Justia Labor & Employment Law Opinion Summaries

The case involves a multi-employer pension fund seeking to collect withdrawal liability under the Multiemployer Pension Plan Amendments Act of 1980 from two corporate entities, which the fund alleged were successors to a defunct contributing employer. The companies denied any liability, contending they had never agreed to make contributions to the fund, were not under common control with the original employer, and were not otherwise subject to the fund’s claims. After the fund notified the companies of the alleged liability several years after the original employer ceased operations, the companies sought a declaratory judgment in federal court to clarify that they were not liable. The fund counterclaimed for withdrawal liability, as well as damages and interest.The United States District Court for the District of New Jersey found genuine disputes of material fact regarding whether the companies could be treated as employers under the applicable law, thus precluding summary judgment on that issue. Nevertheless, the District Court granted judgment in favor of the companies on a separate basis: it concluded that the fund’s eight-year delay in providing notice and demanding payment of withdrawal liability failed to meet the statutory requirement under 29 U.S.C. § 1399(b)(1) that such notice be given “as soon as practicable.” The court reasoned that this requirement is an independent statutory element—not an affirmative defense subject to waiver or arbitration—and that the fund’s failure to comply with it barred any recovery.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit held that timely notice and demand is a necessary element for a withdrawal liability claim to accrue under the MPPAA; if the fund fails to act “as soon as practicable,” its claim cannot proceed, regardless of whether the issue is raised in arbitration or by the parties. Arbitration was not required in this circumstance, and the District Court properly resolved the question. View "RTI Restoration Technologies Inc v. International Painters and Allied Trades Industry Pension Fund" on Justia Law

A former participant in a Zen Buddhist center’s residential training programs asserted wage-and-hour claims against the center and two of its leaders, arguing he was owed various wages and penalties for work performed during his time in the center’s programs. The center operates multiple facilities, offers residential programs, and generates income from guest activities and commercial events. The plaintiff undertook tasks such as guesthouse cleaning, kitchen work, gardening, and guest cooking, receiving modest stipends and room and board. After leaving the center, he filed his claims, alleging unpaid minimum and overtime wages and other statutory violations.The Labor Commissioner held in favor of the plaintiff and found the center, as well as the two individual leaders, liable for significant amounts. The center and the individuals appealed to the Superior Court of California, County of San Francisco. The trial court denied the plaintiff’s motion to dismiss the individual appeals on the ground that only the center, not the individuals, was required to post an appeal bond. The trial court subsequently granted summary judgment for the defendants, holding that the “ministerial exception” of the First Amendment barred the plaintiff’s wage-and-hour claims due to the religious nature of the organization and the plaintiff’s role as a minister.On appeal, the California Court of Appeal, First Appellate District, Division Two, reversed the summary judgment. The court held that the ministerial exception does not categorically bar wage-and-hour claims by ministers against religious organizations in the absence of evidence that adjudicating the claims would require resolving ecclesiastical questions or interfere with religious autonomy. The court affirmed the trial court’s denial of the motion to dismiss the individual appeals, holding that only the employer (the center) was required to post the statutory undertaking, not the individual leaders. The judgment was thus reversed in part and affirmed in part. View "Ehrenkranz v. S.F. Zen Center" on Justia Law

The plaintiff, who was in his mid-fifties and had decades of restaurant industry experience, was employed by the defendant as a field leader, overseeing several restaurants. He was recognized as a top performer in 2021, with high scores on cleanliness and safety audits. In early 2022, a severe cockroach infestation was reported at one of his assigned restaurants. The infestation was not previously known to him, and he took steps to address it once notified. However, his supervisor observed persistent pest and cleanliness problems at this and other locations within his responsibility. Additionally, site audits found that several of his restaurants failed to meet cleanliness standards within a single week.After these incidents, the plaintiff was terminated for failing to maintain company food safety standards and for not reporting critical breaches promptly. He received termination documentation and final warnings simultaneously. The plaintiff later sued under the New Mexico Human Rights Act, alleging that his termination was due to age discrimination. The defendant removed the case to the United States District Court for the District of New Mexico, which granted summary judgment for the employer, holding that the plaintiff had not shown sufficient evidence that the stated reasons for his firing were a pretext for age discrimination.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the case de novo. The court held that the plaintiff did not present enough evidence that the employer’s justification was pretextual. The evidence failed to show that younger employees with comparable problems were treated more favorably or that the employer’s stated reasons were false or inconsistent. The court emphasized that it would not second-guess business decisions absent evidence of discrimination. The Tenth Circuit affirmed the district court’s grant of summary judgment in favor of the employer. View "Sousa v. Chipotle Services" on Justia Law

A nurse employed by Puerto Rico’s State Insurance Fund Corporation reported sexual harassment by a coworker in 2020 and subsequently filed an administrative charge of discrimination and retaliation. After dropping her sexual harassment claim, she pursued a retaliation claim, arguing that she endured a hostile work environment and was involuntarily transferred to a different office. The incidents underlying her claim included several allegedly meritless disciplinary actions and the eventual transfer.The United States District Court for the District of Puerto Rico granted a preliminary injunction separating her from the coworker and, after trial, a jury found in her favor on the retaliation claim, awarding $300,000 in damages. The district court later denied her request for a permanent injunction seeking reassignment to her former office and expungement of disciplinary records. The court awarded her approximately $301,000 in attorney fees and costs, but she challenged the amount as insufficient. Finally, although the defendant did not appeal the judgment or fee award, the district court stayed execution of both under Puerto Rico law, pending approval of a payment plan by the Secretary of Justice.The United States Court of Appeals for the First Circuit affirmed the denial of permanent injunctive relief and the attorney fee award, finding that the district court did not abuse its discretion on either point and that the fee reductions and denial of injunctive remedies were reasonable. The Court of Appeals also vacated the stay of execution of judgment and fees, holding that Puerto Rico’s statutory payment plan requirement could not delay enforcement of a federal judgment under Title VII. The case was remanded for further proceedings consistent with these rulings. View "Garcia Colon v. State Insurance Fund Corporation" on Justia Law

Jennifer Neal was employed by the Department of Veterans Affairs (VA) as a Field Examiner until her removal in August 2020 for alleged unacceptable performance. She challenged her removal before the Merit Systems Protection Board (the Board), arguing that the VA violated the terms of a master collective bargaining agreement by failing to provide her with a performance improvement plan (PIP) prior to removal, and that the performance standards applied to her were unreasonable. During the pendency of her appeal, a Federal Labor Relations Authority (FLRA) decision confirmed the requirement for the VA to provide a PIP before removing bargaining unit employees, as established in a prior arbitration. The administrative judge (AJ) found that the VA's removal of Neal was not in accordance with law and set aside the removal.The VA petitioned for review of the AJ’s decision to the full Board, arguing that the FLRA decision was factually and legally distinguishable. While the petition was pending, the VA voluntarily reinstated Neal, provided her back pay, and otherwise made her whole, effectively granting her all the relief she sought. The Board dismissed the VA’s petition as moot, recognizing that Neal had obtained complete relief. Neal then moved for attorneys’ fees. The AJ granted her request, finding her to be the prevailing party. However, upon the VA’s further petition, the Board reversed, reasoning that because the case became moot before a final Board decision, Neal was not a prevailing party and thus not entitled to fees.The United States Court of Appeals for the Federal Circuit reviewed the Board’s decision. The court held that Neal was a prevailing party because the AJ’s merits decision conferred enduring judicial relief that materially altered the legal relationship between the parties, and the subsequent mootness resulting from the VA’s voluntary compliance did not negate her prevailing party status. The court reversed the Board’s denial of attorneys’ fees and awarded costs to Neal. View "NEAL v. DVA " on Justia Law

Two workers filed a putative class action against several contractors and subcontractors, alleging that they performed work on public works projects and were not paid overtime at the prevailing wage rates required by Nevada law. Their lawsuit sought damages equal to the difference between what they were paid and the higher amounts allegedly owed under Nevada’s prevailing-wage statute for both regular and overtime work. The plaintiffs also asserted, in the alternative, that they could recover these amounts under Nevada’s more general wage-and-hour provisions or as third-party beneficiaries of the relevant public works contracts. The complaint did not specify which public works projects were involved or allege that the plaintiffs had pursued administrative remedies through the Nevada Labor Commissioner.The case was first reviewed by the Eighth Judicial District Court in Clark County. The defendants moved to dismiss the complaint on the basis that the plaintiffs had not alleged exhaustion of the administrative remedies required under Nevada’s prevailing-wage law. The district court granted the motion to dismiss, ruling that there was no private right of action for wage claims under the prevailing-wage statute and that the alternative claims were derivative and failed for the same reason. The court also denied the plaintiffs’ motion for leave to amend the complaint, finding that amendment would be futile.On appeal, the Supreme Court of the State of Nevada affirmed the district court’s decision. The court held that NRS Chapter 338, Nevada’s prevailing-wage statute, does not provide a private right of action to employees outside the administrative process it creates. Claims for violation of the statute must first be brought through the administrative mechanisms with the Labor Commissioner, and cannot be circumvented by recasting them under other wage-and-hour laws or as third-party beneficiary claims. The court also found no error in denying leave to amend the complaint. View "STUCKEY VS. APEX MATERIALS, LLC" on Justia Law

Caroline McCall was employed for over twenty years as a Clinical Systems Coordinator at a hospital, where her responsibilities evolved to include inventory management, IT systems, and various administrative tasks. Over time, her duties increased and she began to suffer from bilateral carpal tunnel syndrome, which medical professionals attributed to her intense hand activity at work. Despite undergoing two surgeries and being prescribed specific workplace accommodations, her employer failed to provide some of these adjustments. After her pain worsened and her responsibilities continued to grow, McCall resigned in December 2020, citing physical and mental exhaustion due to her condition.Following her resignation, McCall applied for temporary total disability benefits under the D.C. Workers’ Compensation Act. An Administrative Law Judge (ALJ) found her testimony and the medical evidence credible, determining that her carpal tunnel syndrome was work-related and that she was unable to perform her job due to insufficient accommodations. The ALJ awarded her temporary total disability benefits. The Compensation Review Board (CRB) affirmed the ALJ’s order, agreeing that the correct legal standard was applied and that substantial evidence supported the findings. The employer challenged the CRB’s decision, arguing that the wrong time frame was used to assess her ability to perform her “usual job,” that the findings were not supported by substantial evidence, and that the ALJ failed to address whether McCall voluntarily retired for reasons unrelated to her disability.The District of Columbia Court of Appeals reviewed the case and affirmed the CRB’s decision. The court held that the CRB applied the correct legal standard by considering McCall’s job duties at the time of her resignation, that substantial evidence supported the finding of temporary total disability, and that McCall’s resignation was causally related to her work injury rather than being a voluntary limitation of income for unrelated reasons. View "Howard v. D.C. Department of Employment Services" on Justia Law

The plaintiff was employed as a legal assistant and later a paralegal in a law firm’s Liquor Group, initially at one firm and then at another firm, Adams and Reese, LLP, after her group switched employers. She alleged that a supervisor, who moved with the group, persistently directed sexualized comments and jokes at her in the workplace, which included derogatory remarks, inappropriate suggestions, and comments about her appearance and personal life. She also claimed that after her employer changed her work schedule, she experienced difficulties related to her disabilities and was subsequently terminated when she was unable to comply with the new attendance requirements. She brought claims of sexual harassment and violations of the Americans with Disabilities Act (ADA).The United States District Court for the Middle District of Tennessee reviewed the employer’s motions to dismiss the sexual harassment claim and to compel arbitration of the ADA claims, based on an arbitration agreement between the parties. The district court denied both motions, holding that the plaintiff sufficiently stated a plausible sexual harassment claim under applicable standards and that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) barred enforcement of the arbitration agreement as to her entire case, not just the sexual harassment claim.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s decision. The court held that the plaintiff’s complaint plausibly alleged pervasive sexual harassment sufficient to survive a motion to dismiss. It further determined that the EFAA renders predispute arbitration agreements unenforceable with respect to an entire “case” relating to a sexual harassment dispute, not just the specific sexual harassment claim. Therefore, the arbitration agreement could not be enforced as to any of the plaintiff’s claims in this action. The disposition was to affirm and remand for further proceedings. View "Bruce v. Adams & Reese, LLP" on Justia Law

A former oncology account manager for a pharmaceutical company was terminated after refusing to comply with the company’s COVID-19 vaccination mandate. The employee had worked remotely throughout his tenure, and when the mandate was announced, he sought both medical and religious exemptions. In support of his medical exemption, he submitted a doctor’s note referencing permanent nerve damage from a prior vaccine injury and indicating increased risk from COVID-19 vaccination. The company denied both exemption requests and cited business necessity and client demands for vaccination as the reason for his termination.After receiving authorization from the New Mexico Human Rights Bureau to pursue his claims, the employee filed suit in federal court, alleging discrimination and retaliation under the New Mexico Human Rights Act (NMHRA) due to his medical condition and religion, as well as a claim for common law retaliatory discharge. The United States District Court for the District of New Mexico dismissed most claims without prejudice, concluding he failed to plausibly allege a disability or serious medical condition affecting a major life activity, failed to show a causal link between protected activity and termination, and did not identify a specific public policy violated by his discharge. The court also denied his motion to alter or amend the judgment and declined his request for leave to amend the complaint.The United States Court of Appeals for the Tenth Circuit affirmed. It held that the employee’s complaint did not sufficiently allege a disability or serious medical condition under the NMHRA because it did not identify a major life activity that was substantially limited. The court also found that the complaint failed to establish a causal connection for retaliation and did not identify a specific public policy to support a common law claim. The Tenth Circuit also found no abuse of discretion in denying the motions for reconsideration and amendment. View "Spinelli v. Coherus Biosciences" on Justia Law

A school administrator responsible for special education at a high school in Texas alleged that his employment was terminated in retaliation for reporting incidents of child abuse by teachers under his supervision and for cooperating with a subsequent Child Protective Services (CPS) investigation. He reported the incidents to his principal, participated in a CPS interview, and raised concerns about disciplinary actions and workplace conduct. After additional workplace conflicts and an EEOC complaint, his contract was ultimately terminated by the district’s Board of Trustees following a hearing, and his administrative appeal was unsuccessful.The United States District Court for the Eastern District of Texas reviewed the administrator’s claims, which included constitutional violations under the First and Fourteenth Amendments, retaliation for whistleblowing, and a civil conspiracy to violate his rights. The district court granted the defendants’ motions to dismiss for failure to state a claim, denied leave to amend the complaint, and denied a motion to alter or amend the judgment.On appeal, the United States Court of Appeals for the Fifth Circuit affirmed the district court’s judgment. The Fifth Circuit held that the administrator’s speech—reporting child abuse to his supervisor, participating in the CPS investigation, and refusing to characterize events as his supervisor wished—was made in his official capacity as an employee, not as a citizen, and was therefore not protected by the First Amendment. The court also found that he received appropriate procedural due process related to his termination and did not state a claim for substantive due process. The individual defendants were entitled to qualified immunity, and the civil conspiracy claim failed because there was no underlying constitutional violation. The court also concluded that the district court did not abuse its discretion in declining to take judicial notice of the administrative record and found other claims waived. View "Castille v. Port Arthur Independent School District" on Justia Law