Justia Labor & Employment Law Opinion Summaries

In this case, the Supreme Court of Iowa was asked to interpret and apply three provisions of the Iowa Code relating to workers' compensation. The plaintiff, Corey Tweeten, worked on his father's farm and sustained a right arm injury on July 25, 2017. He filed a claim for workers’ compensation benefits on January 21, 2020, more than two years after the incident. The defendants, his father's farm and their insurance carrier, appealed a district court order partially granting Tweeten's claim.The Supreme Court was called upon to interpret three provisions of the Iowa Code: (1) whether a compromise settlement between a claimant and the Second Injury Fund precludes further benefits from the employer, (2) whether the discovery rule tolls the statute of limitations for filing a claim for workers’ compensation benefits, and (3) how amendments to the Iowa Code affect reimbursement for independent medical examinations.The Supreme Court of Iowa held that the compromise settlement between Tweeten and the Second Injury Fund did not bar Tweeten's claims against his employer and their insurance carrier. The Court reasoned that the compromise settlement concerned a dispute over whether a previous injury triggered the Second Injury Compensation Act, separate from the claim against the employer for the current injury. Therefore, the compromise settlement did not bar the separate and distinct claim against the employer.Regarding the second issue, the Court ruled that the discovery rule as previously applied by the courts did not survive the 2017 revisions to the relevant section of the Iowa Code. The Court held that the two-year statutory period begins to run when the employee knows or should know that an injury is work-related, without regard to whether the injury is also serious enough to be compensable. As such, the plaintiff's claim was time-barred, as he knew he had a right-arm injury that was work-related more than two years before he sought benefits.Finally, the court held that the plaintiff was not entitled to reimbursement for the independent medical examination under Iowa Code section 85.39, since the injury for which he was examined was not compensable.The court reversed the lower court's decision and remanded the case for further proceedings. View "Tweeten v. Tweeten" on Justia Law

In this case, Scott Olson, an employee of BNSF Railway Company, sued the company under the Federal Employers' Liability Act, seeking damages for injuries he sustained in a workplace accident. A jury found in favor of Olson and awarded him significant damages. The railway company appealed, alleging three specific instances of error by the district court. The Supreme Court of Iowa vacated the decision of the court of appeals, which had granted a new trial, and affirmed the district court's judgment. The court held that the railway company did not properly preserve its challenge to the verdict form for appeal, as the company had failed to object to the form until after the jury returned its verdict. The court also ruled that the district court did not err by allowing Olson to present new negligence claims during the trial that were not alleged in the pleadings or identified during discovery, as the company was clearly on notice that Olson alleged that the company failed to reasonably train all employees as one of the specific allegations of negligence at trial. Lastly, the court found that the company was not prejudiced by Olson's counsel's alleged misconduct during his rebuttal closing argument. View "Olson v. BNSF Railway Company" on Justia Law

In this case heard before the United States Court of Appeals for the Sixth Circuit, the plaintiff, Christina Littler, a bus driver for a school district, appealed a grant of summary judgment in favor of the defendant, Ohio Association of Public School Employees (OAPSE), a union she had joined. Littler had filed a 42 U.S.C. § 1983 action alleging the wrongful deduction and retention of union dues. She claimed that she had withdrawn her union membership and therefore her dues deduction authorization too, but OAPSE had continued to deduct dues from her paycheck. On remand from an earlier appeal, the district court held that Littler had failed to show that OAPSE was a state actor under § 1983, and thus granted OAPSE summary judgment on Littler’s § 1983 claim.The Sixth Circuit affirmed the district court’s judgment. It held that Littler had failed the first prong of the "state action" test under § 1983, as she could not show that the alleged deprivation was caused by any governmental policy or decision. Instead, the conduct she complained about was inconsistent with the collective bargaining agreement and violated her agreement with OAPSE. This conduct was attributed to a private actor—OAPSE—acting contrary to any rule of conduct imposed by the state, and therefore could not be attributed to the state. The court also rejected Littler's argument that the deprivation was caused by the terms of the collective bargaining agreement and the school district’s compliance with the union’s request to withhold dues from her paycheck. Instead, the court held that the specific conduct complained about was OAPSE’s failure to process Littler’s withdrawal pursuant to the membership application and remove her name from the deduction list. This was not governed by a state-imposed rule of conduct but rather by a private individual or organization’s policy. Thus, the court concluded that the challenged conduct could not be fairly attributable to the state. View "Littler v. Ohio Ass'n of Pub. Sch. Emps." on Justia Law

The Supreme Court of the State of Washington held that detained workers at a privately owned and operated immigration detention center are considered "employees" under Washington's Minimum Wage Act (MWA), and are thus entitled to receive the state's minimum wage for their work. The court rejected arguments from the detention center operator, The GEO Group, that the detained workers should be exempt from the MWA because they resided and slept at their place of employment. The court also disagreed with GEO's claim that the MWA's government-institutions exemption applied to the detainees because the facility was operated under contract with the federal government. The court found the government-institutions exemption only applies to detainees in public, government-run institutions, and not in privately owned and operated facilities. Finally, the court ruled that a damages award to one party (a class of detainees) does not prevent another party (the State of Washington) from seeking equitable relief in the form of an unjust enrichment award. The case stemmed from lawsuits brought by the State and a class of detainees alleging that GEO's practice of paying detainees less than Washington's minimum wage violated the MWA. After a lower court ruled in favor of the plaintiffs, GEO appealed, leading to the certification of questions to the Washington Supreme Court. View "Nwauzor v. The GEO Grp., Inc." on Justia Law

In this case, the Supreme Court of the State of Idaho upheld a lower court's summary judgment in favor of the defendants, George and Jesse’s Les Schwab Tire Store, Inc., and two of its owners, Bruce and Richard Byram. The plaintiff, Adam Davis, had been employed as an assistant manager at Les Schwab from April 2016 till June 2019. In March 2019, there was a shortage in the cash deposits and surveillance footage showed Davis bending down out of camera view in the area where the cash deposits were kept while he was alone in the store. This led to Davis being arrested and charged with grand theft, and his employment was terminated. Although the charges against Davis were later dropped, he sued the defendants for breach of his employment contract, false arrest, defamation per se, and for knowingly giving a false report to the police. The district court granted the defendants’ motion for summary judgment on all of Davis’s claims. The Supreme Court affirmed the lower court's decision, finding no genuine issue of material fact that could support Davis’s claims. The court found that Davis was an at-will employee who could be terminated without cause and that there was no evidence to show that the defendants had acted with malice. The court also found that the plaintiff's attorney had violated Rule 11.2 by submitting arguments that were not well grounded in fact, and awarded a portion of the defendants' attorney fees to be paid by the plaintiff's counsel. View "Davis v. George and Jesse's Les Schwab Tire Store, Inc." on Justia Law

In this case, the Supreme Court of Pennsylvania was called upon to determine whether the ascension of an unclassified service employee to a classified service position with higher pay with the same public employer is a promotion under the Civil Service Reform Act (CSRA) and the Veterans’ Preference Act (VPA). The case arose when Ralph E. Lynn, a classified service employee, and Aaron Novotnak, an unclassified service employee, both veterans, applied for a classified service position with the Department of Corrections (DOC). The Office of Administration (OA) deemed the position a promotion for Lynn and did not apply veterans’ preference, while it deemed the position an appointment for Novotnak and applied veterans’ preference. The DOC selected Novotnak for the position, and Lynn appealed to the State Civil Service Commission.The Supreme Court of Pennsylvania held that the ascension of an unclassified service employee to a classified service position with higher pay with the same public employer is not a promotion under the CSRA and the VPA, but rather an appointment. Therefore, it is not discriminatory under section 2704 of the CSRA to award a veterans’ preference to an unclassified service employee seeking an appointment but not to a classified service employee seeking a promotion. The court affirmed the order of the Commonwealth Court in part and reversed in part. The court ruled that Lynn was not entitled to veterans’ preference as he was seeking a promotion, not an appointment. However, Lynn will remain in his position due to a separate issue of technical discrimination that was not reviewed by the court. View "Department of Corrections v. Lynn" on Justia Law

The Court of Appeals of the State of New York held that the plaintiff, a certified diesel technician, was not engaged in an activity protected by Labor Law § 240 (1) when he was injured while repairing a trailer. The plaintiff was working beneath a lifted trailer, fixing a faulty air brake system, when the trailer fell on him. He sued on the grounds that the defendant failed to provide him with adequate safety devices, as required by Labor Law § 240 (1). The court found that the statute was not intended to cover ordinary vehicle repair. The court reasoned that, while the statute protects workers from elevation-related risks in industries like construction, it does not cover every instance where a worker is injured as a result of an elevation differential. The court also noted that extending the statute's coverage to ordinary vehicle repair could lead to an overly broad interpretation that would place undue liability on car owners for injuries sustained by mechanics. Thus, the court affirmed the dismissal of the section 240 (1) cause of action against the defendant. View "Stoneham v Joseph Barsuk, Inc." on Justia Law

The Zurich American Insurance Company sought a writ of mandate against the Workers’ Compensation Appeals Board (WCAB) and the California Insurance Guarantee Association (CIGA), in the Court of Appeal of the State of California. The issue at hand involved the interpretation of Labor Code section 5909, which states that if the WCAB does not act on a party’s petition for reconsideration of a decision by the workers’ compensation judge within 60 days, the petition is “deemed to have been denied.” CIGA filed a petition for reconsideration more than nine months past the filing date. The WCAB justified its late decision on the basis of an “administrative irregularity” that delayed CIGA’s petition. Zurich argued that the petition had already been denied by operation of law under section 5909. The Court of Appeal agreed with Zurich and held that the language and purpose of section 5909 showed a clear legislative intent to terminate the WCAB’s jurisdiction to consider a petition for reconsideration after the 60 days have passed. As a result, decisions on the petition made after that date are void as they exceed the agency’s jurisdiction. The Court of Appeal granted the writ of mandate, directing the WCAB to rescind its order granting CIGA’s petition for reconsideration and dismissing Zurich as a party defendant from the proceeding. View "Zurich Am. Ins. Co. v. Workers' Comp. App. Bd." on Justia Law

This case is a labor dispute between Palomar Health, a public healthcare district, and unions representing nurses and healthcare workers employed by Palomar Health. In 2021, during negotiations to renew their collective bargaining agreements, union organizers began a leafletting campaign outside Palomar Health’s main hospital and sought to meet with employees inside the hospital. Palomar Health responded by filing a complaint for trespass and unlawful picketing in San Diego Superior Court, seeking to ban the organizers from their facilities. The unions filed an unfair practice charge with the Public Employment Relations Board (PERB), asserting Palomar Health’s attempts to ban their representatives and the civil lawsuit violated the unions’ rights under the Meyers-Milias-Brown Act. The trial court overruled the unions’ demurrer and denied their motion to strike, maintaining jurisdiction of the state law claims. On appeal, the unions argued that the trial court lacked jurisdiction over the dispute as their activities were arguably protected by the Meyers-Milias-Brown Act and that jurisdiction fell exclusively under PERB. The Court of Appeal, Fourth Appellate District Division One State of California, agreed with the unions, finding that Palomar Health’s claims were preempted and therefore, the trial court lacked jurisdiction over the dispute. The trial court’s order overruling the demurrer was reversed and the matter was remanded with directions to enter an order sustaining the demurrer without leave to amend, and to dismiss the case on the grounds that it is subject to the exclusive jurisdiction of PERB. View "Palomar Health v. Nat. Nurses United" on Justia Law

In this case heard by the United States Court of Appeals For the Seventh Circuit, Kimberly Barnes-Staples applied for a Real Estate Director position with the General Services Administration (GSA). However, the GSA hired another candidate. Barnes-Staples subsequently sued the GSA, alleging that the interview process discriminated against her because of her race and sex in violation of Title VII of the Civil Rights Act. The district court granted summary judgment in favor of the GSA.Barnes-Staples argued that the GSA did not follow its internal anti-discrimination procedures, which she claimed allowed the GSA to hire a less qualified candidate. She also contended that she was the superior candidate, so the GSA's assertion that the other candidate was more qualified was pretextual. Furthermore, Barnes-Staples asserted that there was a systemic practice of discrimination against Black candidates and employees within the GSA.The Appeals Court, however, found that Barnes-Staples was not "clearly better qualified" than the candidate who was hired. It also found no evidence that the GSA created interview questions to favor the other candidate, nor was there evidence that the GSA violated its own guidelines during the interview process. The court also noted that while Barnes-Staples presented data on promotion and employment rates within the GSA, she failed to provide sufficient context or detail for this data to support her claim of systemic discrimination.The Appeals Court affirmed the district court's grant of summary judgment in favor of the GSA. Additionally, it found that Barnes-Staples had waived her sex discrimination claim as she did not properly develop this argument before the district court. View "Barnes-Staples v. Carnahan" on Justia Law