Justia Labor & Employment Law Opinion Summaries

An employee of the Chicago Transit Authority (CTA), represented by a union, was terminated after repeatedly failing to follow the proper procedure for reporting Family and Medical Leave Act (FMLA) absences. The CTA required employees to notify a third-party administrator, ReedGroup, as well as their work location, when taking FMLA leave. The employee, who is transgender and had previously advocated for workplace accommodations and insurance coverage related to his transition, applied for intermittent FMLA leave for back pain, but his application was denied after he failed to complete the required process for obtaining a third medical opinion. Despite the denial, he continued to report absences as FMLA leave only to his work location, not ReedGroup, resulting in his termination for falsification of leave.After his discharge, the employee sought the union’s assistance in contesting his termination and pursued the available grievance and arbitration procedures. He also filed charges with the Equal Employment Opportunity Commission, then sued both the CTA and the union in the United States District Court for the Northern District of Illinois, Eastern Division. He asserted claims of transgender discrimination and retaliation under Title VII, as well as FMLA interference and retaliation against the CTA, and a municipal liability claim. The district court granted summary judgment in favor of the CTA and the union, concluding that the employee had failed to produce evidence that would allow a reasonable jury to find in his favor.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s decision. The court held that the employee failed to provide sufficient evidence that similarly situated non-transgender employees were treated more favorably, or that the CTA or the union’s actions were pretextual or motivated by discriminatory or retaliatory animus. The court also found no error in the exclusion of evidence and upheld the dismissal of the FMLA claims. The summary judgment for both defendants was affirmed. View "Brown v Chicago Transit Authority" on Justia Law

The appellant was employed by an insurance company and struggled with mental health issues, including major depressive disorder and later posttraumatic stress disorder and anxiety. Over several years, he received annual salary increases and bonuses. In 2020, after transferring to a new team and informing his supervisor about his mental health struggles, he took FMLA leave for treatment. While he was on leave, his supervisor approved a significantly reduced bonus and salary increase compared to prior years. Upon returning to work, he received positive performance reviews and requested accommodations related to his disability. He was granted some accommodations and continued working remotely. In 2021, after requesting further accommodations, he received another reduced bonus and salary increase. Later, after extended medical leave and unsuccessful attempts to return with additional accommodations, his employment was terminated.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the employer on all claims. It found that the appellant had not established a prima facie case of discrimination or retaliation under the ADA and FMLA. Specifically, the District Court held that the reduced bonuses and salary increases did not constitute adverse employment actions and that there was no causal connection between the protected activities (requests for leave and accommodations) and the adverse actions.The United States Court of Appeals for the Third Circuit reviewed the summary judgment order. The court applied the Burlington Northern standard, holding that the less restrictive “materially adverse” standard for retaliation claims under Title VII also applies to ADA and FMLA retaliation claims. The court found that unusually suggestive temporal proximity between the appellant’s FMLA leave and his 2020 bonus established a prima facie case for retaliation, but that such proximity was lacking for the 2021 bonus. The Third Circuit vacated the summary judgment as to the 2020 bonus retaliation claims and remanded for the District Court to consider pretext, while affirming summary judgment as to the 2021 bonus retaliation claims. View "Steidle v. United States Liability Insurance Co" on Justia Law

Dr. Jeffrey M. Ahn, an otolaryngologist practicing in New Jersey and New York, treated patients insured by Cigna Health and Life Insurance Company, which provides ERISA-governed health plans. After submitting claims for approximately fifty treatments, Dr. Ahn received denial notices from Cigna, many of which stated his claims were rejected because he was not a licensed provider. Upon appeal, Cigna sometimes reversed or modified the denial reasons. Dr. Ahn contended that these statements were defamatory and filed suit in New Jersey Superior Court, alleging defamation, defamation per se, and tortious interference.Cigna removed the case to the United States District Court for the District of New Jersey and sought dismissal or summary judgment, arguing ERISA preemption and a statute of limitations defense. Initially, the District Court deferred ruling on preemption, as it was unclear which claims related to ERISA plans. After discovery, Dr. Ahn withdrew two claims, leaving only defamation per se. Cigna again moved for summary judgment, submitting evidence that all relevant plans were governed by ERISA. Dr. Ahn presented no contrary evidence. The District Court found the plans were ERISA plans and held that Dr. Ahn’s defamation per se claim was preempted because it concerned statements made in explanation of benefits forms, which are part of ERISA plan administration.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s decision de novo. The Third Circuit held that ERISA preempts a healthcare provider’s state-law defamation claim when the alleged defamatory statements appeared in explanation of benefits forms sent to beneficiaries of ERISA plans. The court reasoned that such communications are a central aspect of plan administration and that allowing state-law claims would undermine uniformity in ERISA administration. The Third Circuit affirmed the District Court’s grant of summary judgment in favor of Cigna. View "Ahn v. Cigna Health and Life Insurance Co" on Justia Law

Two former flight attendants alleged that their employer terminated them because of their religious beliefs after they commented on the company’s internal communications platform regarding the company’s public support for proposed federal legislation expanding protections for LGBTQ individuals. One plaintiff’s comment explicitly referenced religious concerns, while the other plaintiff’s comment raised a question about the regulation of morality. Both plaintiffs were members of the flight attendants’ union, which actively participated in the internal investigation and disciplinary process. The union representatives made statements that could be interpreted as disparaging the plaintiffs’ religious beliefs. Both plaintiffs had good employment records, though one had a prior disciplinary history.The United States District Court for the Western District of Washington granted summary judgment for the employer and the union on the federal Title VII claims, finding no genuine dispute of material fact as to whether the terminations were motivated by religious discrimination. The district court also ruled that the Railway Labor Act preempted the plaintiffs’ state-law anti-discrimination claims against the union, dismissing those claims.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s rulings de novo. The appeals court held that, based on the evidence and under both direct/circumstantial and burden-shifting standards, there was a genuine dispute of material fact as to whether the employer terminated the plaintiffs because of their religious beliefs, and as to whether the union attempted to cause or acquiesced in their terminations for the same reason. The court also held that the Railway Labor Act’s duty of fair representation does not impliedly preempt state anti-discrimination claims against unions. The Ninth Circuit reversed the district court’s grant of summary judgment and its dismissal of the state-law claims, remanding for further proceedings. View "BROWN V. ALASKA AIRLINES, INC." on Justia Law

Sara Dobbins worked for the U.S. Department of Agriculture (USDA) and experienced mental health issues related to domestic abuse, leading to accommodations at work such as flexible schedules and telework. After her supervisor retired, the USDA allowed her to continue with adjusted scheduling, but with new requirements. When Charles Parr became her supervisor in 2021, he restricted these accommodations due to her frequent unapproved absences and tardiness. Over four months, Dobbins accumulated over thirty “absent without leave” infractions. The USDA suspended her, and later terminated her employment. Dobbins filed an EEOC complaint alleging sex and disability discrimination, hostile work environment, failure to accommodate, and retaliation. The EEOC found no actionable harassment or discrimination.The United States District Court for the Western District of Missouri granted summary judgment in favor of the USDA, finding that Dobbins did not provide sufficient evidence of discrimination or harassment, and failed to exhaust administrative remedies for her failure to accommodate claim.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment order de novo. The appellate court agreed that Dobbins did not present direct or indirect evidence that her suspension or termination were motivated by discrimination based on sex or disability. The court found that her absences, not her disabilities, were the basis for the adverse actions, and that her comparator evidence was insufficient as the other employee was not similarly situated. The court further held that Dobbins’s hostile work environment claim failed because the conduct described was not sufficiently severe or pervasive, nor clearly linked to her disability. Additionally, her failure to accommodate claim was barred for failure to exhaust administrative remedies, and her sex discrimination and retaliation claims were waived because she did not contest them at summary judgment. The court affirmed the district court’s judgment. View "Dobbins v. Rollins" on Justia Law

Employees at a Starbucks store in Sylmar, California, engaged in union organizing activities during 2022. Several conversations between store managers and employees occurred regarding the unionization process, pay and benefit increases, and working conditions. Employees reported statements by managers suggesting that certain benefits would be paused or lost due to union negotiations, that unionization would not improve conditions, and that other jobs offered better pay. One employee, Untaran, was interrogated about his union support and subsequently terminated, with conflicting accounts regarding the reasons for his discharge.After a union election where a majority voted against representation, the union filed objections based on Untaran’s termination and management statements. An Administrative Law Judge for the National Labor Relations Board (NLRB) found violations of the National Labor Relations Act (NLRA), including coercive threats, interrogation, and unlawful discharge, and ordered remedies such as reinstatement, back pay, compensatory damages, and a new election. The NLRB adopted some findings and reversed others, particularly expanding the findings regarding coercive interrogation and threats.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court upheld the NLRB’s findings and enforcement orders regarding one coercive threat against Pichardo, the threat against Untaran, and Untaran’s coercive interrogation claim, finding these supported by substantial evidence. However, the court denied enforcement for the NLRB’s order regarding Untaran’s unlawful discharge claim and the coercive threat claims involving Sosa and Ramirez, as they lacked substantial evidence. The court dismissed Starbucks’s appeal regarding the order for a second union election, citing lack of jurisdiction over representation proceedings consolidated with unfair labor practice cases. View "Starbucks v. NLRB" on Justia Law

Technicians employed by the defendant performed installation, maintenance, inspection, testing, repair, and replacement of fire alarms, fire sprinklers, and security system equipment under contracts with public entities in New York. These contracts varied in their language regarding the payment of prevailing wages: some disclaimed any obligation to pay prevailing wages, some were silent, and a few expressly based payment on prevailing wage rates. All contracts included a clause providing that any action against the defendant had to be brought within one year of accrual.The plaintiffs brought a proposed class action in the United States District Court for the Northern District of New York, alleging, among other claims, that they were owed prevailing wages as third-party beneficiaries of the contracts. The District Court granted the defendant’s motion for partial summary judgment, finding that the breach of contract claims were time-barred by the contractual limitation period, that the contracts did not expressly entitle plaintiffs to prevailing wages, and, in the alternative, that plaintiffs were not covered by the prevailing wage law. On appeal, the United States Court of Appeals for the Second Circuit held that plaintiffs were covered by Labor Law § 220 but certified two questions to the New York Court of Appeals regarding the implicit inclusion of prevailing wage promises in public works contracts and the enforceability of shortened contractual limitation periods.The New York Court of Appeals held that the promise to pay prevailing wages is implicit in every public works contract covered by Labor Law § 220, regardless of whether that promise appears in the contract’s text. As a result, employees may bring third-party beneficiary breach of contract claims to enforce the prevailing wage requirement. The Court further held that contractual agreements to shorten the statute of limitations for such claims are unenforceable. The Court answered the first certified question in the affirmative and the second in the negative. View "Walton v Comfort Sys. USA (Syracuse), Inc." on Justia Law

A registered nurse, who is a black woman and naturalized U.S. citizen from Ghana, began working at a healthcare system in Texas and alleged frequent discrimination and harassment by co-workers, including mockery of her accent and food, derogatory comments about black employees, and preferential treatment of Filipino employees. She reported these incidents to supervisors, but claims their response was inadequate. After further complaints, she alleges retaliation through informal and formal disciplinary actions and the extension of her probation period. She was later injured in a car accident, took medical leave, and upon seeking treatment at a hospital operated by the same employer during a hurricane lockdown, had contentious interactions with staff, but ultimately received care. When she tried to return to work, she requested refresher orientation and additional training, but after further delays and lack of response, she resigned, citing discrimination and retaliation.She subsequently filed two charges with the Equal Employment Opportunity Commission. The first charge, encompassing events through September 2017, was timely; the second, covering her resignation and later events, was untimely. In May 2021, she sued her employer for discrimination, hostile work environment, retaliation under Title VII and Section 1981, and disability discrimination under the ADA. The United States District Court for the Southern District of Texas adopted a magistrate judge’s recommendation granting summary judgment to the employer on all claims.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed summary judgment for the employer on most claims. However, it reversed the grant of summary judgment on the plaintiff’s Title VII and Section 1981 hostile-work-environment claims, holding that there was a genuine dispute of material fact as to whether the conduct was severe or pervasive and whether the employer’s response was adequate. The court remanded those claims for further proceedings, limiting them to facts alleged in the plaintiff’s timely EEOC charge. View "Brenyah v. Columbia Hospital" on Justia Law

Robert Cocom, a former airport janitor, brought a putative class action against his previous employer, ABM Aviation, Inc., alleging wage and hour violations. When he was hired, Cocom signed a Mutual Arbitration Agreement (MAA) requiring employment-related disputes to be resolved through arbitration. The MAA included waivers of class, collective, and representative actions, as well as a provision stating that arbitration awards would not have preclusive or precedential effect in other proceedings. Cocom’s lawsuit was originally filed in state court but was removed to federal court by ABM, which then moved to compel arbitration and strike the class claims.The United States District Court for the Central District of California denied ABM’s motion, finding the arbitration agreement both procedurally and substantively unconscionable. The court relied heavily on the California Court of Appeal’s decision in Cook v. University of Southern California, interpreting the MAA as having an overly broad scope, indefinite duration, and lack of mutuality, and concluding that certain waivers violated California law. Finding multiple provisions unconscionable, the district court declined to sever them and refused to enforce the MAA.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s judgment. The appellate court held that the MAA’s provisions were distinguishable from those in Cook, noting that the MAA was limited to employment-related disputes, thereby avoiding the overbreadth, indefinite duration, and mutuality issues identified in Cook. The Ninth Circuit also found that any potentially unconscionable waivers (such as those related to representative actions or public injunctive relief) were severable. The main holding was that the MAA was not substantively unconscionable and should be enforced, and the case was remanded for further proceedings. View "COCOM V. ABM AVIATION, INC." on Justia Law

A charter city in California employs attorneys who are classified as at-will, exempt employees under its city charter. During negotiations for a new memorandum of understanding, the union representing these attorneys made two proposals: one requiring that any discipline, including termination, be for just cause and subject to arbitration, and another requiring layoffs to be conducted by seniority. The city refused to submit these proposals to binding interest arbitration, maintaining that such changes conflicted with its charter, which specifies that exempt employees serve at the pleasure of the appointing authority and can be terminated without cause. The union filed an unfair practice charge with the Public Employment Relations Board (PERB), arguing the city violated its obligations under state law and the city charter by refusing to arbitrate these proposals.Before the Court of Appeal’s review, an administrative law judge found for the union, concluding that the city’s charter provision was superseded by the Meyers-Milias-Brown Act (MMBA) because the proposals addressed matters of statewide concern. PERB affirmed the ALJ’s decision, but on different grounds, finding that the charter could be harmonized with the MMBA and that the proposals were eligible for arbitration. PERB held the city had engaged in bad faith bargaining by refusing to submit the proposals to arbitration and ordered the city to allow arbitration, as well as to compensate the union for related costs.The California Court of Appeal, First Appellate District, Division Five, granted review and reversed PERB’s decision. The court held that, under the city’s charter and civil service commission rules, the at-will status of exempt attorneys is not subject to binding interest arbitration. The court found that the proposals sought to alter matters specifically carved out from arbitration by the charter. Consequently, the court vacated PERB’s findings and orders, concluding that the city did not violate its duty to bargain in good faith by refusing to arbitrate these proposals. View "City & County of S.F. v. Public Employment Relations Bd." on Justia Law