Justia Labor & Employment Law Opinion Summaries

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

Craig Price, a Black man, filed a lawsuit against his former employer, Valvoline LLC, alleging that his employment was terminated due to his race and he was subjected to a hostile work environment. Valvoline operated on an attendance policy, and Price had been repeatedly warned about his absenteeism, with his employment eventually terminated after he missed a shift due to food poisoning. Price also alleged that discriminatory comments had been made by his supervisors. The United States Court of Appeals for the Fifth Circuit affirmed the district court's summary judgment in favor of Valvoline. The Appeals Court found that Price's employment was terminated due to his repeated absenteeism, not because of his race. Furthermore, the court concluded that the allegedly race-motivated comments were not objectively severe or pervasive enough to create a hostile work environment. The court also noted that Price could not demonstrate that the alleged harassment he experienced was frequent or that it interfered with his work performance. Therefore, Price's claims of race discrimination and a hostile work environment were rejected. View "Price v. Valvoline" on Justia Law

The case concerns Carlos Williams, a former employee of the United States Postal Service (USPS), who alleged that the USPS terminated his employment for discriminatory reasons. Williams, a Black man who identifies as a Choctaw and a Moor, had worked for the USPS for 17 years and had filed numerous complaints against the USPS regarding his and other postal workers' treatment. Williams was fired in 2014 after he failed to show up at work for several months.The district court narrowed Williams' suit to focus solely on the 2014 firing and the claims alleging retaliation and discrimination based on race, gender, and national origin. After a five-day trial, the jury delivered a verdict in favor of the USPS. Williams appealed this decision.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court rejected Williams' claims that his firing constituted double jeopardy (as his suspension and later firing punished him twice for the same conduct) and violated his due process rights, as these claims were neither pleaded in the original complaint nor relevant to the employment discrimination claim. Furthermore, the court found that the district court did not err in declining to recruit a third lawyer for Williams after his first two lawyers withdrew from the case. Finally, the court concluded that the district court's pretrial evidentiary rulings and trial management decisions were not erroneous. View "Williams v. DeJoy" on Justia Law

The case involves Nicholas Vichio, a warehouse supervisor at US Foods, Inc. who was terminated after the arrival of a new vice president of operations, Charles Zadlo. Vichio, who had previously received positive performance reviews, was placed on a performance improvement plan by Zadlo and subsequently terminated. Vichio filed a lawsuit under the Age Discrimination in Employment Act. The district court granted summary judgment in favor of US Foods, concluding that Vichio failed to show that the performance issues cited were a pretext for discrimination.On appeal, the United States Court of Appeals for the Seventh Circuit reversed the district court's judgment. The appellate court concluded that Vichio had presented sufficient evidence to allow a reasonable jury to infer discrimination. This evidence included the sudden negative performance reviews upon the arrival of Zadlo, the seemingly predetermined nature of Vichio's termination, the identical language in performance improvement plans for Vichio and another older employee, and the hiring of a younger employee to replace Vichio. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Vichio v. US Foods, Inc." on Justia Law

In the case involving Sandra Lopez and Catholic Charities of the Archdiocese of Omaha, the Nebraska Supreme Court affirmed the district court's dismissal of the case, holding that the Nebraska Workers’ Compensation Act provides the exclusive remedy for workplace injuries. Lopez, an employee of Catholic Charities, sued her employer alleging assault and intentional infliction of emotional distress following a realistic active shooter drill conducted at her workplace. She claimed physical and mental injuries as a result of the drill. The district court dismissed the suit, asserting that her exclusive remedy was workers’ compensation. On appeal, Lopez argued that she should be able to pursue tort theories of recovery against her employer for injuries suffered if the employer acted with a specific intent to injure the employee. However, the court found that even if an employer acts with a specific intent to injure an employee, the resulting injury is accidental if it is unexpected or unforeseen to the person suffering the injury, and thus compensable under the Workers’ Compensation Act. The court also rejected Lopez's constitutional challenge due to non-compliance with procedural requirements and her public policy argument because it was not grounded on any specific statute or recognized legal authority. View "Lopez v. Catholic Charities" on Justia Law

A married couple who owned a small dental practice, D.L. Markham DDS, MSD, Inc., established an employee pension benefit plan for their business. They hired Variable Annuity Life Insurance Company (VALIC) to maintain the plan. Dissatisfied with VALIC's services, they decided to terminate their contract and were informed by VALIC that they would be charged a 5% surrender fee on all of the plan’s assets. The couple sued, alleging VALIC violated the Employee Retirement Income Security Act of 1974 (ERISA) by breaching its fiduciary duties and engaging in a prohibited transaction. The United States Court of Appeals for the Fifth Circuit affirmed the district court's dismissal of their claims. The court held that VALIC did not act as a fiduciary when it collected the surrender fee, as it simply adhered to the contract by collecting the previously agreed-upon compensation. The court also found that VALIC was not a "party in interest" when it entered the contract, as it had not yet begun providing services to the plan. Finally, the court held that VALIC's collection of the surrender fee did not constitute a separate transaction under ERISA, as it was a payment in accordance with an existing agreement. The court also affirmed the district court’s denial of the plaintiffs’ request to amend their complaint due to undue delay and insufficient detail of their new allegations. View "Markham v. Variable Annuity Life" on Justia Law

In this case, the Virginia Supreme Court ruled in favor of Peter Vlaming, a high school French teacher who was terminated by the West Point School Board for refusing to use a transgender student's preferred pronouns. Vlaming had chosen to use the student's preferred name but avoided using any third-person pronouns to refer to the student as it conflicted with his religious beliefs. The School Board fired Vlaming for not complying with its policy to use government-mandated pronouns.Vlaming sued the School Board, alleging that his termination violated his constitutional, statutory, and breach-of-contract rights. The Circuit Court dismissed Vlaming's claims, holding that they failed to state legally viable causes of action. The Supreme Court of Virginia, however, reversed the decision and remanded the case for further proceedings. The Court concluded that Vlaming's complaint sufficiently alleged that the School Board substantially burdened his right to free exercise of religion under the Virginia Constitution and that his claims under the Virginia Religious Freedom Restoration Act should not have been dismissed. Moreover, the Court held that Vlaming has alleged a viable compelled speech claim under the free speech provision of the Virginia Constitution. The Court rejected the School Board's argument that it could compel Vlaming's speech as part of his official duties as a teacher. The Court concluded that Vlaming's refusal to use certain pronouns did not interfere with his duties as a French teacher or disrupt the school's operations.The Court's decision reaffirmed the fundamental right to free speech and the free exercise of religion under the Virginia Constitution, emphasizing that these rights extend to public school teachers in their interactions with students. It clarified that although the government has a legitimate interest in ensuring non-discrimination and respect for all students, this interest must be balanced against individual rights to free speech and the free exercise of religion. The Court also clarified that a public school teacher's speech in the classroom is not entirely within the control of the school board and that teachers cannot be compelled to express views that conflict with their sincerely held religious beliefs. View "Vlaming v. West Point School Board" on Justia Law

Doris Lapham, a former employee of Walgreen Co., filed a lawsuit against the company claiming violation of the Family and Medical Leave Act (FMLA) and Florida’s Private Sector Whistleblower Act (FWA). Lapham asserted that Walgreens interfered with her attempts to obtain leave under the FMLA to care for her disabled son, and retaliated against her for those attempts. The district court granted summary judgment in favor of Walgreens on all claims.Upon appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The Appeals Court held that the proper causation standard for both FMLA and FWA retaliation claims is but-for causation, meaning that the plaintiff must prove that the adverse action would not have occurred but for the purported cause. Here, Lapham failed to show that Walgreens’ stated reasons for her termination (insubordination and dishonesty) were merely pretext for retaliation and that, but for her attempts to exercise her FMLA rights, she would not have been fired. Furthermore, Lapham failed to produce evidence showing she suffered any remediable prejudice due to Walgreens' alleged interference with her FMLA rights. View "Lapham v. Walgreen Co." on Justia Law

In the case before the United States Court of Appeals for the First Circuit, a collective of long-haul truck drivers, led by Juan Carlos Montoya, contended that their employer, CRST Expedited and CRST International (collectively referred to as "CRST"), violated the Fair Labor Standards Act (FLSA) by not compensating them for time spent in a truck's sleeper berth exceeding eight hours within a 24-hour period. CRST operates a "team driving model" where two drivers alternate between driving and resting in the sleeper berth of the truck, allowing the vehicle to be in near-continuous motion. The drivers argued that the time spent in the sleeper berth was "on duty" time, as defined by Department of Labor regulations, and thus should be compensated as work. The district court granted summary judgment for the drivers, determining that such time was indeed compensable work. The Court of Appeals affirmed this decision, holding that the time drivers spend in the sleeper berth that exceeds eight hours per day is compensable work under the FLSA. The Court reasoned that the drivers' confinement to the sleeper berth, the importance of continuous travel to CRST's business model, and the potential burdens placed on the drivers suggest that the time predominantly benefits the employer. Furthermore, the Court interpreted the Department of Labor regulations to allow an employer to exclude a sleeping period of no more than eight hours from hours worked in a 24-hour period. View "Montoya v. CRST Expedited, Inc." on Justia Law

In the case heard by the Supreme Court of the State of Montana, Caryn Miske, the plaintiff and appellant, was appealing a district court decision that granted the Department of Natural Resources and Conservation (DNRC) summary judgment on all of her claims that arose from her termination by the DNRC from the Flathead Basin Commission.The primary facts of the case involve Miske's employment as the Executive Director of the Flathead Basin Commission, a body established by the 1983 Legislature to protect the environment of Flathead Lake and its tributaries. The Commission is administratively attached to the DNRC, a relationship that Miske argued allowed the Commission independent authority over staffing decisions. However, the DNRC contended that the Commission and DNRC share concurrent authority over staffing decisions.The court affirmed the district court's grant of summary judgment to the DNRC on all of Miske's claims. It held that, based on the plain language and structure of the relevant statutes, the DNRC and the Commission have concurrent authority over staffing decisions, and therefore, Miske was a DNRC employee.The court also ruled that the DNRC didn't commit intentional interference with contractual relations as it wasn't a stranger to Miske's relationship with the Commission. Additionally, the court found that Miske's lobbying efforts on behalf of the Commission were made in her capacity as a DNRC employee and thus were not protected political speech. Lastly, the court held that the DNRC had good cause to terminate Miske due to her repeated failures to provide the DNRC with state-issued credit card statements, which constituted a legitimate business reason for her termination. View "Miske v. DNRC" on Justia Law