Justia Labor & Employment Law Opinion Summaries

Frankie Nelson worked at Provident Hospital, part of the Cook County Health and Hospital System, from 1997 until her voluntary retirement in 2010. She held union positions, first as Environmental Services Supervisor and later as Building Custodian I. Between 2002 and 2005, Nelson and a male colleague, Henry White, shared the duties of Acting Assistant Director of Environmental Services, each handling different aspects of the role in addition to their regular jobs. Nelson later alleged that, during this period, she was paid less than similarly situated male employees due to sex discrimination, focusing her claim on the pay disparity between herself and White, as well as two Directors, Nate Gordon and Jerry Brown.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of Cook County on both Nelson’s Title VII and Equal Pay Act claims. On appeal, Nelson challenged only the summary judgment on her Title VII claim, arguing that the district court failed to apply the correct legal standard and erred in determining that White was not a valid comparator. The district court had found that Nelson did not provide evidence of White’s compensation to support her claim of pay disparity and further concluded that White, Gordon, and Brown were not similarly situated to Nelson due to differences in job duties, qualifications, and supervisory roles.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court applied the correct legal standards, including both the McDonnell Douglas framework and the totality of the evidence approach. The court concluded that Nelson failed to provide sufficient evidence of pay disparity with White and that none of the alleged comparators were similarly situated to her. Therefore, summary judgment for the defendant was properly granted. View "Nelson v County of Cook" on Justia Law

A former dancer at two adult entertainment clubs in Manhattan filed a class charge with the Equal Employment Opportunity Commission (EEOC), alleging pervasive sexual harassment and a hostile work environment affecting herself and other female dancers. She claimed that the clubs’ policies and practices fostered this environment, including being forced to change in open areas monitored by video and being pressured to engage in sexual acts with customers. After receiving the charge, the EEOC requested information from the clubs, including employee “pedigree” data such as names, demographics, and employment details. The clubs objected, arguing the requests were irrelevant and burdensome, but the EEOC issued subpoenas for the information.The United States District Court for the Southern District of New York granted the EEOC’s petition to enforce the subpoenas, finding the requested information relevant to the investigation and not unduly burdensome for the clubs to produce. The clubs appealed and, while the appeal was pending, the EEOC issued a right-to-sue letter to the charging party, who then filed a class action lawsuit in the same district court. The clubs argued that the EEOC lost its authority to investigate and enforce subpoenas once the right-to-sue letter was issued and the lawsuit commenced.The United States Court of Appeals for the Second Circuit held that the EEOC retains its statutory authority to investigate charges and enforce subpoenas even after issuing a right-to-sue letter and after the charging party files a lawsuit. The court also found that the employee information sought was relevant to the underlying charge and that the clubs had not shown compliance would be unduly burdensome. The Second Circuit therefore affirmed the district court’s order enforcing the subpoenas. View "EEOC v. AAM Holding Corp." on Justia Law

The plaintiff, a mail clerk with sickle cell anemia, was employed by the United States Postal Service (USPS) and had a history of attendance issues, some of which were covered by the Family Medical Leave Act (FMLA). To avoid termination, he entered into a Last Chance Agreement (LCA) that limited unscheduled absences and specified that FMLA-approved absences would not count against him if properly documented. After several disputed absences, some of which the plaintiff claimed were FMLA-protected, USPS terminated his employment for violating the LCA.The United States District Court for the Eastern District of Michigan granted summary judgment in favor of USPS on most of the plaintiff’s claims, finding that he failed to establish FMLA coverage for all but one disputed date and did not sufficiently notify USPS of a need for accommodations under the Rehabilitation Act. The court also held that the plaintiff’s FMLA medical certification, which estimated two days of intermittent leave per month, created a hard cap on his FMLA leave. The plaintiff’s claims regarding one date were settled, and his motion for reconsideration was denied.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court affirmed the district court’s decision regarding the December 26, 2018 absence and the Rehabilitation Act claim, finding no evidence of a request for accommodation. However, it reversed the district court’s holding that the FMLA medical certification imposed a strict monthly limit on unforeseeable intermittent leave, clarifying that such certifications provide only estimates, not hard caps. The court remanded for further proceedings to determine whether the plaintiff gave proper notice for FMLA leave on certain dates and vacated the district court’s summary judgment on FMLA interference and retaliation claims related to the LCA, pending resolution of factual disputes. View "Jackson v. Postal Service" on Justia Law

A worker in Humboldt County performed maintenance and other services for several years on property managed by his employers, in exchange for free rent but without additional pay or benefits. After the arrangement ended, he filed claims with the Labor Commissioner, asserting he was an employee entitled to unpaid wages, liquidated damages, and penalties, including under California’s Paid Sick Leave law. The employers contended he was an independent contractor, but the Labor Commissioner found he was an employee and awarded him compensation.The employers appealed the Labor Commissioner’s decision to the Humboldt County Superior Court, which conducted a de novo bench trial. The court agreed that the worker was an employee and awarded unpaid wages, penalties, and interest. However, it denied liquidated damages, finding the employers acted in good faith based on their mutual understanding with the worker that he would work for rent and not as an employee. The court also rejected the worker’s claim for penalties under the Paid Sick Leave law, concluding such claims could not be raised in court during an employer’s appeal of a Labor Commissioner ruling. The worker appealed, and the California Court of Appeal affirmed the superior court’s rulings on both the liquidated damages and Paid Sick Leave issues.The Supreme Court of California reviewed the case. It held, first, that to establish a good faith defense to liquidated damages for minimum wage violations, an employer must show it made a reasonable attempt to determine the requirements of minimum wage law; mere ignorance of the law is insufficient. Second, the court held that an employee may raise a claim under the Paid Sick Leave law in the context of an employer’s appeal to the superior court of a Labor Commissioner ruling. The Supreme Court reversed the Court of Appeal’s judgment and remanded for further proceedings. View "Iloff v. LaPaille" on Justia Law

A police sergeant in Dermott, Arkansas, was terminated from his position after being charged with tampering with physical evidence and abuse of office. The charges stemmed from an incident in which the sergeant received a bag of quarters, believed to be stolen, from another officer following a robbery investigation. The sergeant’s documentation of the evidence was inconsistent, and the quarters were not turned in to the department. During a subsequent investigation, the sergeant admitted he may have used the quarters for personal purposes. Although the charges were later dismissed, the sergeant maintained that his termination was solely due to the criminal charges. He also previously reported another officer’s excessive use of force, which he claimed was a motivating factor in his firing.The United States District Court for the Eastern District of Arkansas granted summary judgment and judgment on the pleadings in favor of the defendants, including the police chief, the officer involved, and the city. The court found that the sergeant failed to establish a genuine dispute of material fact regarding whether his termination was motivated by his protected speech, as the firing occurred long after his report and the criminal charges provided an obvious alternative explanation. The court also determined that the sergeant was not seized under the Fourth Amendment, negating his malicious prosecution claim, and that he lacked a property interest in his employment under Arkansas law, defeating his due process claims. The court exercised supplemental jurisdiction over the state law claims and found them lacking on the merits, including claims under the Arkansas Whistle-Blower Act, malicious prosecution, abuse of process, and defamation.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court held that the sergeant failed to present sufficient evidence to support his federal constitutional claims or his state law claims, and that the district court did not abuse its discretion in retaining and resolving the state law claims. View "Brown v. City of Dermott Arkansas" on Justia Law

The plaintiff, a former police officer in Dermott, Arkansas, alleged that he was forced to resign in retaliation for reporting a fellow officer’s excessive use of force. The incident in question involved the other officer grabbing an arrestee by the neck while the arrestee was restrained. Subsequently, the officer accused the plaintiff of taking money from a parolee, which the parolee confirmed in a statement. The police chief referred the matter to a prosecutor, who initiated a state police investigation. During this period, the plaintiff’s employment status became unclear, with conflicting statements about whether he was fired or resigned. The plaintiff ultimately resigned after a job offer from another police department was rescinded due to the ongoing investigation. He was later charged with abuse of office and witness bribery, but the charges were dismissed when the parolee could not be located.The United States District Court for the Eastern District of Arkansas granted summary judgment in favor of the defendants on all claims. The court found that the plaintiff had voluntarily resigned and had not suffered an adverse employment action, which was necessary for his First Amendment retaliation claim. The court also determined that the plaintiff was not “seized” within the meaning of the Fourth Amendment for his malicious prosecution claim, as a summons to appear in court did not constitute a seizure. The court exercised supplemental jurisdiction over the state law claims and found that they failed on the merits, including claims under the Arkansas Whistle Blower Act, malicious prosecution, abuse of process, and defamation.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that the plaintiff’s voluntary resignation did not amount to an adverse employment action, and that he was not seized under the Fourth Amendment. The court also agreed that the state law claims failed as a matter of law. View "Brown v. City of Dermott Arkansas" on Justia Law

Dean Naylor served as the jail administrator for the Muscatine County Sheriff’s Office from 2010 until his termination in May 2020. His firing followed public controversy over religious commentary he posted online, including a document and YouTube videos expressing post-tribulation Rapture beliefs and making inflammatory statements about Muslims and the gay community. After a local newspaper article highlighted these views, public officials and community members raised concerns about the treatment of detainees at the jail, and representatives from Johnson County and the United States Marshals Service questioned whether they would continue housing overflow inmates at the facility.Naylor sued Muscatine County in the United States District Court for the Southern District of Iowa, alleging his termination violated Title VII by discriminating against him based on his religion. The district court granted summary judgment to Muscatine County, finding that retaining Naylor would impose an undue hardship on the County, specifically citing potential harm to the jail’s public image and the risk to business relationships with outside entities that contract for overflow detainee housing.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment ruling de novo. The appellate court held that Muscatine County had not provided sufficient evidence to establish, as a matter of law, that retaining Naylor would cause an undue hardship under Title VII. The court found that the evidence of reputational harm and threatened business relationships was speculative and did not eliminate genuine disputes of material fact. Accordingly, the Eighth Circuit reversed the district court’s grant of summary judgment and remanded the case for further proceedings. View "Naylor v. County of Muscatine" on Justia Law

Eugene Hudson, a long-time member and leader within the American Federation of Government Employees (AFGE), was twice removed from his position as National Secretary-Treasurer after he criticized the union’s leadership and use of resources while campaigning for union president. Hudson’s communications, including a letter and an email sent to union officers using union resources, led to internal disciplinary proceedings. The AFGE’s National Executive Council found that Hudson’s actions violated the union’s constitution, resulting in his removal in August 2017. After a preliminary injunction reinstated him, a second investigation led to his removal again in February 2018. Hudson amended his lawsuit to challenge both removals, alleging they were acts of retaliation for his protected speech under section 101(a)(2) of the Labor-Management Reporting and Disclosure Act (LMRDA).The United States District Court for the District of Columbia presided over a jury trial, where the jury found that AFGE unlawfully retaliated against Hudson in the first removal but not the second, awarding no damages. Hudson moved for a new trial, arguing that the jury instructions misstated the causation standard and the burden of proof. The district court denied the motion, holding that Hudson had not properly preserved his objections and that the instructions were not plainly erroneous.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that a retaliation claim under LMRDA section 101(a)(2) requires proof of but-for causation, not merely that protected speech was a motivating factor. The court also found that Hudson could not challenge the burden of proof instruction because he had proposed the language used. The court affirmed the district court’s judgment, denying Hudson’s request for a new trial. View "Hudson v. American Federation of Government Employees" on Justia Law

In this case, a group of pensioners from a multiemployer retirement fund governed by ERISA challenged the reduction of their pension benefits following the enactment of the Multiemployer Pension Reform Act of 2014 (MPRA). The MPRA allowed plan administrators to reduce benefits for current and future beneficiaries in order to prevent plan insolvency, subject to certain procedural safeguards and approval by the U.S. Department of the Treasury. The plaintiffs, who had vested rights to their pension benefits, argued that these reductions constituted an uncompensated taking under the Fifth Amendment.The United States Court of Federal Claims granted summary judgment in favor of the government. The Claims Court found that while the plaintiffs had a cognizable property interest in their vested pension benefits, the reduction of those benefits did not amount to a physical taking. Instead, the court analyzed the claim as a regulatory taking under the Penn Central framework and concluded that the economic impact, interference with investment-backed expectations, and the character of the government action did not support a finding of a taking.On appeal, the United States Court of Appeals for the Federal Circuit affirmed the Claims Court’s decision. The Federal Circuit held that the MPRA’s reduction of pension benefits was not a physical taking because the plaintiffs had only a contractual right to payment, not a property interest in the plan’s assets, and the government did not appropriate any specific property for itself or a third party. The court further held that, under the Penn Central test, the reduction did not constitute a regulatory taking, as the economic impact was not severe, the plaintiffs’ expectations were not unduly interfered with given the heavily regulated nature of pension plans, and the government action served a substantial public purpose. The judgment for the government was affirmed. View "KING v. US " on Justia Law

Four former employees of grocery store chains, who participated in a defined contribution 401(k) retirement plan, brought a putative class action under the Employee Retirement Income Security Act of 1974 (ERISA). They alleged that the plan’s fiduciaries mismanaged the plan by failing to prudently select and monitor investment options, failing to act solely in the interest of plan participants, and allowing excessive fees and improper compensation arrangements. The plaintiffs sought monetary and injunctive relief on behalf of themselves, the plan, and a proposed class of similarly situated participants.The United States District Court for the Northern District of New York dismissed several of the plaintiffs’ claims for lack of Article III standing, finding that the plaintiffs had not alleged any concrete injury to their individual accounts from the alleged mismanagement of certain investment options or from the plan’s compensation arrangements. The district court concluded that because the plaintiffs had not invested in the specific funds they challenged, or had not shown that the alleged breaches affected their own accounts, they lacked standing to pursue those claims. The court did find standing for some claims related to funds in which the plaintiffs had invested, but ultimately dismissed those claims for failure to state a claim and denied leave to amend.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the district court’s dismissal of the claims for lack of standing. The Second Circuit held that participants in a defined contribution plan must plausibly allege a concrete, individualized financial injury to establish Article III standing for monetary relief under ERISA. Because the plaintiffs did not allege that they suffered losses in their own accounts from the challenged conduct, they lacked both individual and class standing for those claims. The court affirmed in part and vacated in part the district court’s judgment, remanding for further proceedings consistent with its opinion. View "Collins v. Ne. Grocery, LLC" on Justia Law