Justia Labor & Employment Law Opinion Summaries

A firefighter employed by a county for over two decades reported safety violations concerning the maintenance of fire extinguishers on county fire engines. After raising these concerns with his superiors, he was barred from working in fire prevention, which he believed was retaliation for his whistleblowing activities. Although he filed internal complaints with the county’s Office of Human Resources and the Civil Service Commission, he withdrew his appeal after assurances that his concerns would be addressed. Later, he was investigated for alleged misconduct and ultimately terminated for violations of county rules. He then filed a claim under the Government Claims Act, which the county rejected.The Superior Court of Kern County granted the county’s motion for judgment on the pleadings, finding that the plaintiff’s failure to exhaust the internal administrative remedies—specifically, by not appealing his dismissal to the Civil Service Commission—barred his whistleblower retaliation lawsuit. The court denied the plaintiff’s request for leave to amend his complaint, holding that he could not allege exhaustion of remedies.The Court of Appeal of the State of California, Fifth Appellate District, reviewed the case. It held that the plaintiff was not required to exhaust the county’s internal administrative remedies before bringing his whistleblower retaliation claims because the county’s ordinances and rules did not provide a clearly defined process for submitting, evaluating, and resolving such claims. The court distinguished between general disciplinary appeals and procedures for discrimination or harassment claims, noting that there was no specific administrative remedy for whistleblower retaliation. Consequently, the appellate court reversed the judgment and remanded the matter with instructions to deny the county’s motion for judgment on the pleadings. The holding clarifies that, where an internal administrative process does not address a particular type of claim, exhaustion of that process is not required before filing suit. View "Romero v. County of Kern" on Justia Law

Several participants in a terminated employee stock ownership plan asserted claims under the Employee Retirement Income Security Act (ERISA) following the sale and dissolution of their plan. The plan, created by A360, Inc. in 2016, purchased all company stock and became its sole owner. In 2019, A360 and its trustee sold the plan’s shares to another entity, amending the plan at the same time to include an arbitration clause that required all claims to be resolved individually and prohibited representative, class, or group relief. The plan was terminated shortly thereafter, and the proceeds were distributed to participants. The plaintiffs alleged that the defendants undervalued the shares and breached fiduciary duties, seeking plan-wide monetary and equitable relief.The United States District Court for the Northern District of Georgia considered the defendants’ motion to compel arbitration based on the plan’s amended arbitration provisions. The district court determined that although the plan itself could assent to arbitration, the arbitration provision was unenforceable because it precluded plan-wide relief authorized by ERISA. The court found that the provision constituted a prospective waiver of statutory rights and concluded that, per the plan amendment’s own terms, the arbitration provision was not severable and thus entirely void.The United States Court of Appeals for the Eleventh Circuit reviewed the district court’s denial of the motion to compel arbitration de novo. The Eleventh Circuit held that the arbitration provision was unenforceable under the effective vindication doctrine because it barred participants from seeking plan-wide relief for breaches of fiduciary duty, as provided by ERISA. The court joined other circuits in concluding that such provisions violate ERISA’s substantive rights and affirmed the district court’s invalidation of the arbitration procedure and denial of the motion to compel arbitration. View "Williams v. Shapiro" on Justia Law

Manuel Contreras worked for Green Thumb Produce, Inc., primarily in the sanitation department, and became aware that he was earning less than other employees performing similar duties, some with less seniority. He repeatedly raised the pay disparity with management, but no action was taken. After consulting with the Labor Commissioner’s Office and reviewing a FAQ about the California Equal Pay Act (EPA), Contreras believed his employer was violating equal pay laws and presented these concerns, along with the FAQ, to human resources. Shortly thereafter, he was terminated, with Green Thumb citing violations of company policy.Contreras filed suit in the Superior Court of Riverside County, asserting three causes of action, including a claim under Labor Code section 1102.5(b) for whistleblower retaliation. At trial, the jury found in Contreras’s favor on all claims and awarded damages. Green Thumb moved for partial judgment notwithstanding the verdict (JNOV) on the whistleblower claim, arguing Contreras’s misunderstanding of the EPA—specifically, that he did not believe his pay disparity was based on sex, race, or ethnicity—was an unreasonable basis for a claim under section 1102.5(b). The Superior Court granted the JNOV motion, reasoning that Contreras’s belief did not relate to a violation of law.On appeal to the California Court of Appeal, Fourth Appellate District, Division One, the court addressed whether Contreras’s mistaken interpretation of the EPA defeated his whistleblower retaliation claim. The appellate court held that section 1102.5(b) requires only that an employee have an objectively reasonable belief that a violation of law occurred, not that the belief be legally correct. The court found that substantial evidence supported the jury’s conclusion that Contreras reasonably believed Green Thumb violated the EPA based on his consultation with the Labor Commissioner and the potentially misleading FAQ. The appellate court reversed the trial court’s JNOV ruling and instructed it to amend the judgment consistent with the jury’s verdict. View "Contreras v. Green Thumb Produce Inc." on Justia Law

A registered nurse who worked for the Indian Health Service during the COVID-19 pandemic claimed that she and similarly situated nurses were required by supervisors to work overtime without compensation. After resigning, she filed a class action lawsuit in the United States Court of Federal Claims, alleging, among other things, that the government violated the federal overtime statute by failing to pay for overtime that was allegedly induced by supervisors. Specifically, she argued that the statutory requirement for overtime to be “officially ordered or approved” should cover such induced overtime, even in the absence of written authorization.The United States Court of Federal Claims dismissed all counts of her complaint for failure to state a claim. With respect to the overtime claim (Count II), the court found that she did not allege that she or any potential class members had written authorization for their overtime, as required by the relevant Office of Personnel Management (OPM) regulation.On appeal, the United States Court of Appeals for the Federal Circuit, sitting en banc, reviewed the validity of the OPM’s regulation that requires overtime orders or approvals to be in writing, in light of the statutory language and recent Supreme Court precedent on agency rulemaking authority. The court held that the statute delegates to OPM the authority to prescribe necessary regulations for administering the overtime pay statute, and that this includes the discretion to require written authorization as part of the “officially ordered or approved” process. The court concluded that the writing requirement is a valid exercise of OPM’s rulemaking authority and does not contradict the statute. The Federal Circuit therefore affirmed the Court of Federal Claims’ dismissal of the overtime claim and remanded the remaining claims to the original panel for further consideration. View "Lesko v. United States" on Justia Law

A Black woman who had worked for a community college for nearly two decades applied for a promotion to Assistant Dean of Workforce Solutions after serving as Director of Special Populations. The position required significant experience in workforce development, including knowledge of specific funding and grant-writing. The applicant pool included her and a Hispanic male colleague who had overseen larger programs and had more direct experience with the job’s requirements. A search committee interviewed candidates, with the final hiring decision made by the Vice President of Enrollment and Outreach Initiatives.The United States District Court for the District of Maryland initially dismissed her claims of race and gender discrimination under Title VII. On appeal, the United States Court of Appeals for the Fourth Circuit reversed and remanded in part, allowing her to pursue a disparate treatment claim focused on the college’s failure to promote her and its issuance of a corrective action letter for a payroll error. Following discovery, the district court granted summary judgment for the college, finding that the plaintiff did not present sufficient evidence of intentional discrimination, and that the employer’s stated reason—selecting the more qualified candidate—was not shown to be pretextual.Reviewing the case de novo, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s grant of summary judgment. The court assumed that the plaintiff established a prima facie case of discrimination but held that she did not meet her burden to show the employer’s justification was pretext. The court found that the selected candidate’s qualifications aligned more closely with the position, and that neither evidence of preselection, circumstantial evidence of discriminatory comments, nor disparate discipline sufficed to demonstrate intentional discrimination or pretext. The court thus affirmed the judgment in favor of the college. View "Hood-Wilson v. Board of Trustees, Community College of Baltimore" on Justia Law

An individual employed as a law enforcement officer by a county sheriff’s office regularly took advantage of a policy allowing approved off-duty work to supplement his income. When a construction company contracted with the state to repair bridges and overpasses, the contract required the company to use uniformed law enforcement officers to manage traffic. The sheriff’s office coordinated which officers would staff these off-duty positions, managed their assignments, collected timesheets, and required that officers be paid directly by the company. On one such off-duty assignment, the officer was injured by a vehicle while directing traffic and sought workers’ compensation benefits, claiming both the sheriff’s office and the construction company as employers.The officer filed a claim with the North Carolina Industrial Commission, which determined that he was employed solely by the sheriff’s office, not by the construction company. This decision was affirmed by the Full Commission. On appeal, the North Carolina Court of Appeals agreed the officer was not an independent contractor, but determined that the construction company was liable as a joint employer under the joint employment doctrine.The Supreme Court of North Carolina, upon discretionary review, clarified the distinction between the joint employment and lent employee doctrines. Applying the joint employment doctrine, the Court found that while there was an implied contract for hire between the officer and the construction company, the company did not exercise sufficient control over the details of the officer’s work to qualify as a joint employer. The Court held that the sheriff’s office was the officer’s sole employer for workers’ compensation purposes and reversed the Court of Appeals’ determination that the construction company was a joint employer. View "Lassiter v. Robeson Cnty. Sheriff's Dep't" on Justia Law

Several former employees of a logistics company left their positions and later joined a competitor. The former employer alleged that, as a condition of their employment, these individuals had signed agreements containing restrictive covenants, including broad non-solicitation and business interference clauses. The company claimed the employees breached these restrictive covenants and further alleged that the competitor had tortiously interfered with its contractual relationships.Initially, the United States District Court for the District of Minnesota granted summary judgment for the defendants, holding that the agreements were unenforceable under California law, and thus the breach of contract and tortious interference claims failed. On the first appeal, the Eighth Circuit determined that Minnesota law rather than California law governed the agreements for all but one employee, remanding the case to the district court to reconsider the enforceability of the contracts under Minnesota law and to resolve related summary judgment motions. On remand, the district court again granted summary judgment to the defendants, holding the restrictive covenants were overly broad and unenforceable under Minnesota law, and denied the plaintiff’s motion for voluntary dismissal of certain claims.On appeal, the United States Court of Appeals for the Eighth Circuit held that the restrictive covenants in the agreements are unenforceable under Minnesota law, as they sweep more broadly than necessary to protect the former employer’s business interests, both in scope and geographic reach. The Eighth Circuit also affirmed the district court’s denial of voluntary dismissal, finding it would waste judicial resources and could prejudice the affected employee. The Eighth Circuit affirmed the district court's grant of summary judgment for the defendants, denial of the plaintiff’s summary judgment motion, and denial of the plaintiff’s motion for voluntary dismissal. View "C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc." on Justia Law

The plaintiff, who worked as a truck driver for the defendants for approximately nine months in 2018, brought claims alleging that the defendants failed to provide required meal and rest breaks, failed to reimburse necessary work-related expenses, and violated California’s unfair competition law. The plaintiff also filed a representative claim for civil penalties under the Labor Code Private Attorneys General Act of 2004 (PAGA), all arising from his employment as a driver.The Superior Court of Sutter County denied the plaintiff’s motion for class certification on the meal break, rest break, expense reimbursement, and unfair competition claims. In particular, the court found that the plaintiff failed to present substantial evidence of a common policy of discouraging breaks or of a community of interest among the proposed class members. The court relied on declarations from other drivers indicating they were not discouraged from taking breaks and noting variability in their experiences. The court also granted the defendants’ motion to strike the PAGA claim on manageability grounds, reasoning that adjudicating the claim would require individual testimony from 75 drivers and would be unmanageable.The California Court of Appeal, Third Appellate District, affirmed in part and reversed in part. It affirmed the denial of class certification for the rest break and expense reimbursement claims, finding insufficient evidence of commonality. However, it reversed the denial of class certification for the meal break and derivative unfair competition claims, holding that the trial court failed to apply the burden-shifting framework required by Donohue v. AMN Services, LLC when time records show missed or unrecorded meal breaks. Additionally, the appellate court reversed the order striking the PAGA claim, holding that trial courts lack inherent authority to strike PAGA claims solely based on manageability concerns, as clarified in Estrada v. Royalty Carpet Mills, Inc. The case was remanded for further proceedings, including consideration of whether the PAGA claim is preempted by federal law. View "Dieves v. Butte Sand Trucking Co." on Justia Law

A female senior administrator at a Mississippi public university, who had served as Vice President and Chief of Staff since 2017, alleged that she was not hired for the position of university president on two occasions, in 2020 and 2023, despite her extensive qualifications and expressed interest. In 2020, following the resignation of the then-president, the university’s governing board appointed a less-experienced male interim president without conducting a search or soliciting applications, even though the plaintiff had managed university affairs in the president’s absence. After the interim president was placed on administrative leave in 2023, the board began a new search. The plaintiff applied but was denied an interview; instead, the board selected another male candidate with less experience, who had not applied for the position.The plaintiff filed suit against the board members in their individual capacities, alleging sex discrimination under the Equal Protection Clause via 42 U.S.C. § 1983, as well as Title VII claims. The United States District Court for the Southern District of Mississippi dismissed all claims against the individual board members except for the § 1983 equal protection claim regarding the 2023 hiring decision. The district court found that the plaintiff stated a prima facie case of sex discrimination and that the right to be free from such discrimination was clearly established, thus denying the defendants’ motion to dismiss based on qualified immunity.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed the denial of qualified immunity de novo. The court held that the plaintiff adequately pleaded a violation of clearly established equal protection rights, including allegations that each defendant took individual actions causing the asserted harm. The Fifth Circuit therefore affirmed the district court’s denial of the motion to dismiss as to the § 1983 equal protection claim arising from the 2023 hiring decision. View "Jackson v. Duff" on Justia Law

A group of retired law enforcement officers who had worked for a Connecticut town sought a court declaration that they were entitled to receive contributions to their health savings accounts (HSAs) from the town in the same manner as currently employed police officers. The retirees based their claim on a pension agreement negotiated by the town and their union, which provided that retirees would receive health insurance coverage, including deductibles, “in effect for active Police Officers.” After these retirees left their positions, a new collective bargaining agreement was executed that changed the town’s insurance plan to a high deductible health plan and required the town to contribute 50% of the deductible amount to the HSAs of active police officers. The retirees, now participating in the same insurance plan, did not receive these contributions.The Superior Court for the judicial district of New London found in favor of the retirees, concluding that the pension agreement entitled them to the same HSA contributions as active officers. The court awarded damages accordingly. The Appellate Court affirmed, reasoning that the effect of the HSA contributions was to lower the deductible for active officers, and that the retirees were entitled to equal treatment under the pension agreement.On appeal, the Connecticut Supreme Court reviewed whether these HSA contributions constituted “coverage” or “deductibles” under the relevant pension agreement. The court held that the ordinary meaning of “coverage” and “deductible” did not include HSA contributions, which are distinct from the insurance policy’s terms and can be used for a variety of purposes. The court further noted that extrinsic evidence, including subsequent collective bargaining agreements, confirmed that the contracting parties did not intend HSA contributions for retirees. The Supreme Court reversed the Appellate Court’s judgment and directed that judgment be entered for the town. View "Duso v. Groton" on Justia Law