Justia Labor & Employment Law Opinion Summaries

An individual who was the sole owner and employee of a general contracting business applied for workers’ compensation insurance and later suffered a serious injury while working. After the accident, he claimed to have notified his insurance agent of the injury, but the agent testified that he did not recall being notified until much later, after the statutory notice period had expired. The insurer denied the claim, arguing that the owner did not provide timely notice of his injury, as required by the Pennsylvania Workers’ Compensation Act.The matter was first heard by a workers’ compensation judge, who credited the agent’s testimony and found that the owner did not provide notice within 120 days, barring his claim under Section 311 of the Act. On appeal, the Workers’ Compensation Appeal Board reversed, relying on precedent stating that notice to an insurer is not required and that, since the owner was his own employer, notice was instantaneous. The case was remanded for further findings and the owner was ultimately awarded benefits. The insurer appealed, and the Commonwealth Court reversed, holding that Section 311 requires a sole proprietor to provide notice to the insurer within 120 days, distinguishing the case from prior cases involving corporate forms.The Supreme Court of Pennsylvania reviewed the case and concluded that Section 311 does not require a sole owner-employee to notify the insurer of a work-related injury within 120 days to be eligible for compensation. The Court held that the statutory definition of “employer” does not include the insurer for purposes of the notice requirement in Section 311 and found no ambiguity in the statute justifying a contrary reading. The Supreme Court reversed the Commonwealth Court’s decision and remanded the case for further proceedings. View "Erie Insurance Co. v. Heater" on Justia Law

The plaintiff, a general laborer, sued his employer and its owner for violations of the Massachusetts Wage Act, alleging that he was not paid for four weeks of work. He sought damages for lost wages. The defendants denied the allegations and filed counterclaims against the plaintiff for abuse of process and malicious prosecution. In response, the plaintiff filed a special motion to dismiss the counterclaims under the Massachusetts anti-SLAPP statute, claiming the counterclaims were solely based on his act of petitioning the court to recover his wages.A judge in the Waltham Division of the District Court Department initially dismissed the counterclaims, but later reversed that decision after granting the defendants’ motion for reconsideration. The plaintiff then pursued an interlocutory appeal. The Massachusetts Appeals Court reversed the lower court’s decision and ordered the counterclaims dismissed under the anti-SLAPP statute. The Appeals Court subsequently considered the plaintiff’s unopposed petition for appellate attorney’s fees, which used the lodestar method to calculate a request of $67,361.25. Although the Appeals Court found the hours and rates reasonable, it reduced the award by half, reasoning that the fees were disproportionate to the relatively low monetary value of the underlying Wage Act claims.The Supreme Judicial Court of Massachusetts granted further appellate review, limited to the issue of appellate attorney’s fees. The court held that it was an abuse of discretion for the Appeals Court to reduce the fee award based on the value of the underlying Wage Act claims when the reasonableness of the hours and rates for the anti-SLAPP work had already been established. The Supreme Judicial Court therefore reversed the reduction and affirmed an award of $67,361.25 in appellate attorney’s fees for the anti-SLAPP work. View "Hidalgo v. Watch City Construction Corp." on Justia Law

Four employees of the University of Puerto Rico sought to stop the deduction of union dues from their paychecks after the Supreme Court’s decision in Janus v. American Federation of State, County, & Municipal Employees, Council 31, which held that public sector employees could not be compelled to pay union dues without consent. Despite their requests, the University and the union continued to deduct dues for nearly three years. The employees then brought suit against the University’s president and the union, alleging violations of their First Amendment rights and seeking declaratory and injunctive relief, as well as damages.The United States District Court for the District of Puerto Rico largely granted summary judgment to the University president and the union, finding no constitutional violation. However, the court ordered the union to reimburse the employees for dues deducted after their resignations but denied interest and did not grant declaratory or injunctive relief. The court also declined to exercise supplemental jurisdiction over the employees’ Puerto Rico law claims.On appeal, the United States Court of Appeals for the First Circuit was asked only to direct the district court to issue declaratory judgments stating that the past and potential future deductions were unconstitutional. The First Circuit dismissed the appeal as moot. It held that a declaration regarding past conduct would be merely advisory because the deductions had already ceased and a judgment ordering reimbursement was in place. The court also found the request for prospective relief moot, as the University and union had admitted their error, stopped the deductions, and adopted new policies to comply with Janus. The court concluded there was no substantial controversy remaining and that the voluntary cessation doctrine did not apply under these facts. The appeal was therefore dismissed as moot. View "Ramos-Ramos v. Jordan-Conde" on Justia Law

A White police officer employed by the Atlanta Police Department alleged that he was denied a promotion to Captain in December 2014 and was later removed from a flexible work schedule after he reported alleged misconduct by superiors. The officer had previously reported in 2008 that Black supervisors were allegedly treating White officers less favorably, which resulted in tension but was not shown to have been communicated to the ultimate decisionmaker for promotions. In 2015, after reporting possible ticket-fixing by his superiors to internal and federal authorities, the officer was required to work a fixed schedule, which impacted his ability to work a second job and fulfill childcare obligations.The United States District Court for the Northern District of Georgia dismissed or granted summary judgment on most of the officer’s claims, including those under Title VII for racial discrimination and retaliation, and under the Georgia Whistleblower Act. The court found no evidence that the Police Chief, who was the sole decisionmaker for promotions, was aware of the officer’s 2008 discrimination complaint, and further held that the officer had not experienced an adverse employment action as required by the statutes. At trial, the jury found for the City on the Title VII discrimination claim, concluding the officer had not been denied a promotion.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed most of the district court’s rulings, including summary judgment for the City on the Title VII and Whistleblower Act claims and the jury verdict on the discrimination claim. However, the Eleventh Circuit reversed the grant of summary judgment for the Chief and another supervisor on the First Amendment retaliation claim, holding that revoking the officer’s flexible schedule constituted a material adverse action sufficient to support such a claim. The case was remanded for further proceedings on this First Amendment issue. View "Joyner v. City of Atlanta" on Justia Law

The plaintiff was employed as a Change Analyst by a utility company, with responsibilities requiring travel throughout a multi-state service territory. Amid the COVID-19 pandemic in July 2020, the plaintiff took a vacation to Ohio and California and, upon its conclusion, sought to work remotely from outside his designated territory. Although company policy permitted temporary remote work from outside the service area, it required supervisory approval, which the plaintiff had not obtained. When notified by the company’s Human Resources Director that he would be deemed to have resigned unless he immediately returned to his territory, the plaintiff, for the first time, disclosed a preexisting condition and requested a reasonable accommodation to work remotely, citing COVID-19 risks. He provided a brief doctor’s note but did not supply further documentation or assert any reason he could not work remotely from within his service territory. After failing to return or provide sufficient medical documentation, his employment was terminated.The United States District Court for the District of Massachusetts granted summary judgment in favor of the employer on the plaintiff’s claims of retaliation under Massachusetts law and the Family and Medical Leave Act, finding no causal connection between the plaintiff’s protected activity and his termination. The district court determined that the employer had already decided to terminate the plaintiff before he engaged in any protected conduct.Reviewing the case de novo, the United States Court of Appeals for the First Circuit affirmed. The court held that the clear chronological order of events precluded any finding that the plaintiff’s request for accommodation or invocation of FMLA rights caused his termination. The court found that the adverse employment action was determined before the protected activity occurred and that the employer’s actions showed consideration for, rather than retaliation against, the plaintiff’s rights. The grant of summary judgment was affirmed in full. View "Harris v. National Grid USA Service Company, Inc." on Justia Law

Two married tenured professors at California State University, Chico alleged that they were subjected to harassment and discrimination by their department chair, with one professor experiencing conduct targeted at her gender and Korean ancestry. Despite their reports to university administration, the university did not intervene. As a result, one professor suffered serious mental health consequences, leading their doctor to recommend that she not work in the same environment as the chair. The university’s lack of response allegedly forced both professors to resign and accept positions at another university. After their resignation, the university initiated an investigation into one professor for an alleged violation of student privacy laws and communicated these allegations to the new employer, which the professors claimed was intended to sabotage their new employment. There were also alleged delays in transferring their lab equipment.The professors filed suit in the Superior Court of Butte County, asserting, among other claims, retaliation and whistleblower retaliation under California law. The university filed a special motion to strike these two causes of action under California’s anti-SLAPP statute, arguing that the claims were based in part on communications protected by the statute. The trial court denied the motion, finding the university’s actions involved an official proceeding but also concluding that the professors demonstrated a likelihood of prevailing on their claims.The California Court of Appeal, Third Appellate District, reviewed the case and affirmed the trial court’s denial of the anti-SLAPP motion. The appellate court held that the university failed to carry its burden to show that all actions underlying the challenged causes of action were protected activity. The court clarified that the presence of some protected communications within the allegations does not mean the entire cause of action arises from protected activity. The judgment denying the anti-SLAPP motion was therefore affirmed. View "Pechkis v. Trustees of the Cal. State University" on Justia Law

Several former executives and employees of a storage company were terminated or allegedly constructively terminated and subsequently brought claims against the company and its principals for wrongful termination, retaliation, harassment, and related causes of action. The company, in turn, sued two of the former executives, alleging breach of contract and misuse of confidential information, including forwarding company emails to personal accounts. The emails at issue contained communications from the company’s legal counsel and were allegedly attorney-client privileged. After their terminations, the former employees provided these emails to their attorney for use in their lawsuits against the company.The Superior Court of Orange County considered the company’s motions to disqualify the law firm representing the former employees, based on the firm’s possession and use of the disputed emails. The court found the emails were privileged and that the company held the privilege. However, it denied the motions, reasoning that the employees had been intended recipients of the emails, that privileged content would not be used to the company’s disadvantage, and that the emails were central to both parties’ claims.On appeal, the California Court of Appeal, Fourth Appellate District, Division Three, held that the trial court abused its discretion. The appellate court determined that the proper analytical framework for attorney disqualification, as set forth in State Comp. Ins. Fund v. WPS, Inc., should apply not only to inadvertently disclosed privileged material but also to situations where an attorney receives material that was impermissibly taken from the privilege holder without authorization. The appellate court found the trial court erred in its legal analysis, failed to properly apply the relevant standard regarding future prejudice, and made unsupported findings. The court reversed the trial court’s orders and remanded for reconsideration of the disqualification motions under the correct legal standards. View "Guardian Storage Centers v. Simpson" on Justia Law

A former employee brought a class action lawsuit against her former employer, alleging violations of California wage and hour laws and other employment-related statutes. After the complaint was filed, the employer entered into approximately 954 individual settlement agreements with other employees, providing cash payments in exchange for releases of claims. The plaintiff did not sign such an agreement but moved for class certification and later sought to invalidate the individual settlements on the grounds of fraud and coercion, arguing the employer misrepresented the litigation’s status and the scope of the settlements.The Superior Court of San Bernardino County partially granted the motion, ruling that the individual settlement agreements were voidable due to fraud or duress and ordered that a curative notice be sent to affected employees. The court’s notice advised that employees could rescind their agreements and join the class action, but did not require immediate repayment of settlement funds to the employer. The employer objected, arguing the notice should have informed employees that they might be required to return the settlement money if they rescinded and the employer ultimately prevailed in the litigation. The trial court declined to include this language, instead following certain federal cases that allowed offsetting the settlement amount against any recovery but did not require repayment before judgment.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case on a writ. The court held that under California Civil Code sections 1689, 1691, and 1693, employees who rescind their settlement agreements may be required to repay the consideration they received, but repayment can be delayed until final judgment unless the employer shows substantial prejudice from delay. The court also found the trial court retains equitable authority to adjust repayment at judgment under section 1692. The appellate court directed the trial court to reconsider the curative notice in accordance with these principles. Each side was ordered to bear their own costs on appeal. View "The Merchant of Tennis, Inc. v. Superior Court" on Justia Law

Energy Harbor Nuclear Corporation operated a power plant in Pennsylvania, where its employees were represented by the International Brotherhood of Electrical Workers, Local 29. After a 2021 dispute over health care benefit contributions, an arbitrator found that Energy Harbor had underpaid and ordered it to make additional contributions for 2021. Later, the parties entered into a new collective-bargaining agreement (CBA) on October 1, 2021, which included a broad arbitration clause and a merger clause voiding prior agreements not incorporated into the new CBA. When the union later alleged that Energy Harbor similarly underpaid contributions for 2022, it filed a grievance, contending that Energy Harbor failed to adjust 2022 contributions as required by the prior arbitration award.The United States District Court for the Western District of Pennsylvania reviewed the matter after the union sought to compel arbitration. The District Court, adopting a magistrate judge’s recommendation, held that the broad arbitration clause in the new CBA covered the dispute regarding the 2022 contributions. The court reasoned that because the grievance referenced the contribution-increase provision of the CBA, the dispute was subject to arbitration, and found no evidence that the parties intended to exclude such claims from arbitration.On appeal, the United States Court of Appeals for the Third Circuit reversed. The Third Circuit held that, although the arbitration clause was broad, the union’s grievance regarding 2022 contributions did not arise under the new CBA but instead relied on the prior arbitration award, which was not incorporated into the new agreement. The court concluded that the dispute had “nothing to do with” the rights under the CBA because there was no evidence of a required increase in Energy Harbor’s health care plan costs from 2021 to 2022. The Third Circuit reversed and remanded with instructions to grant summary judgment for Energy Harbor. View "International Brotherhood of Electrical Workers Local Union 29 v. Energy Harbor Nuclear Corp" on Justia Law

On the evening of October 2, 2024, an employee was jogging in the parking lot of a Walmart distribution center when he was struck by a tractor-trailer driven by another Walmart employee who was performing his job duties. Both individuals were employed by Walmart at the time of the incident. The injured employee subsequently filed suit against Walmart and the co-employee, seeking damages under various tort theories, including negligence, wantonness, and co-employee liability.The case was first heard in the Pike Circuit Court. Walmart responded to the complaint by raising the defense that the employee’s claims were barred by the exclusive-remedy provisions of Alabama’s Workers’ Compensation Act, as the injured employee had already accepted workers’ compensation and medical benefits for the incident, while represented by counsel, and had not reserved any right to pursue other remedies. The trial court granted summary judgment in favor of Walmart and the co-employee, finding the acceptance of workers’ compensation benefits estopped the employee from pursuing additional remedies and that there was no evidence of willful conduct by the co-employee.On appeal, the Supreme Court of Alabama reviewed the trial court’s decision de novo. The Supreme Court affirmed the summary judgment, holding that the employee’s acceptance of workers’ compensation benefits constituted an election of remedies that precluded him from seeking damages through a civil tort action against Walmart. The Court also held that, under Alabama law, co-employees are immune from civil liability except in cases of willful conduct, and the plaintiff failed to present substantial evidence of willful conduct by the co-employee. Thus, the Supreme Court affirmed the trial court’s summary judgment in favor of both Walmart and the co-employee. View "Duke v. Walmart, Inc." on Justia Law