Justia Labor & Employment Law Opinion Summaries

Brownsburg Community School Corporation requires its high school teachers to call all students by the names registered in the school’s official student database. Kluge, a teacher, objected on religious grounds to using the first names of transgender students to the extent that he deemed those names not consistent with their sex recorded at birth. After Brownsburg initially accommodated Kluge’s request to call all students by their last names only, the school withdrew the accommodation when it became apparent that the practice was harming students and negatively impacting the learning environment for transgender students, other students in Kluge’s classes and in the school generally, and the faculty.Kluge brought a Title VII religious discrimination and retaliation suit after he was terminated from his employment. The district court granted the school summary judgment, concluding that the school was unable to accommodate Kluge’s religious beliefs and practices without imposing an undue hardship on the school’s conduct of its business of educating all students and rejected Kluge’s retaliation claim.The Seventh Circuit affirmed. The undisputed evidence demonstrates that Kluge’s accommodation harmed students and disrupted the learning environment. No reasonable jury could conclude that harm to students and disruption to the learning environment are de minimis harms to a school’s conduct of its business. View "Kluge v. Brownsburg Community School Corp." on Justia Law

In 2012, Trahanas began working as a technologist in Dr. Schwulst’s laboratory at Northwestern's School of Medicine. Trahanas claims Schwulst made demeaning remarks about her work, mental health, and sexual orientation and that her lab coworkers harassed her. Trahanas did not report the incidents. Trahanas received positive performance reviews from Schwulst, who recommended Trahanas for raises and promotion.Trahanas had been diagnosed with ADHD, depression, and anxiety and decided to take time off. She did not provide advance notice. On February 16, 2015, Trahanas did not report to work. She later emailed Schwulst. Trahanas was granted 12 weeks of leave under the Family and Medical Leave Act (FMLA), When her leave expired, Northwestern informed Trahanas that failure to return to work or extend her leave would result in termination. She did not extend leave or return to work. Northwestern terminated her employment.Trahanas sued, asserting a hostile work environment under Title VII, 42 U.S.C. 2000e, retaliation under the Americans with Disabilities Act, 42 U.S.C. 12101, and under the FMLA, 29 U.S.C. 2601. The Seventh Circuit affirmed summary judgment in favor of the defendants. Trahanas’s voluntary decision not to return to work or extend leave does not amount to a tangible employment action. The court noted Northwestern’s anti-harassment policy and that Trahanas “unreasonably failed to take advantage of any preventive or corrective opportunities” to avoid harm. Trahanas cannot show that her leave played a motivating factor in Northwestern’s decision to terminate her employment. The court also rejected state law claims. View "Trahanas v. Northwestern University" on Justia Law

Shemran, Inc. (Shemran) appealed the denial of its motion to compel arbitration of a Labor Code Private Attorneys General Act of 2004 (PAGA) action brought by a former employee, Blaine Nickson. The motion was based on Nickson’s agreement to arbitrate all individual claims arising from his employment. At the time of the trial court’s ruling, a predispute agreement to arbitrate PAGA claims was unenforceable under Iskanian v. CLS Transportation Los Angeles, LLC, 59 Cal.4th 348 (2014). But during the pendency of this appeal, the United States Supreme Court decided Viking River Cruises, Inc. v. Moriana, 142 S.Ct. 1906 (2022), holding that the Federal Arbitration Act (FAA) preempted Iskanian in part. The issue before the California Court of Appeal was whether the trial court’s ruling survived Viking River. To this, the Court held it did not: Nickson’s individual PAGA claims are arbitrable. Further, the Court held Nickson's nonindividual PAGA claims should not be dismissed, and remained pending at the superior court. The Court left management of the remainder of the litigation during the pendency of arbitration "to the trial court's sound discretion." View "Nickson v. Shemran, Inc." on Justia Law

The Mine Safety and Health Administration (“MSHA”) is an agency within the Department of Labor whose mission is to administer the provisions of the Federal Mine Safety and Health Act (“Mine Act”). The Mine Act authorizes the Secretary of Labor (“Secretary”), acting through MSHA, to promulgate mandatory safety and health standards, inspect mines, issue citations and orders for violations of the Act or mandatory standards, and propose penalties for those violations. An inspector for MSHA discovered a crane at Westfall operating on-site with no working service brakes. Eight years after the sentence was deemed a final order, and only after MSHA had begun enforcement proceedings against the operator for failing to pay its delinquent penalties, Westfall filed a motion to reopen the matter. A two-member majority of the Commission granted the motion. The DC Circuit granted the Secretary’s petition for review, reversed the Commission’s decision dismissing Westfall’s motion to reopen as moot, and remanded the case for a prompt disposition. The court explained that the Commission’s decision relies on a ground not raised or addressed by the parties, lacks substantial evidence to support its principal findings, and ignores the potential applicability of Federal Rule of Civil Procedure 60(b) covering motions to reopen. View "Secretary of Labor v. Westfall Aggregate & Materials, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court reversing the decision of the workers' compensation commissioner denying the claim filed by the husband of a deceased employee for burial expenses and death benefits as the surviving spouse, holding that the district court did not err.Approximately two and a half years into her marriage Wife left her marital home with Husband, accepted a job in a different city, and moved in with a family friend. Husband and Wife never divorced. Wife was subsequently permanently and totally disabled as a result of a work injury and was awarded workers' compensation benefits. Four years later, Wife died from an overdose. Husband filed a claim for burial expenses and death benefits as the surviving spouse. Employer/Insurer denied the claim. The commissioner upheld the denial, concluding that Husband had willfully deserted Wife without any fault by her and thus was not entitled to benefits under Iowa Code 85.42(1)(a). The district court reversed. The Supreme Court affirmed, holding that there was not substantial evidence to support the commissioner's finding that Husband deserted Wife without fault by her under section 85.42(1)(a). View "Blasdell v. Linnhaven, Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part an order of the court of appeals in this jurisdictional dispute, holding that the Corporate Defendants intentionally reached out to North Carolina to conduct business activities in the state, and the claims at issue in this case arose from or were related to those activities.After Plaintiff was officially terminated from his employment he brought an action against Individual and Corporate Defendants alleging, inter alia, fraud, misrepresentation, and breach of contract. Defendants moved to dismiss the action. The trial court denied the motions. The court of appeals reversed, holding that the Corporate Defendants' activities alone were not sufficient to establish specific jurisdiction and that Plaintiff's claims did not arise out of, or even relate to, the alleged contacts between Defendants and North Carolina. The Supreme Court reversed the court of appeals' decision as to Corporate Defendants, affirmed with respect to Individual Defendants, and remanded, holding that the trial court may exercise personal jurisdiction over Corporate Defendants pursuant to the Due Process Clause. View "Schaeffer v. SingleCare Holdings, LLC" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing this action brought by Academic Labor United (ALU) requesting declaratory judgments that graduate assistants were foreclosed from exercising the collective bargaining rights provided to public employees under Haw. Const. art. XIII, 2 and Haw. Rev. Stat. 89, holding that there was no error.ALU, which represented graduate student employees of the University of Hawaii who wish to engage in collective bargaining, brought this suit arguing that a pair of 1972 decisions of the Hawaii Public Employment Relations Board determined that graduate assistants were not "employees" under chapter 89 and were thus foreclosed from exercising collective bargaining rights. The circuit court dismissed the case on jurisdictional grounds. The Supreme Court affirmed, holding that because ALU had not invoked Hawaii Administrative Rules 12-42-9 to clarify whether its members are employees under chapter 89 and had not exhausted its administrative remedies, the circuit court did not have jurisdiction over ALU's action. View "Academic Labor United v. Bd. of Regents of the University of Haw." on Justia Law

The Commission on Teacher Credentialing (Commission) and its Committee of Credentials (Committee) (collectively, defendants) appealed the grant of mandamus relief to petitioner Russell Earnest, setting aside the Committee’s disciplinary recommendation against him and enjoining the Commission from acting on that recommendation. Defendants argued the trial court erred in finding: (1) Earnest was excused from exhausting his administrative remedies; and (2) the Committee lacked jurisdiction to conduct a formal review pursuant to Education Code1 section 44242.5 (d). They further asserted the trial court should have denied the petition under the doctrine of judicial restraint. In the unpublished portion of the opinion, the Court of Appeal concluded all three factors outlined in Coachella Valley Mosquito & Vector Control Dist. v. California Public Employment Relations Bd., 35 Cal.4th 1072 (2005) weighed in favor of excusing Earnest from exhausting his administrative remedies. In the published portion of the opinion, the Court found that although section 44242.5 (b)(3) generally provided a jurisdictional basis for the Committee to commence initial reviews, as discussed post, the provision was also incorporated in section 44242.5 (d)(3) to provide a jurisdictional basis for the Committee to commence formal reviews. It was this jurisdictional provision the Committee relied upon in commencing a formal review of Earnest’s fitness to hold a credential. The Court thus concluded the plain language of section 44242.5(b)(3) imposed the onus on the employer to determine whether to provide a notifying statement to the Committee, and thus only the employer may determine whether an enumerated action was the “result of an allegation of misconduct,” triggering the Committee’s jurisdiction. Applying that interpretation to the facts of this case, the Court concluded the Committee did not have jurisdiction to commence a formal review of Earnest’s fitness to hold a credential. The grant of mandamus relief was thus affirmed. View "Earnest v. Com. on Teacher Credentialing" on Justia Law

The First Circuit affirmed the decision of the district court entering summary judgment for Defendants on all of Plaintiff's claims in this wrongful termination case, holding that there was no error in the trial court proceedings.Plaintiff, a former police officer, filed a complaint against the town of Lexington, Massachusetts and its retired chief of police, arguing that Defendants denied him due process during the proceedings that led to the termination of his employment and that Defendants intentionally interfered with his efforts to gain employment elsewhere. The district court entered summary judgment for Defendants on all claims. The First Circuit affirmed, holding that there was no material fact in dispute as to whether the reason stated for refusing to hire Plaintiff was pretextual and that there was sufficient evidence from which a reasonable jury could find that Defendants' stated reason for denying him employment was pretextual. View "Mirabella v. Town of Lexington, Mass." on Justia Law

Plaintiffs sought class certification to pursue various claims against the Hilton Hotels Retirement Plan (“Hilton Plan”) for what they say are unlawfully denied vested retirement benefits. The district court ultimately denied certification on the ground that Plaintiffs had proposed an “impermissibly ‘fail-safe’” class—that is, a class definition for which membership can only be ascertained through “a determination of the merits of the case.”   The DC Circuit reversed and remanded the district court’s decision, finding that the district court, in this case, bypassed Rule 23’s requirements and based its denial of class certification entirely on the class’s “fail-safe” character. The court explained that the textual requirements of Rule 23 are fully capable of guarding against unwise uses of the class action mechanism. So the court rejected a rule against “fail-safe” classes as a freestanding bar to class certification ungrounded in Rule 23’s prescribed criteria. Instead, district courts should rely on the carefully calibrated requirements in Rule 23 to guide their class certification decisions and the authority the Rule gives them to deal with curable misarticulations of a proposed class definition. View "In re: Valerie White" on Justia Law