Court found that the plaintiff did not present evidence that the defendant had particularized knowledge of the specific danger to the plaintiff at the moment of the incident, nor that the risk was obvious or highly probable. The court held that violations of general safety rules and evidence of negligence do not meet the threshold for willful and wanton misconduct required to overcome co-employee immunity. Accordingly, the Supreme Court affirmed the district court’s grant of summary judgment in favor of the defendant. View "Courtney v. Meyer" on Justia Law

A deputy sheriff sergeant was terminated from his employment after an incident where he encountered two individuals with active “time pay” warrants for failure to pay fines. Despite confirming the existence and validity of the warrants, which were issued by a county court and directed to any law enforcement officer, he told the individuals that he would not arrest them because he believed doing so would be pointless. The interaction was recorded on his body camera. After the sheriff’s office conducted an internal investigation, the sergeant was found to have violated standard operating procedures by neglecting his duty.The sergeant appealed the termination to the county sheriff’s merit commission, which upheld the decision after a hearing. He then filed a petition in error with the District Court for Lancaster County, arguing that the evidence did not support his termination, that due process was denied because he was not given notice regarding issues of credibility or prior investigations, that the commission’s decision was void for untimely delivery, and that he had not waived any objections by failing to object during the administrative hearing. The district court found sufficient evidence supported the commission’s decision, determined the procedures were constitutionally adequate, rejected the argument about untimely delivery because no specific deadline for notification was violated, and concluded there was no prejudice regarding any waiver issue.The Nebraska Supreme Court reviewed the case. It held that sufficient evidence supported the finding that the sergeant neglected his statutory duty to execute the warrants, which justified termination under the governing procedures. The court also held that due process requirements were satisfied, as the sergeant received notice of the charges, an explanation of the evidence, and an opportunity to be heard. The court affirmed the district court’s judgment, finding no prejudicial error in the proceedings. View "Schmuecker v. Lancaster County" on Justia Law

The plaintiff sued his former employer for multiple Labor Code violations, including overtime wage, rest period, separation earnings, wage statement, and recordkeeping violations, under California’s Private Attorneys General Act (PAGA). The employer conceded liability for certain violations, and the parties stipulated to most relevant facts, leaving the amount of civil penalties as the main issue for trial. The plaintiff argued for maximum PAGA penalties totaling over $55 million, while the employer argued for substantial reductions based on the technical nature of the violations and corrective actions taken. The plaintiff also sought over $1.5 million in attorney fees, including a lodestar multiplier.The Superior Court of Orange County, after summary adjudication and trial briefs, awarded $515,965 in civil penalties, applying reductions based on factors such as the absence of unpaid wages for some violations, the employer’s good faith efforts to correct issues, and the relatively small amounts of lost wages. For the wage statement issue, the court found substantial compliance and imposed a reduced penalty. For rest period and overtime-related issues, penalties were further reduced due to the technical nature of violations and corrective actions. The court awarded full penalties for the bonus pay issue. Regarding attorney fees, the court accepted the lodestar but applied a negative multiplier to account for inflated billing rates and the relatively straightforward nature of the litigation, awarding $733,440 in fees.The California Court of Appeal, Fourth Appellate District, Division Three, affirmed the judgment. The court held that the Labor Code does not mandate any particular method for reducing PAGA penalties, allowing trial courts discretion to apply reductions on a per employee or per pay period basis. The court found no abuse of discretion in the trial court’s calculation of penalties or application of a negative fee multiplier. The final judgment and fee award were affirmed. View "Taduran v. James R. Glidewell, Dental Ceramics" on Justia Law

Two journalists, both of Iraqi national origin, worked for a Virginia-based media company operating Arabic-language broadcasts targeting the Middle East and North Africa. The company maintained a mandatory Code of Ethics and social media policy requiring its journalists to remain neutral both in their reporting and in personal social media posts. Both journalists violated these policies by posting political content on social media, and after refusing direct orders to remove the posts, each was terminated. They alleged that the company enforced its policies more harshly against Iraqi journalists than non-Iraqi journalists and that their terminations were discriminatory under Title VII of the Civil Rights Act of 1964.Each journalist filed a separate lawsuit in the United States District Court for the Eastern District of Virginia, asserting claims of national origin discrimination. Both district courts granted the employer’s motions to dismiss, finding that the complaints failed to allege sufficient facts to plausibly support a claim of discrimination. Specifically, the courts found that neither plaintiff identified non-Iraqi employees who engaged in similarly insubordinate conduct—such as violating the same policies after direct warnings—yet were treated more favorably.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed both cases de novo. The court affirmed the district courts’ decisions, holding that the plaintiffs’ complaints did not state plausible claims for relief under Title VII. The court found that the facts alleged showed the plaintiffs were terminated for insubordination and repeated policy violations, not because of their national origin, and that the comparator allegations were too generalized to support an inference of discrimination. The court also held that the district court did not abuse its discretion in denying one plaintiff leave to amend, as no request for leave was made and amendment would have been futile. The judgments of dismissal were affirmed. View "Aljizzani v. Middle East Broadcasting Networks, Inc." on Justia Law

The appellant, Mark Justman, sought to recover accidental death life insurance benefits following the death of his wife, Karen Justman, who died from septic shock caused by a bacterial infection after eating raw oysters. At the time of her death, she was employed by Accenture LLP and was covered by both basic and optional accidental death and dismemberment (AD&D) insurance through a group plan. Prudential Insurance Company of America served as the Claims Administrator in 2021, while Accenture was designated as the Plan Administrator. After Prudential denied Justman’s claim on the grounds that the death was due to illness rather than an accident, Justman exhausted Prudential’s administrative appeals process without success.Justman then filed suit in the United States District Court for the Eastern District of Pennsylvania against both Prudential and Accenture, asserting wrongful denial of benefits under ERISA § 502(a)(1)(B) and breach of fiduciary duty for allegedly failing to provide required summary plan descriptions (SPDs). Prudential settled, leaving only Accenture as a defendant. The District Court dismissed Justman’s claims, finding insufficient factual allegations that Accenture controlled the benefits determination or failed to provide SPDs within statutory deadlines. The court allowed Justman to amend his complaint multiple times but found that further amendment would be futile and dismissed the case with prejudice.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s rulings. The Third Circuit held that a proper defendant in an ERISA § 502(a)(1)(B) claim is the entity with authority over benefits determinations, which in this case was Prudential, not Accenture. The court also concluded that Justman’s claims regarding failure to provide SPDs and breach of fiduciary duty were not plausibly pleaded. The Third Circuit found no abuse of discretion in the denial of leave to amend or reconsideration and affirmed the dismissal with prejudice. View "Justman v. Accenture LLP" on Justia Law

Several unions representing approximately 800,000 federal civilian employees challenged an executive order issued by the President in March 2025. This order, Executive Order 14,251, invoked statutory authority to exclude various federal agencies and subdivisions from collective bargaining rights, citing national security concerns. The agencies affected included the Departments of State, Justice, Veterans Affairs, and others, and the order was accompanied by White House and Office of Personnel Management statements which asserted that union activities impeded national security functions. The unions alleged that the President’s action constituted unlawful retaliation against them for engaging in protected First Amendment activities, including lawsuits and public criticism of the Administration.The case originated in the United States District Court for the Northern District of California. There, the judge granted a preliminary injunction, enjoining the enforcement of Executive Order 14,251 on the grounds that the unions raised a serious question as to whether the order was issued in retaliation for their protected speech. The district court focused on statements in the White House’s supporting materials, finding these reflected hostility toward the unions’ activities. The court did not address the merits of the unions’ other claims.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s preliminary injunction. The Ninth Circuit agreed that the district court had jurisdiction to hear the unions’ claims, rejecting the government’s argument that the unions were required to pursue administrative remedies before the Federal Labor Relations Authority. However, the Ninth Circuit vacated the preliminary injunction. The appellate court held that, even if the unions made a prima facie showing of retaliation, the government demonstrated that the President would have issued the order regardless of the unions’ protected conduct, due to legitimate national security concerns. Because the unions did not show a likelihood of success or serious questions on the merits, the preliminary injunction was vacated. View "AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO V. TRUMP" on Justia Law

A 72-year-old employee was terminated from her job at a convenience store following an incident in which she was confronted by an armed robber during her shift. The robber, after demanding cigarettes, approached the employee with knives, prompting her to extend her arms defensively. The robber then took the cigarettes and left. Subsequently, the employer fired the employee for violating its policy against confronting shoplifters. The employee sued, alleging wrongful discharge for exercising her right to self-defense under Colorado law and claiming the termination violated public policy.After the case was removed to the United States District Court for the District of Colorado, the employer moved for summary judgment, arguing both that the employee had not acted in self-defense and that Colorado did not recognize self-defense as a public-policy exception to at-will employment. The district court granted summary judgment for the employer, finding no such public-policy exception. On appeal, the Tenth Circuit reversed and remanded, identifying unresolved factual issues regarding whether the employee had acted in self-defense and whether that was the reason for her termination. The district court then denied summary judgment, finding disputed material facts suitable for jury determination. The employee requested certification of a legal question to the Supreme Court of Colorado, which was granted.The Supreme Court of Colorado, en banc, answered the certified question in the affirmative. The Court held that both Colorado’s statutory and constitutional rights to self-defense constitute a clear public policy, and that employees cannot be lawfully terminated for lawfully exercising self-defense in response to an unprovoked attack at work. The Court recognized a narrow public-policy exception to the at-will employment doctrine for such circumstances and returned the case to the district court for further proceedings. View "Moreno v. Circle K Stores, Inc." on Justia Law

Several patients sustained work-related injuries and began receiving workers’ compensation benefits. Their treating physicians, Drs. Purewal and Jalali, wrote prescriptions that were filled by 700 Pharmacy. The State Workers’ Insurance Fund, acting as the insurer for the patients’ employers, refused to pay for these prescriptions, arguing that the Anti-Referral Provision of the Workers’ Compensation Act (WCA) barred payment because the physicians had a financial interest in the pharmacy and thus engaged in unlawful self-referrals.A hearing officer from the Bureau of Workers’ Compensation Fee Review Hearing Office addressed the Pharmacy’s fee review applications. The hearing officer found that the Anti-Referral Provision made it unlawful for providers to refer patients for “goods or services” if they had a financial interest in the receiving entity. Relying on state regulations and the federal Stark Law, the hearing officer determined that prescription drugs and pharmaceutical services fell within the meaning of “goods or services,” thus denying the Pharmacy’s claims for payment. The Commonwealth Court affirmed, finding that the phrase “goods or services” acted as a catchall, including prescription drugs and professional pharmaceutical services within the self-referral ban.The Supreme Court of Pennsylvania reviewed these consolidated appeals. Applying principles of statutory interpretation, the court held that the Anti-Referral Provision’s prohibition on self-referrals is limited to the eight specifically enumerated categories of services and does not extend to prescription drugs or professional pharmaceutical services. The court reasoned that the statute’s plain language and structure do not support reading “goods or services” as a catchall encompassing unlisted services. The court reversed the Commonwealth Court and remanded for proceedings consistent with its decision. The main holding is that the Anti-Referral Provision does not bar payment for prescription drugs and pharmaceutical services provided under these circumstances. View "700 Pharm. v. Bur of WC" on Justia Law

During the COVID-19 pandemic, the Superintendent of Hamtramck Public Schools took voluntary medical leave under the Family and Medical Leave Act (FMLA). When she prepared to return, the school district placed her on paid administrative leave pending an investigation into alleged misconduct. While on leave, she filed charges of discrimination with government agencies and was not allowed to return to her duties for over a year. She alleged that these actions were the result of retaliation and discrimination after she had involuntarily reassigned several teachers, which had sparked conflict with the school board and teachers’ union.While still on paid leave, the Superintendent filed suit in the United States District Court for the Eastern District of Michigan against the school district, several board members, and the teachers’ union, alleging multiple claims including discrimination based on disability, sex, and national origin, as well as retaliation. She attempted to amend her complaint multiple times. The district court denied her motion to file a Fourth Amended Complaint, holding that the proposed amendments were futile, and granted the defendants’ motions to dismiss the original complaint with prejudice. She then appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of leave to amend de novo. The appellate court held that the district court erred in finding that her proposed claims for FMLA retaliation and Title IX sex discrimination were futile. The Sixth Circuit concluded that her allegations plausibly stated claims under both statutes, applying the correct legal standards. The appellate court vacated the district court’s dismissal, reversed its futility determination, and remanded the case so the plaintiff could proceed with her amended complaint. View "Ahmed v. Hamtramck Public Schools" on Justia Law