Justia Labor & Employment Law Opinion Summaries

The Supreme Court reversed the opinion of the court of appeals reversing the trial court's dismissal of Plaintiff's complaint for malicious prosecution against his union, the local chapter, and several individuals associated with the union, holding that Plaintiff did not allege sufficient facts for a court to conclude that the dismissal of his criminal case was a favorable termination.Plaintiff brought this action alleging that the union's leadership accused him of misusing union funds after he publicly criticized the union's financial waste, leading to his indictment on two felony charges. The State successfully moved to retire the charges for one year, after which the charges were dismissed. The trial court dismissed Plaintiff's malicious prosecution claim on the basis that the retirement and dismissal of the criminal charges was not a favorable termination on the merits. The court of appeals reversed. The Supreme Court reversed, holding (1) Plaintiffs can pursue a claim for malicious prosecution only if an objective examination, limited to the documents disposing of the proceeding or the applicable procedural rules, indicates the termination of the underlying criminal proceeding reflects on the merits of the case and was due to the innocence of the accused; and (2) under this standard, Plaintiff did not allege sufficient facts to survive a motion to dismiss. View "Mynatt v. National Treasury Employees Union, Chapter 39" on Justia Law

After being fired by his employer, Anheuser-Busch Companies, LLC, Intervenor filed suit in federal district court, alleging that his termination reflected racial discrimination and retaliation in violation of Title VII. Anheuser-Busch filed a motion seeking to compel arbitration of Intervenor’s district court claims, asserting that at the time when he was hired, Intervenor had agreed to be bound by the company’s Dispute Resolution Policy. Intervenor disagreed that he was required to arbitrate his claims. After Anheuser-Busch asked the district court to compel arbitration, Intervenor filed an unfair labor practice charge with the NLRB, arguing that Defendant’s efforts to enforce its arbitration agreement contravened the collective bargaining agreement and constituted a unilateral change to the terms of Intervenor’s employment, in violation of the National Labor Relations Act (“NLRA”).   The Eleventh Circuit granted the petition for review of the Board’s order dismissing the complaint, vacated the decision of the Board, and remanded for consideration of whether enforcement of the Dispute Resolution Policy against Intervenor would violate the NLRA. The court held that the Board applied an erroneously narrow standard for determining whether Anheuser-Busch’s motion had an illegal objective. The court explained that on remand, the Board should instead determine whether the outcome sought by Anheuser-Busch’s motion— the compelled arbitration of Brown’s Title VII claims under the Dispute Resolution Policy—would violate the NLRA. If the Board decides that the answer to that question is “yes,” it should then order all relief that is appropriate based on Anheuser-Busch’s unlawful conduct. View "International Brotherhood of Teamsters Local 947 v. National Labor Relations Board" on Justia Law

Defendant Niagara Mohawk Power Corporation (the "Company"), which does business as National Grid, is an electric and natural gas utility that operates throughout New York State. According to Plaintiff Local Union 97, International Brotherhood of Electrical Workers, AFL-CIO (the "Union"), Defendant agreed to provide to certain retired employees, former members of the Union. The Union filed a motion to compel arbitration pursuant to section 301(a) of the Labor Management Relations Act, 29 U.S.C. Section 185(a). The same day, the Company filed a motion for summary judgment dismissing the Complaint. The district court granted the Union's motion to compel arbitration, denied the Company's motion for summary judgment, and ordered that the case be closed.   The Second Circuit affirmed, holding that the agreement covers the dispute. The court explained that when it negotiated the Agreement, the Union bargained both for health insurance benefits for retired employees and for a grievance procedure that included, where necessary, access to arbitration. The court explained that it expressed no view on the merits of the Union's grievance; that is a question for the arbitrator. But interpreting the collective bargaining agreement in light of the principles the Supreme Court reaffirmed in Granite Rock, it is clear that the parties intended to arbitrate this dispute. View "Local Union 97, Int'l Bhd. of Elec. Workers, AFL-CIO v. Niagara Mohawk" on Justia Law

In 2001, Sylvester Wince, who is Black, began work as a Hospital maintenance mechanic. In 2010 the Hospital contracted with CBRE. Wince kept his job under the title of Stationary Engineer. Wince is a licensed Stationary Engineer, has a bachelor’s degree, and holds certificates in electricity, air quality, and refrigeration. Collective bargaining agreements (CBAs) governed Wince’s employment. Wince alleges that CBRE denied him a promotion because of his race. Wince’s application for the job was outside CBRE’s usual hierarchy for promotions; the job went to a white man with similar credentials who had gone through that hierarchy. Wince claimed he was the subject of racist slurs and a discriminatory nickname, “Sly.” After Wince told his coworkers he disliked the nickname, they stopped using it. Wince claimed CBRE’s management made comments that revealed racial bias. Wince also alleged that he filed grievances accusing CBRE of denying him holidays, overtime, promotions, and paid time off and that CBRE failed to address them. In 2018 Wince filed a charge of discrimination with the EEOC, which was dismissed. In 2019, Wince quit CBRE for a position at another hospital.The Seventh Circuit affirmed the summary judgment rejection of his claims of racial discrimination and retaliation under 42 U.S.C. 1981 and Title VII; breach of the CBA, the Fair Labor Standards Act, and the Illinois Wage Payment and Collections Act; and constructive discharge. View "Wince v. CBRE, Inc." on Justia Law

The First Circuit affirmed the district court's default judgment in a tort action brought against the owner of a boat that Plaintiff was working on at the time of his injury, holding that the district court did not err in granting default judgment and denying Appellant's request for leave to file a late claim under Supplemental Rule F of the Federal Rules of Civil Procedure.Appellant, a commercial fisherman, filed a complaint in a Massachusetts state court alleging that he was injured while working on a vessel owned by G&J Fisheries, Inc. and that G&J was liable for unseaworthiness and negligence under the Jones Act, 46 U.S.C. 30104. G&J filed a complaint in the federal district court seeking exoneration from liability under 46 U.S.C. 30501-12 and Supplemental Rule F. The district court enjoined all other lawsuits against G&J pursuant to Supplemental Rule F(3) and then granted default judgment for G&J on the grounds that Appellant failed to file a claim as required under the rule. The First Circuit affirmed, holding that the district court did not err in granting default judgment and in denying Appellant's request to file a late claim under Supplemental Rule F(4). View "G&J Fisheries, Inc. v. Costa" on Justia Law

In these actions to recover underinsured motorist benefits allegedly due under certain automobile insurance coverage provided by the State pursuant to a collective bargaining agreement the Supreme Court held that the appellate court incorrectly concluded that the trial court should have reduced one appellant's award by the sums received in settlement of a claim under Connecticut's Dram Shop Act, Conn. Gen. Stat. 30-102.The trial court found for Appellants on liability but awarded only a fraction of the damages sought, due in part to the court's rejection of Appellants' PTSD claim. The appellate court reversed in part, concluding that the trial court's failure to reduce Appellants' damages by their dram shop recovery violated the common-law rule against double recovery. The Supreme Court reversed in part, holding that the appellate court (1) properly affirmed the trial court's conclusion that Appellants were not entitled to recover underinsured motorist benefits for alleged PTSD; and (2) improperly reversed the judgments insofar as the trial court determined that the State was not entitled to a reduction in the awards for sums received by Appellants in settlement of a dram shop claim. View "Menard v. State" on Justia Law

The Supreme Court affirmed the order of the Board of Review (BOR) affirming the finding of the Office of Judges (OOJ) that Respondent's claim for occupational pneumoconiosis benefits against Petitioner was timely, holding that Petitioner was not entitled to relief on its allegations of error.The claims representative for Petitioner's worker's compensation insurance carrier found that Respondent's claim for benefits was filed outside of the pertinent three-year statute of limitations and therefore denied it. The OOJ reversed, ruling that Respondent was not time-barred from filing his claim. Thereafter, the Occupational Pneumoconiosis Board found that Respondent had a ten-percent impairment. The BOR affirmed on the timeliness issue. The Supreme Court affirmed, holding that the BOR did not clearly err in finding that Respondent filed his occupational pneumoconiosis claim within the three-year limitations period. View "Argus Energy, LLC v. Marenko" on Justia Law

Plaintiff filed a class action lawsuit against Medical Center seeking declaratory and injunctive relief and alleging violations of the unfair competition law (UCL) and the Consumer Legal Remedies Act (CLRA) in connection with Medical Center’s emergency room billing practices. Briefly summarized, Plaintiff alleged Medical Center’s practice of charging him (and other similarly situated patients) an undisclosed “Evaluation and Management Services Fee” (EMS Fee) was an “unfair, deceptive, and unlawful practice.” The trial entered judgment in favor of Defendants.   The Fifth Appellate District reversed. The court held that Plaintiff sought a declaration of the parties' rights and duties under the COA and their legal rights in connection with EMS Fee disclosures. An actual controversy is alleged and appears to exist. Plaintiff is entitled to seek declaratory relief in regard to each controversy stated. The court concluded he has adequately stated a cause of action for declaratory relief. The court wrote that on remand, the trial court will have the discretion to consider a motion by Plaintiff to amend the FAC to state a cause of action for breach of contract should Plaintiff choose to file one. View "Naranjo v. Doctors Medical Center of Modesto, Inc." on Justia Law

The Restaurant Law Center and the Texas Restaurant Association (“Plaintiffs”) challenge a Department of Labor regulation that refines how the federal minimum wage applies to tipped employees. The district court denied Plaintiffs a preliminary injunction on the sole ground that they failed to establish irreparable harm from complying with the new rule.   The Fifth Circuit reversed, holding that Plaintiffs sufficiently showed irreparable harm in unrecoverable compliance costs. The court explained that the 30-minute limitation is a new constraint on the tip credit that both requires distinct recordkeeping and affects the existing 20-percent standard. Neither the district court nor the Department explained why this new requirement would not impose new costs. To the contrary, the rule itself confirms that employers who want to continue claiming the tip credit—like Plaintiffs’ members—will “incur ongoing management costs” to ensure employees do not spend more than 30 minutes continuously performing directly supporting work. The court found that the district court abused its discretion in finding no evidence of irreparable harm View "Restaurant Law Center v. LABR" on Justia Law

Plaintiff was a long-term employee of Defendant St. Cecilia Catholic School. In her final year of employment, Defendant worked part-time as an art teacher and office administrator. Following her discharge, Defendant filed this action against St. Cecilia for age discrimination in violation of the California Fair Employment and Housing Act (FEHA) The trial court granted St. Cecilia’s motion for summary judgment on the ground that Plaintiff’s suit was barred by the ministerial exception, a constitutional doctrine that precludes certain employment claims brought against a religious institution by its ministers.   The Second Appellate District reversed the judgment in favor of St. Cecilia and remanded for further proceedings. The court concluded that there are triable issues of material fact as to whether the ministerial exception applies in this case. Further, the court wrote that St. Cecilia did not waive the ministerial exception by failing to assert the defense in its answer. The evidence that Plaintiff promoted “Christ-like” behavior in her class does not establish, as a matter of law, that she performed vital religious duties for St. Cecilia or otherwise qualified as a minister. Because there are triable issues of material fact as to whether the ministerial exception applies to Plaintiff’s former job position as an art teacher and an office administrator, St. Cecilia was not entitled to judgment as a matter of law on Plaintiff’s age discrimination suit. View "Atkins v. St. Cecilia Catholic School" on Justia Law