Justia Labor & Employment Law Opinion Summaries

In the case at hand, the United States Court of Appeals for the Seventh Circuit reviewed an employment discrimination case. The plaintiff, LuzMaria Arroyo, a military reservist, brought a lawsuit against her employer, Volvo Group North America, LLC, alleging discrimination based on her military status and her post-traumatic stress disorder (PTSD). After a jury ruled in Arroyo's favor and awarded her $7,800,000 in damages, the district court granted judgment as a matter of law to Volvo on Arroyo’s Americans with Disabilities Act (ADA) claim, and ordered a new trial on the remaining Uniformed Services Employment and Reemployment Rights Act (USERRA) claim, where the jury found for Volvo. Arroyo appealed this decision.The Court of Appeals affirmed the district court's decision. The court found that Arroyo was not a "qualified individual" under the ADA as she failed to comply with Volvo's attendance policy, an essential job function. Arroyo's positive job performance reviews did not negate her violation of the attendance policy. The court also found no conflict with its previous decision in Arroyo I, which had reversed the district court's grant of summary judgment to Volvo on the ADA and USERRA claims.Further, the court upheld the district court's decision for a new trial on the USERRA claim. The court agreed that the jury’s verdict as to the ADA claim was influenced by passion and prejudice that also tainted the jury’s determination of USERRA liability. Finally, the court found no abuse of discretion in the district court's decision to exclude evidence of Arroyo’s PTSD in the new trial, as PTSD alone was not sufficient to raise a cognizable discrimination claim under USERRA. View "Arroyo v. Volvo Group North America, LLC" on Justia Law

In this case, the Plaintiff, Barbara M. Parmenter, had subscribed to a long-term care insurance policy offered by her employer, Tufts University, and underwritten by The Prudential Insurance Company of America. The policy was governed by the Employee Retirement Income Security Act of 1974. After Prudential twice increased Parmenter's premium rate payments for her policy, she sued Tufts and Prudential, alleging each breached their respective fiduciary duties owed to her when Prudential increased those rates. The defendants responded with motions to dismiss for failure to state a plausible claim. The district court granted each of their motions and Parmenter appealed.The United States Court of Appeals For the First Circuit found that the language in the policy stating that premium increases would be "subject to the approval of the Massachusetts Commissioner of Insurance" was ambiguous, and could not be definitively interpreted based solely on the pleadings and contract documents currently available. Therefore, the court reversed the district court's decision to dismiss the case against Prudential and remanded it for further proceedings.However, the court affirmed the dismissal of the case against Tufts, as Parmenter's allegations that Tufts failed to prevent the premium rate increases or monitor Prudential did not fall into one of the categories of co-fiduciary liability set forth in section 1105(a) of the Employee Retirement Income Security Act. View "Parmenter v. Prudential Ins. Co. of America" on Justia Law

In this case, the plaintiff, an African-American male, brought an employment discrimination lawsuit against his former employer, Genzyme Therapeutic Products, LP, and one of its executives. The plaintiff alleged racial discrimination, harassment, and retaliation. The district court granted summary judgment in favor of the defendants, finding that the plaintiff failed to provide sufficient proof that the employer's stated rationale for certain adverse employment actions was pretextual. The court also found that the plaintiff did not provide enough evidence to demonstrate a causal connection between the alleged protected conduct (filing a complaint against another employee for racial discrimination) and the adverse action (a poor performance review).On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court held that the plaintiff failed to establish that there was a genuine issue of material fact as to whether the employer's proffered reason for the negative performance review was a pretext for discrimination. The court noted that the plaintiff's argument relied heavily on speculation and conjecture rather than definite and competent evidence. The court also highlighted that even if the plaintiff's direct manager thought he was deserving of a higher rating, this did not shed light on the executive's view, nor did it allow a reasonable juror to find that the executive's stated rationale was pretextual. The court concluded that a single racially tinged comment made by the executive was not sufficient to prove discriminatory intent. View "Boykin v. Genzyme Therapeutic Products, LP" on Justia Law

In this case before the United States Court of Appeals for the First Circuit, five groups of current and former public employees in the Commonwealth of Puerto Rico (the "Commonwealth") appealed an order by the court overseeing the Commonwealth-wide debt restructuring litigation (the "Title III court") on their motions to secure administrative-expense priority for their back pay claims. The back pay claims arose from allegations that their public employers failed to adjust their wages upward, a violation of Puerto Rico law. The Title III court had previously rejected efforts to assert administrative-expense priority for back pay for work performed before the commencement of the Commonwealth's debt restructuring case under Title III of the Puerto Rico Oversight, Management, and Economic Stability Act ("PROMESA").The appellate court affirmed the Title III court's decision. The appellate court agreed that the pre-petition work claims did not qualify for administrative-expense priority under § 503(b)(1)(A)(ii) of the Bankruptcy Code, which is incorporated into PROMESA, because they were not "wages and benefits awarded pursuant to a judicial proceeding . . . as back pay attributable to any period of time occurring after commencement of the case under this title." The appellate court also held that the Title III court did not abuse its discretion in deferring its decision on administrative-expense status for back pay claims concerning work performed post-petition but for which there has not yet been any judgment in the underlying commonwealth court and agency proceedings. View "Abraham Gimenez Plaintiff Group v. FOMB" on Justia Law

In this case heard by the United States Court of Appeals for the Seventh Circuit, the plaintiff, Alexis Wells, sought to hold her employer, The Freeman Company, liable for sexual assault committed by a fellow employee, Timothy Vaughn. Wells asserted that the company should be held responsible under Title VII, the Indiana Wage Payment Statute, and various tort theories. The court, however, affirmed the district court's ruling that Wells was an independent contractor, not an employee, which meant that Freeman's conduct was not tortious and Vaughn's actions could not be attributed to Freeman. The court applied the Knight factors, which analyze the "economic realities" of a work relationship, to determine whether a worker is an employee for purposes of Title VII. The court concluded that most of these factors pointed towards Wells being an independent contractor. Thus, her claims under Title VII and the Indiana Wage Payment Statute failed. The court also dismissed Wells' state law claims for Intentional Infliction of Emotional Distress (IIED) and Negligent Infliction of Emotional Distress (NIED), concluding that Freeman's pre-litigation conduct was not so outrageous as to be regarded as "atrocious," and that Vaughn's conduct was outside the scope of his employment, respectively. Therefore, the court could not hold Freeman vicariously liable for Vaughn's actions. View "Wells v. Freeman Company" on Justia Law

Hospital Menonita de Guayama, Inc. (Petitioner) purchased Hospital San Lucas Guayama (Hospital San Lucas) and became a successor employer. Hospital San Lucas had previously recognized five distinct bargaining units of employees represented by Unidad Laboral de Enfermeras (OS) y Empleados de la Salud (Union). However, after acquiring Hospital San Lucas, Petitioner first failed to bargain in good faith with the Union, then serially withdrew recognition from the Union as the collective bargaining agent for each of the five units. As a result, the National Labor Relations Board (Board) filed a complaint against the Petitioner, alleging violations of Sections 8(a)(5) and (1) of the National Labor Relations Act.The United States Court of Appeals for the District of Columbia Circuit upheld the Board's decision. The court found that the Board had correctly applied the "successor bar" rule, which holds that an incumbent union enjoys an irrebuttable presumption of majority status for a reasonable period of time following the successor employer's voluntary recognition of the union. The court concluded that, on the facts presented, the Board’s application of the successor bar rule was consistent with established Board precedent, permissible, and reasonable. The Board's conclusion that Petitioner refused to bargain in good faith with the Union and engaged in multiple unfair labor practices followed directly from established Board precedent. The court also rejected Petitioner's request to overturn the successor bar rule. View "Hospital Menonita de Guayama, Inc. v. NLRB" on Justia Law

Paulo Trindade, a former employee of Grove Services, Inc., sued his previous employer for breach of contract and violations of the Massachusetts Wage Act, claiming he had been underpaid on his sales commission compensation for the years 2014, 2015, and 2016. Following a bench trial, the United States District Court for the District of Massachusetts ruled in part for Trindade and in part for Grove, awarding Trindade $330,597 in damages. Both parties appealed. The United States Court of Appeals for the First Circuit affirmed the lower court's judgment. The Court of Appeals agreed with the district court's conclusion that Trindade's amended complaint, which included a claim for unpaid wages for 2016, related back to his original complaint, making the claim timely under Massachusetts law. The Court of Appeals also concluded that the district court was correct in its decision to award the damages it did, including an amount for the late payment and underpayment of Trindade's 2016 commission. View "Trindade v. Grove Services, Inc." on Justia Law

The case involves plaintiff-appellant Cassandra Kincaid, an assistant principal at Central Middle School in Kansas, who claimed that she was harassed by the Unified School District No. 500 in retaliation for her reporting a student-on-student sexual assault. The United States Court of Appeals for the Tenth Circuit affirmed the district court's grant of summary judgment in favor of the school district. The court concluded that Kincaid did not satisfy her burden of creating a genuine dispute of material fact that the reasons given for the alleged material adverse actions against her were pretextual. The court examined various aspects of the case under Title VII and Title IX, which prohibit retaliation against individuals for complaining of sex discrimination. It considered numerous allegedly adverse employment actions, including two emails sent by the school principal, a request for Kincaid's transfer, and a letter of concern. The court concluded that none of the evidence Kincaid provided created a genuine dispute of material fact about pretext. View "Kincaid v. Unified School District No. 500, Kansas City, KS" on Justia Law

Jeffrey Bruno, a veteran firefighter with the Kankakee Fire Department, sued Mayor Chasity Wells-Armstrong, James Ellexson, the Human Resources Director for the City of Kankakee, and the City of Kankakee, alleging discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA). Bruno suffered a severe cardiac event in 2017 and upon his return to work was promoted to Deputy Chief. However, in 2019, he was denied a raise and presented with an employment contract that tied additional compensation to his enrollment in college courses. When Bruno requested the removal of this education condition, citing his heart condition as a barrier to attending classes, his request was denied. After signing the contract, Bruno retired and initiated legal proceedings.The United States Court of Appeals For the Seventh Circuit affirmed the district court's decision, which had granted summary judgment for the defendants. The court concluded that Bruno's request to remove the education condition was not a request for a reasonable accommodation under the ADA, as it would not impact his ability to perform his job. The court also rejected Bruno's claim of disparate treatment, as his argument of pretext was contradicted by the evidence. Bruno's ADA retaliation claim also failed because his identified protected activity was not protected under the ADA. As Bruno's IHRA and indemnification claims were dependent on his ADA claims, these too were rejected. View "Bruno v. Wells-Armstrong" on Justia Law

In the case before the United States Court of Appeals for the Fourth Circuit, Bikachi Amisi, a contract nurse, sued Officer Lakeyta Brooks and Officer Roy Townsend for violating her Fourth Amendment rights when she was mistakenly strip searched on her first day of work at Riverside Regional Jail. Amisi also brought several tort claims under Virginia state law. The defendants moved for summary judgment, arguing they were entitled to qualified immunity and good-faith immunity under Virginia law. They also argued that the Virginia Workers’ Compensation Act’s exclusivity provision barred Amisi's claims. The district court denied their motions and the defendants appealed.The Court of Appeals affirmed the district court's decision. It held that both officers were not entitled to qualified immunity, a legal protection that shields officers who commit constitutional violations but who could reasonably believe their actions were lawful, because their actions were not reasonable and Amisi’s right to be free from unreasonable strip searches was clearly established. The court also held that the Virginia Workers' Compensation Act did not bar Amisi's state-law claims because her injuries did not arise out of her employment. The Court further held that Officer Townsend was not entitled to immunity under Virginia law as his belief that his conduct was lawful was not objectively reasonable. View "Amisi v. Brooks" on Justia Law