Justia Labor & Employment Law Opinion Summaries

An employee at a quarry died after falling through an unsecured catwalk gate into dangerous machinery. The machinery, used for processing lime, was typically secured by metal linchpins, but at the time of the accident, the gate was fastened only with a metal wire instead of the pins. The worker’s family brought suit against two of his co-employees, a supervisor and a safety director, alleging gross negligence for failing to prevent the accident. Both defendants testified that they did not know the securing pins were missing, and there had been no prior similar accidents since safety rails were installed decades earlier.After a jury trial in the Iowa District Court for Benton County, the plaintiffs were awarded damages totaling approximately $2.84 million. The district court denied the defendants’ post-trial motions. On appeal, the Iowa Court of Appeals affirmed, reasoning that the evidence supported the conclusion that injury was probable under the circumstances, and relied in part on what the defendants should have known.The Supreme Court of Iowa reviewed the case and determined that, under Iowa law, recovery for co-employee gross negligence requires proof that the defendants had actual knowledge of the specific peril—the missing pins that left the gate unsecured. The court found that there was no evidence either defendant actually knew about the missing pins or unsecured gate. As a result, the legal standard for gross negligence was not met. The Supreme Court of Iowa vacated the decision of the court of appeals, reversed the judgment of the district court, and remanded the case for dismissal, holding that the plaintiffs’ exclusive remedy was under the state’s workers’ compensation statute. View "Griffith v. Kulper" on Justia Law

Andrew Sangster, on behalf of a class of flight instructors, filed suit against the University of North Dakota alleging that instructors were not paid for all hours worked. Sangster claimed the university compensated instructors only for student contact hours and excluded other work-related tasks such as scheduling, pre- and post-flight procedures, recordkeeping, and waiting at the airport. He sought damages for violations of the Fair Labor Standards Act (FLSA), North Dakota wage laws, unjust enrichment, and conversion.The District Court for Cass County reviewed the university’s motion to dismiss, which argued the court lacked jurisdiction because Sangster failed to give timely notice to the Office of Management and Budget as required by North Dakota law. Sangster admitted he had not provided this notice but contended his claims were contractual and thus exempt from the notice requirement. The district court denied the motion to dismiss with respect to the FLSA, state wage law, and unjust enrichment claims, finding them contractual in nature. The conversion claim was dismissed because Sangster conceded the notice requirement applied.The Supreme Court of the State of North Dakota subsequently reviewed the district court’s decision upon the University’s petition for a supervisory writ. The Supreme Court exercised its discretionary supervisory jurisdiction, holding that Sangster’s claims for relief under the FLSA, North Dakota wage laws, and unjust enrichment were not contractual in nature and therefore not authorized by N.D.C.C. ch. 32-12. The Supreme Court concluded that because Sangster had not complied with the statutory notice requirements for noncontractual claims, the district court lacked subject matter jurisdiction. The court granted the supervisory writ and directed the district court to dismiss Sangster’s case for lack of jurisdiction. View "UND v. Whelan" on Justia Law

Several health care facilities and their affiliates faced administrative complaints from the General Counsel of the National Labor Relations Board (NLRB) in 2012 for alleged unfair labor practices. The proceedings were assigned to Administrative Law Judge (ALJ) Kenneth Chu, who developed the factual record over multiple hearings. During this period, the Supreme Court’s decision in NLRB v. Noel Canning invalidated certain NLRB Board appointments, calling into question ALJ Chu’s own appointment. The Board later “ratified” prior actions, including Chu’s appointment, after regaining a lawful quorum. Administrative proceedings were delayed for several years due to interlocutory appeals and COVID-19, and ultimately resumed in 2023. Shortly before resumption, the plaintiffs sought to halt the proceedings, arguing the ALJ was unlawfully appointed and protected from removal in a manner unconstitutional under the separation of powers.The plaintiffs initially sought relief in the United States District Court for the District of New Jersey, which denied a temporary restraining order and transferred the case to the United States District Court for the District of Connecticut. There, the plaintiffs moved for a preliminary injunction, again raising constitutional arguments regarding the ALJ’s appointment and removal protections. The District of Connecticut denied the injunction, finding the plaintiffs had not shown a clear likelihood of success on the merits. Proceedings before ALJ Chu concluded in May 2024, after which Chu retired and the NLRB Board assumed de novo review of the case.The United States Court of Appeals for the Second Circuit reviewed the appeal. It assumed jurisdiction but declined to address the likelihood of success on the merits, instead affirming the district court’s denial of a preliminary injunction on the ground that the plaintiffs could not demonstrate irreparable harm. The court held that, because all proceedings before the challenged ALJ had concluded and the Board (now lawfully constituted) would conduct de novo review, there was no risk of irreparable injury warranting injunctive relief. The order was affirmed. View "Care One, LLC v. NLRB" on Justia Law

Janet Duke, after retiring from Luxottica U.S. Holdings Corp., elected to receive pension benefits through a joint and survivor annuity (JSA), calculated using actuarial assumptions set by her employer’s defined benefit pension plan. Duke alleged that her plan used outdated assumptions—specifically, a 7% interest rate and life expectancy tables from 1971—to convert single life annuities (SLA) into JSA benefits, resulting in lower monthly payments for her and similarly situated retirees. She claimed this systematic practice violated ERISA’s requirements for actuarial equivalence and compliance, thereby potentially harming the plan’s participants and the plan itself.In the United States District Court for the Eastern District of New York, Duke filed a putative class action seeking relief under ERISA Sections 502(a)(2) and 502(a)(3), including plan reformation and monetary repayments to the plan. The district court initially found Duke lacked standing for Section 502(a)(2) claims but later reversed itself and held that she did have standing for both plan reformation and monetary payments. The court compelled individual arbitration of her Section 502(a)(3) claims under a dispute resolution agreement but held that the “effective vindication” doctrine prevented mandatory arbitration of her Section 502(a)(2) claims. Defendants’ motion for a mandatory stay of litigation pending arbitration was denied.The United States Court of Appeals for the Second Circuit reviewed the district court’s rulings. It held that Duke has Article III standing to pursue plan reformation under Section 502(a)(2) because her alleged injury—reduced benefits due to outdated assumptions—could be redressed by reformation of the plan. However, Duke lacks standing to seek monetary payments to the plan, as such relief would not redress any personal injury she suffered. The Second Circuit also held that the effective vindication doctrine precludes mandatory individual arbitration of her Section 502(a)(2) claim and affirmed the district court’s discretionary denial of a mandatory stay. The order was affirmed in part and reversed in part. View "Duke v. Luxottica U.S. Holdings Corp." on Justia Law

An employee of a New York City tour company was terminated in 2012, allegedly for attempting to unionize. The National Labor Relations Board (NLRB) began investigating the termination, and in 2013, its adjudicative body found the discharge violated the National Labor Relations Act (NLRA), ordering the company to reinstate the employee and compensate him for lost earnings. After a brief reinstatement and a second termination, further proceedings led to a backpay judgment against the company and several affiliates, including some of the current appellants. When the judgment debtors failed to pay, the NLRB issued administrative subpoenas seeking documents to determine whether the appellants could be held liable for the judgment. The appellants did not comply with these subpoenas.The United States District Court for the Southern District of New York reviewed the NLRB’s application to enforce the subpoenas. The court rejected the appellants’ arguments concerning lack of subject-matter jurisdiction, personal jurisdiction, and improper venue, holding that the NLRA authorized nationwide service of process and that the inquiry was conducted in the Southern District of New York. The court denied the appellants’ motion to transfer the case to the Southern District of Texas and awarded attorneys’ fees and costs to the NLRB, later specifying the amount.The United States Court of Appeals for the Second Circuit found that the district court had subject-matter and personal jurisdiction to enforce the subpoenas, and that venue was proper. It held that the district court did not abuse its discretion by refusing to transfer the case or by awarding fees and costs based on the appellants’ repeated evasion of service and failure to comply. However, the appellate court lacked jurisdiction to review the district court’s subsequent order fixing the amount of fees and costs, as no timely notice of appeal was filed for that order. The judgment was thus affirmed in part and dismissed in part. View "Nat'l Lab. Rels. Bd. v. Universal Smart Conts., LLC" on Justia Law

Harvard Maintenance, a janitorial contractor in New York City, employed Carina Cruz as a cleaner. Cruz raised several complaints alleging violations of the collective bargaining agreement, including assignment of certain cleaning tasks and concerns about working conditions. In response to her complaints, Cruz faced threats from supervisors, was suspended following workplace disputes, and ultimately terminated in June 2020. Cruz filed a complaint with the National Labor Relations Board (NLRB), claiming her suspension and termination were unlawful reprisals for protected union activity.An administrative law judge (ALJ) for the NLRB found that Harvard Maintenance unlawfully threatened, suspended, and fired Cruz in violation of the National Labor Relations Act (NLRA) and ordered remedies including backpay, reimbursement for job search expenses, and compensation for “direct or foreseeable pecuniary harms.” The NLRB adopted the ALJ’s findings and order. Harvard Maintenance petitioned for review with the United States Court of Appeals for the Fifth Circuit, challenging the findings of coercive statements, unlawful discharge, and the scope of the awarded remedies.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the NLRB’s findings regarding coercive statements and unlawful discharge were supported by substantial evidence and affirmed those parts of the Board’s order. However, the Fifth Circuit concluded that the award of consequential damages for “direct or foreseeable pecuniary harms” exceeded the NLRB’s statutory authority under the NLRA, which permits only equitable remedies. Therefore, the court denied Harvard Maintenance’s petition for review as to the findings of unlawful conduct, but granted relief and vacated the portion of the order awarding consequential damages. The Board’s application for enforcement was granted except as to the consequential damages remedy. View "Harvard Maintenance v. National Labor Relations Board" on Justia Law

A prospective employee, Fuentes, applied for work at Empire Nissan and signed an “Applicant Statement and Agreement” that included a mandatory arbitration provision. The document was printed in an extremely small, blurry font that was nearly unreadable and contained a lengthy, complex paragraph filled with legal jargon and statutory references. Fuentes was given only five minutes to review the entire employment packet, was not offered an opportunity to ask questions, and did not receive a copy. Later, she signed two confidentiality agreements that appeared to allow Empire Nissan to seek judicial remedies, not mentioning arbitration. After working at Empire Nissan for over two years, Fuentes was terminated following a request for extended medical leave and subsequently sued the company for wrongful discharge and related claims.Empire Nissan moved to compel arbitration. The Los Angeles County Superior Court denied the motion, finding the arbitration agreement unconscionable due to its illegibility, complexity, and the lack of a meaningful opportunity for review or negotiation, establishing a high degree of procedural unconscionability and a low to moderate degree of substantive unconscionability. The court also found that the confidentiality agreements appeared to carve out certain claims from arbitration for Empire Nissan. The Second District Court of Appeal reversed, holding that “tiny and unreadable print” concerns procedural unconscionability only—not substantive—and, interpreting the agreements as requiring arbitration, found no substantive unconscionability and declined to address procedural unconscionability.The Supreme Court of California reviewed the case and held that a contract’s format, such as illegibility, is generally irrelevant to substantive unconscionability, which concerns the fairness of the contract’s terms. However, courts must more closely scrutinize the terms of contracts that are difficult to read for unfairness or one-sidedness when there is high procedural unconscionability. The Court reversed the Court of Appeal’s judgment and remanded the matter to the trial court for further proceedings consistent with its clarified standards. View "Fuentes v. Empire Nissan" on Justia Law

Carl Kleinfeldt was a longtime employee who participated in his employer’s retirement plan. He originally designated his wife, Dená Langdon, as the primary beneficiary and his sisters as contingent beneficiaries. After divorcing Langdon in September 2022, Kleinfeldt sent a fax to his employer’s benefits center requesting that Langdon be removed as beneficiary from his retirement accounts. Although the employer updated Langdon’s status from “spouse” to “ex-spouse,” she remained listed as the primary beneficiary at the time of Kleinfeldt’s death in January 2023.Following Kleinfeldt’s death, the employer planned to distribute the retirement account funds to Langdon. Both Langdon and Kleinfeldt’s estate submitted competing claims to the employer, which denied the estate's claim but allowed an appeal. When conflicting claims persisted, the employer filed an interpleader action in the United States District Court for the Western District of Wisconsin and deposited the funds with the court. During litigation, the district court determined that Kleinfeldt’s sister, Terry Scholz, also had a potential claim as a surviving contingent beneficiary and joined her estate as a necessary party. After cross-motions for summary judgment, the district court denied both and instead granted summary judgment sua sponte to Scholz’s estate, finding that Kleinfeldt had substantially complied with the plan’s requirements to remove Langdon as beneficiary.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s summary judgment de novo. The appellate court held that Kleinfeldt did not meet the requirements of substantial compliance because he failed to follow the plan’s specified procedures for changing a beneficiary, which required contacting the benefits center or updating beneficiaries online—not simply sending a fax. The Seventh Circuit reversed the district court’s judgment and remanded with instructions to enter judgment in favor of Langdon as the primary beneficiary. View "Packaging Corporation of America Thrift Plan for Hourly Employees v. Langdon" on Justia Law

Benjamin Zarn, a Forensic Support Specialist employed at a state-run treatment center, challenged workplace Covid-19 protocols implemented by the Minnesota Department of Human Services (MDHS). In 2021, MDHS adopted policies requiring employees who did not telework to provide proof of Covid-19 vaccination or undergo weekly testing. Additionally, vaccinated employees who tested positive for Covid-19 could receive up to seven days of paid administrative leave if they exhausted their sick leave. Zarn objected to the vaccine and testing requirements on religious and moral grounds, citing his Catholic beliefs and concerns about the use of fetal cells in vaccines. Despite his objections, Zarn complied with the testing policy but claimed he did so under duress, fearing job loss. Although Zarn expressed dissatisfaction with the policies to his supervisor, union president, and administrators, he did not formally request a religious accommodation.Zarn filed charges with the Equal Employment Opportunity Commission (EEOC), alleging religious discrimination under Title VII and violations of the Americans with Disabilities Act (ADA). After receiving right-to-sue letters, he sued MDHS in the United States District Court for the District of Minnesota, also alleging violations of the Minnesota Human Rights Act and the Minnesota Refusal of Treatment statute. The district court dismissed the state law claims for lack of jurisdiction and failure to state a claim, and then granted summary judgment to MDHS on the federal claims, finding that Zarn failed to exhaust administrative remedies for some claims and did not notify MDHS of a religious conflict or suffer an adverse employment action.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo. The appellate court affirmed the district court’s judgment, holding that Zarn failed to exhaust administrative remedies regarding the Covid Pay Policy, did not notify MDHS of a religious conflict as required to establish a prima facie Title VII failure-to-accommodate claim, and that the Covid testing requirement did not violate the ADA because it was job-related and consistent with business necessity. View "Zarn v. Minn. Dept. of Human Services" on Justia Law

Samuel Perez filed a lawsuit in 2022 against By the Rockies, LLC, alleging that during his employment in 2016 and 2017, he and other employees were denied required meal and rest breaks, in violation of Colorado’s Minimum Wage Act. Perez sought recovery for unpaid wages based on these alleged violations. By the Rockies moved to dismiss the claim as untimely, arguing that the applicable statute of limitations was two years, as set forth in the Colorado Wage Claim Act, while Perez contended that the general six-year limitations period for actions to recover a liquidated debt should apply, since the Minimum Wage Act itself does not specify a limitations period.The District Court for Larimer County agreed with By the Rockies and dismissed Perez’s complaint, applying the Wage Claim Act’s two-year statute of limitations. Perez appealed, and a divided panel of the Colorado Court of Appeals reversed the dismissal. The majority held that the six-year limitations period in section 13-80-103.5(1)(a) applied, reasoning that the Wage Claim Act’s limitations period was restricted to claims brought specifically under that Act, not under the Minimum Wage Act. The dissent argued that the Wage Claim Act’s limitations period was more specific and appropriate in light of the overall statutory scheme governing wage claims in Colorado.The Supreme Court of Colorado granted certiorari to resolve which limitations period applies to claims under the Minimum Wage Act. The Court held that the two-year limitations period set forth in the Wage Claim Act governs such claims, reasoning that both Acts are part of a comprehensive statutory scheme addressing unpaid wages and that the Wage Claim Act is more specific to wage disputes than the general limitations provision. The Supreme Court of Colorado reversed the judgment of the Court of Appeals and remanded the case with instructions to reinstate the district court’s order of dismissal. View "By the Rockies, LLC v. Perez" on Justia Law