Justia Labor & Employment Law Opinion Summaries

Two Texas employers: Braidwood Management, Inc. (“Braidwood”) and Bear Creek Bible Church (“Bear Creek”), filed suit, as per their closely held religious beliefs, asserting that Title VII, as interpreted in the EEOC’s guidance and Bostock, prevents them from operating their places of employment in a way compatible with their Christian beliefs. Plaintiffs have implicitly asserted that they will not alter or discontinue their employment practices. all parties admitted in district court that numerous policies promulgated by plaintiffs (such as those about dress codes and segregating bathroom usage by solely biological sex) already clearly violate EEOC guidance. Both plaintiffs also contend that they are focused on individuals’ behavior, not their asserted identity.   The Fifth Circuit affirmed the district court’s conclusion that plaintiffs’ claims are justiciable; reversed the class certifications; affirmed the judgment against Bear Creek; affirmed the ruling that Braidwood is statutorily entitled to a Title VII exemption; vacated the judgment that Braidwood is constitutionally entitled to a Title VII exemption; and vacated the judgment regarding the scope-of-Title-VII claims as a matter of law. The court reasoned that under the facts presented, it cannot determine a more appropriate, limited class definition for any of the classes presented here. Accordingly, the court held that both Braidwood and Bear Creek have standing and bring individual claims. Further, the court explained that the EEOC failed to show a compelling interest in denying Braidwood, individually, an exemption. The agency does not even attempt to argue the point outside of gesturing to a generalized interest in prohibiting all forms of sex discrimination in every potential case. View "Braidwood Management v. EEOC" on Justia Law

The Supreme Court affirmed the judgment and orders approving a settlement between Robert Allum and Montana State Fund and dismissing Allum's claims for benefits, holding that Allum resolved all of his dispute benefits, and therefore, the Workers' Compensation Court (WCC) did not have jurisdiction over Allum's remaining stand-alone constitutional challenges.The State Fund accepted liability for the knee injury Allum received at work. Later, Allum notified State Fund that he also asserted a back condition resultant from his knee injury. Allum filed a petition seeking a hearing on his injury claims and also sought a hearing on his claims challenging the constitutionality of the Montana Workers' Compensation Act and the WCC. Allum and State Fund settled the injury claims prior to trial. The WCC approved the settlement agreement and then concluded that it lacked jurisdiction to address Allum's constitutional challenges because Allum had resolved all of his benefit disputes. The Supreme Court affirmed, holding that the WCC's conclusions of law were correct. View "Allum v. Mont. State Fund" on Justia Law

The Supreme Court reversed the judgment of the appellate court affirming the decision of the Compensation Review Board upholding the finding and award of the Workers' Compensation Commissioner for the Second Districting ordering the town of Waterford to accept as compensable Plaintiff's claim for heart disease benefits pursuant to Conn. Gen. Stat. 7-433c, holding that the appellate court erred.In concluding that Plaintiff was entitled to benefits the Commissioner determined that section 7-433c does not define the phrase "uniformed member of a paid municipal fire department." The appellate court affirmed. On appeal, the town argued that the appellate court erred in determining that the definition of "member" in Conn. Gen. Stat. 7-425(5) does not govern whether the plaintiff was a uniformed member of a paid municipal fire department for purposes of section 7-433c. The appellate court affirmed. The Supreme Court reversed, holding that the definition of "member" in section 7-425(5) governs eligibility for benefits under section 7-433c. View "Clark v. Waterford, Cohanzie Fire Dep't" on Justia Law

CSX Transportation, Inc. (“CSXT”) issued furlough notices to employees at its facility in Huntington, West Virginia. Shortly thereafter, over 65 employees submitted forms requesting to take medical leave based on claimed minor soft-tissue injuries sustained while off duty. The forms were similar in content; all were signed by one of two chiropractors; and all called for medical leave of eight weeks or more.Under CSXT’s benefit plans, if an employee were furloughed while on medical leave, the employee would receive health and welfare benefits for up to two years. Otherwise, a furloughed employee would receive such benefits for only four months. Suspecting benefits fraud, CSXT charged the employees with violating its workplace rule against dishonesty and, following hearings, terminated their employment.Plaintiffs, a group of 58 terminated employees, claimed violations of their rights under federal and state law, including violations of the Employee Retirement Income Security Act of 1974 (“ERISA”), the Rehabilitation Act of 1973, the West Virginia Human Rights Act, and the Family and Medical Leave Act of 1993 (“FMLA”). The district court granted summary judgment to CSXT on all claims and Plaintiffs appealed.The Fourth Circuit affirmed, finding that Employer's belief that Plaintiff employees committed benefits fraud was a legitimate and nondiscriminatory reason for terminating Plaintiffs and that Plaintiffs couldn't prove pretext or retaliation. View "Justin Adkins v. CSX Transportation, Inc." on Justia Law

Plaintiff sought judicial review of the Merit Systems Protection Board’s (MSPB) final decision affirming his removal from the Department of Homeland Security (DHS) but filed his complaint in the district court one day after the statutory deadline prescribed in 5 U.S.C. Section 7703(b)(2). The district court dismissed his complaint as untimely. The district court held in the alternative that Plaintiff had not presented facts to warrant equitable tolling.   The DC Circuit affirmed the dismissal on the alternative ground that Robinson failed to show that he was entitled to equitable tolling. The court explained that in light of the combined weight of intervening United States Supreme Court authority and the decisions of the other circuits interpreting section 7703(b)(2) as a non-jurisdictional claims-processing rule since King, the court now holds that section 7703(b)(2)’s thirty-day filing deadline is a non-jurisdictional claims-processing rule. As such, the record shows that Plaintiff chose to mail his complaint by standard mail four days before the statutory filing deadline and assumed the risk his complaint would arrive late. On these facts, Plaintiff’s decision to use standard mail is a 14 “garden variety claim of excusable neglect” insufficient to warrant equitable tolling. View "Adam Robinson v. DHS Office of Inspector General" on Justia Law

Plaintiff-appellant Sharhea Wise worked as a mail carrier for the United States Postal Service. When she got pregnant, she asked to avoid handling heavy items. The Postal Service agreed to provide help when items were too heavy, but Wise needed to tell someone when she needed help. On two occasions, Wise allegedly had to handle items that were too heavy. Both times, she blamed the Postal Service for failing to accommodate her need for help. The Postal Service argued in response that Wise hadn’t asked for help. Days after Wise allegedly had to handle the heavy items, she walked off the job and the Postal Service fired her. Wise claimed retaliation, attributing the firing to her requests for help. The Postal Service denied retaliation, explaining that it had fired Wise because she walked off the job. Wise characterized this explanation as pretextual. The district court granted summary judgment to the Postal Service, and Wise challenged the rulings. The Tenth Circuit agreed with her challenge on the failure-to-accommodate claim. "On this claim, a reasonable factfinder could find that the Postal Service had failed to accommodate Ms. Wise’s need to avoid handling heavy items." But the Court agreed with the grant of summary judgment on the retaliation claim because: (1) the Postal Service presented a neutral, nonretaliatory explanation for the firing; and (2) Wise lacked evidence of pretext. View "Wise v. DeJoy" on Justia Law

The Supreme Court reversed the decision of the court of appeals and reinstated the opinion and award filed by the North Carolina Industrial Commission in favor of Plaintiff following a tractor-trailer accident in which Plaintiff, an employee a trucking company, sustained injury, holding that the agency's decision should not have been disturbed by the lower appellate court.After the accident, Plaintiff provided notice to her employer and its insurance carrier of the accident and of the injury her husband received in the accident but did not report injury to herself. The Commission concluded that Plaintiff's injury was causally related to the accident, that Plaintiff had a reasonable excuse for not providing notice of her injury until two years later, that Defendants were not prejudiced, and that Plaintiff was totally disabled as a result of her injury. The court of appeals reversed. The Supreme Court reversed, holding that there was no error in either the Commission's findings of fact or in its conclusions of law. View "Sprouse v. Turner Trucking Co." on Justia Law

The Supreme Court reversed the judgment of the district court denying Thomas L. Cardella & Associates' (Cardella) motion for judgment notwithstanding the verdict in this case alleging common law negligent supervision or retention, holding that the claim was barred by the Iowa Workers' Compensation Act (IWCA), Iowa Code ch. 85.Plaintiff sued Cardella two years after she quit her employment there. Because she missed the deadline for bringing a hostile work environment claim under the Iowa Civil Rights Act (ICRA), Iowa Code ch. 216, Plaintiff sued for common law negligent supervision or retention and presented her claim to the jury seeking emotional distress damages related to her mental health as a negligent supervision claim premised on Cardella failing to protect her from assault and battery. After a trial, the jury awarded Plaintiff $400,000 in emotional distress damages. The Supreme Court reversed, holding that, as presented to the jury, Plaintiff's claim was barred by IWCA. View "McCoy v. Thomas L. Cardella & Associates" on Justia Law

Plaintiff, a lieutenant in the Kankakee Fire Department (“KFD”)—was attacked by another firefighter while responding to a fire at a senior living facility. The City suspended the other firefighter for twenty-four hours without pay, ordered him to complete an anger management course, and directed him to avoid working on the same shift as Plaintiff for three months. Plaintiff experienced ongoing physical and mental injuries from the incident, causing her to take leave from work and apply for workers’ compensation. She returned to work six months later but permanently left her position shortly after. She then filed a lawsuit, alleging that Defendants, among other things, retaliated against her for certain protected activities under Title VII and condoned aggressive and inappropriate behaviors as part of a “code of silence” that resulted in her attack. The district court granted summary judgment for Defendants, and this appeal followed.   The Seventh Circuit affirmed. The court explained that on the merits, Plaintiff’s claim fails because none of her evidence, separately or taken together, creates a genuine dispute regarding whether Defendants had a practice of condoning aggressive behavior, resulting in a constitutional injury. Further the court wrote that the record does not support Plaintiff’s contention that there was such a high risk of constitutional injury from the other firefighter that the “single incident” theory of municipal liability applies here. The court held Plaintiff failed to create a genuine dispute of material fact precluding summary judgment regarding her Fourth Amendment Monell claim and her Title VII retaliation claim. The district court, therefore, properly granted summary judgment to Defendants. View "Michelle Giese v. City of Kankakee" on Justia Law

The Supreme Court granted in part and denied in part a writ requested by Petitioners prohibiting the Honorable David H. Wilmoth, Judge of the Circuit Court of Randolph County, from enforcing its order denying Petitioners' motion to dismiss certain claims set forth in the underlying wrongful termination complaint, holding that some of Respondents' claims should have been dismissed.On appeal, Respondents argued that Petitioners failed to exhaust their administrative remedies through the state public employees grievance procedure, W. Va. Code 6C-2-1 to -8, and that other claims were subject to dismissal for failure to state a claim upon which relief can be granted. The Supreme Court granted the requested writ in part, holding (1) the circuit court erred in denying Respondents' motion to dismiss certain claims; and (2) the remaining claims were not barred by the exhaustion rule and were sufficiently pled to go forward. View "State ex rel. Devono v. Honorable Wilmoth" on Justia Law