Justia Labor & Employment Law Opinion Summaries

After being employed by the City of St. Louis as a corrections officer for over two decades, the plaintiff was transferred to a clerk typist position in the City’s towing division following an injury. In her new role, she uncovered and reported numerous instances of apparent misconduct and fraud involving the unlawful sale or transfer of vehicles by employees at the tow lot. She conveyed her concerns to various city officials, including her supervisors, the mayor’s office, and the comptroller’s office, and ultimately disclosed the information to the media. Following these disclosures, she experienced workplace retaliation and was ultimately terminated by the Director of the Department of Streets the day after a news story, which included information she had provided, was broadcast.The United States District Court for the Eastern District of Missouri dismissed the First Amendment claim against the City but allowed the First Amendment retaliation claim against the Director, in his individual capacity, to proceed to trial. The jury found in favor of the plaintiff, concluding that her protected speech was a motivating factor in her termination, and awarded compensatory and punitive damages. The district court denied the Director’s post-trial motions for judgment as a matter of law and for a new trial.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the Director failed to preserve his qualified immunity defense for appeal and found that there was sufficient evidence for the jury to find that the plaintiff’s protected speech motivated her termination. The court further determined that the district court did not abuse its discretion in admitting contested evidence or in denying a new trial, and that there was enough evidence for punitive damages. The Eighth Circuit affirmed the district court’s judgment. View "Woods v. City of St. Louis, Missouri" on Justia Law

A teacher employed by a school district in a remote Alaska village rented housing from the district. After the district removed a railing from the stairs of the teacher’s residence and did not repair it despite complaints, the teacher fell while taking out the trash and was injured. The teacher notified the school principal of his injury, but she declined to assist or allow him to seek medical help. There were additional conflicts between the teacher and the principal, including disciplinary actions and allegations of policy violations. The teacher later reported the principal to her supervisors and the state’s Professional Teaching Practices Commission. Following these events, the district decided not to rehire the teacher for the following school year.The teacher filed a negligence lawsuit against the district and the principal, later amending his complaint to add claims for whistleblower retaliation, wrongful termination, defamation, intentional infliction of emotional distress (IIED), and workplace safety violations. The Bering Strait School District, after being sued, reported the injury as work-related to the Alaska Workers’ Compensation Board and moved to dismiss the lawsuit, arguing that the teacher’s exclusive remedy was through workers’ compensation. The Superior Court for the Second Judicial District, Nome, dismissed the case in its entirety, concluding that the teacher failed to state a claim, and later awarded attorney’s fees to the district.The Supreme Court of the State of Alaska reviewed the case and held that, taking the teacher’s allegations as true, it was not clear that his injury was within the course and scope of his employment or that workers’ compensation was his exclusive remedy. The court reversed dismissal of the negligence, whistleblower, wrongful termination, IIED, and defamation claims, finding the complaint stated viable claims. The court affirmed dismissal of the workplace safety claim and vacated the attorney’s fees award, remanding the case for further proceedings. View "Mitchell v. Bering Strait School District" on Justia Law

A county office established to oversee the sheriff’s department received a whistleblower complaint and, in conducting its investigation, issued subpoenas to certain sheriff’s employees seeking documents and testimony. The sheriff’s employees refused to comply, and both the sheriff’s office and the deputy sheriffs’ union asserted that the oversight office did not have authority to issue subpoenas related to whistleblower investigations. The oversight office then petitioned the Sonoma County Superior Court for an order enforcing the subpoenas and initiating contempt proceedings against the noncompliant parties.The Sonoma County Superior Court denied the oversight office’s request, finding that it did not have the authority to issue the subpoenas under the relevant laws and local ordinances. The oversight office appealed this denial, arguing that state law granted it subpoena power and that no labor agreement or local ordinance eliminated this authority.The California Court of Appeal, First Appellate District, Division Five, reviewed the case. It first determined that the trial court’s order was appealable as a final judgment. On the merits, the appellate court held that section 25303.7 of the Government Code directly grants subpoena power to sheriff oversight entities created under that statute, and that the oversight office in question qualified as such an entity—even though it was not named “inspector general.” The court further held that the existence of a labor agreement between the county and the union did not eliminate the statutory subpoena authority and that any contrary provisions in the agreement could not override state law. The court also rejected arguments that the oversight office lacked authority to investigate the sheriff individually, and found that newly enacted law clarified that such entities have access to peace officer personnel records. The appellate court reversed the trial court’s order and remanded with instructions to enforce the subpoenas. View "Independent Office of Law v. Sonoma County Sheriff's Office" on Justia Law

The plaintiff, a Hawaii resident, entered into a National Employment Agreement with Cardiovascular Systems, Inc. (CSI), a Minnesota-based medical device company, to serve as District Sales Manager for Hawaii. The agreement required him to complete mandatory training in Minnesota before he could work fully in Hawaii. He attended training in Minnesota for a total of twelve days over two visits during early 2023 and participated in remote meetings from Hawaii. Shortly after completing training, CSI terminated his employment. The plaintiff alleged that his termination was in retaliation for reporting illegal conduct in violation of federal law, while CSI claimed it was due to his conduct. Subsequently, Abbott Laboratories, Inc. acquired CSI.The plaintiff first filed a complaint in Minnesota state court against Abbott Laboratories, Inc. (ALI) under the Minnesota Whistleblower Act (MWA). ALI removed the case to federal court and moved to dismiss the complaint. After an unsuccessful attempt to amend his complaint, the plaintiff voluntarily dismissed the action and refiled a nearly identical complaint, later amending it to add CSI as a defendant and a claim under the Hawaii Whistleblowers’ Protection Act (HWPA). The defendants again moved to dismiss, and the plaintiff sought to further amend the complaint to add more details and another defendant.The United States District Court for the District of Minnesota granted the motion to dismiss, holding that the plaintiff did not qualify as an “employee” under the MWA because he neither performed “services for hire” nor maintained ongoing physical presence in Minnesota, and that he had waived his HWPA claim by agreeing to a Minnesota choice-of-law provision in his employment contract. The Eighth Circuit Court of Appeals affirmed, concluding that the district court correctly applied Minnesota law, enforced the choice-of-law provision, and properly denied leave to amend as futile. View "Ghosh v. Abbott Laboratories" on Justia Law

The trustees of an ERISA-regulated pension plan invested in six classes of residential mortgage-backed securities (RMBSs). Three of these investments were in notes issued by Delaware statutory trusts via indenture agreements, while the other three were in regular-interest certificates issued by trusts governed under New York law and classified as REMICs for tax purposes. The trustees alleged that the mortgage servicers mismanaged the loans and engaged in self-dealing, violating ERISA fiduciary duties. They also claimed that Wells Fargo, as master servicer for some trusts, failed to adequately supervise Ocwen (another servicer) and failed to pursue litigation on behalf of the trusts.The United States District Court for the Southern District of New York granted summary judgment in favor of all defendants, holding that, under the Department of Labor’s regulation, only the RMBSs themselves—not the underlying mortgages—were plan assets for ERISA purposes. The court determined that both the notes and the regular-interest certificates were treated as indebtedness without substantial equity features, so the look-through exception did not apply. The trustees’ cross-motion for partial summary judgment was denied.On appeal, the United States Court of Appeals for the Second Circuit affirmed in part, reversed in part, and remanded. The court agreed that the notes issued by the indenture trusts lacked substantial equity features and thus the underlying mortgages were not plan assets. However, it held that the regular-interest certificates represented beneficial interests in the REMIC trusts; under the controlling regulation, the assets of such a trust in which a plan holds a beneficial interest are themselves plan assets. The case was remanded to the district court to consider whether Ocwen acted as an ERISA fiduciary with respect to the mortgages underlying the REMIC trusts. View "Powell v. Ocwen Fin. Corp." on Justia Law

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