Justia Labor & Employment Law Opinion Summaries

A man was hired by a retail store in October 2020 and worked without incident for about 20 months. In June and July 2022, he was involved in a series of disruptive workplace incidents, including emotional outbursts, irrational statements, and aggressive behavior that concerned his supervisors and colleagues. Following these events, the company terminated his employment for violating its workplace violence policy. At no time prior to his termination did the employee disclose to company officials that he had been diagnosed with bipolar disorder, nor did he request any accommodations related to a mental disability.After his termination, the employee provided a generic doctor’s note indicating he could return to work, but it did not mention any disability. He later contacted the company seeking reinstatement, alleging discrimination based on his mental disability. The company reviewed his claim but upheld the termination decision.The employee subsequently filed a lawsuit in the Superior Court of Los Angeles County, asserting claims under California’s Fair Employment and Housing Act (FEHA) for disability discrimination, failure to provide reasonable accommodation, and failure to engage in the interactive process. The Superior Court granted summary judgment in favor of the employer, finding there was no evidence the company knew of the employee’s disability at the time of termination, and that the company had a legitimate, nondiscriminatory reason for the termination.On appeal, the California Court of Appeal, Second Appellate District, Division Five, affirmed the lower court’s judgment. The appellate court held that, as a matter of law, an employer cannot be held liable under FEHA for disability discrimination or failure to accommodate a disability when the employee’s disability was undisclosed and not the only reasonable interpretation of the employee’s observed conduct. The court concluded the employer’s knowledge of a disability cannot be inferred unless a disability is the only reasonable explanation for the employee’s behavior. View "Husband v. Target Corp." on Justia Law

Four employers participating in an underfunded multiemployer pension plan withdrew from the plan in 2018. The plan’s trustees, using a newly adopted discount rate of 6.50% (previously 7.50%), calculated each employer’s withdrawal liability based on the plan’s unfunded vested benefits as of December 31, 2017. The change in the discount rate, adopted after the measurement date but before the calculation, significantly increased the amounts the employers owed. The employers challenged these assessments in arbitration, arguing that only actuarial assumptions in effect as of the measurement date could be used.Each arbitrator agreed with the employers, concluding that the plan should have used the discount rate in effect on the measurement date and requiring reassessment with the prior, higher rate. The fund’s trustees then sought review in the United States District Court for the District of Columbia, which disagreed with the arbitrators and held that it was permissible for the plan’s actuary to select assumptions after the measurement date. The United States Court of Appeals for the District of Columbia Circuit affirmed, reasoning that the statutory text did not require actuarial assumptions to be fixed as of the measurement date, and that assumptions could be adopted later as long as they reflected the best estimate as of that date. This decision created a conflict with a prior ruling by the United States Court of Appeals for the Second Circuit.The Supreme Court of the United States held that the relevant provisions of ERISA do not require the actuarial assumptions used to calculate withdrawal liability to be selected on or before the statutory measurement date. The Court affirmed the D.C. Circuit, concluding that, while the measurement date fixes the relevant factual data, the timing of selecting actuarial assumptions is not limited by statute. The Court also noted that the statute requires only that the assumptions be reasonable and reflect the actuary’s best estimate. View "M & K Employee Solutions, Inc. v. Trustees of IAM Nat. Pension" on Justia Law

An off-duty police officer in the District of Columbia shot and seriously injured a man outside a residence in Maryland after suspecting an attempted vehicle break-in. The officer did not call 911 as trained, confronted the individual, and used deadly force, although no weapon or evidence of crime was found on the victim. Following internal reviews, the police department sought to terminate the officer. His union invoked arbitration, as allowed by the collective bargaining agreement.An arbitrator determined that the officer’s conduct was reckless, violated departmental policies, and met the definition of reckless endangerment under Maryland law. However, the arbitrator concluded that termination was not warranted and reduced the discipline to a 45-day suspension, referencing a prior similar case involving another officer. The District of Columbia Public Employee Relations Board (PERB) sustained this sanction. The Superior Court of the District of Columbia affirmed PERB’s decision. On a prior appeal, the District of Columbia Court of Appeals remanded the case, directing PERB to further explain its reasoning regarding whether the arbitral award was contrary to law or public policy.After PERB again upheld the arbitrator’s decision on remand and the Superior Court affirmed, the case returned to the District of Columbia Court of Appeals. The court reviewed whether the arbitral award was “on its face contrary to law and public policy.” The court held that the award was not contrary to law because the arbitrator did not purport to apply and misapply the Douglas factors, nor was the penalty so disproportionate as to be illegal. The court further held that the award was not contrary to public policy, noting the absence of a statutory or regulatory mandate requiring termination under these circumstances and emphasizing the narrow grounds for overturning arbitral awards on public policy. The court affirmed the judgment upholding PERB’s decision. View "District of Columbia Metropolitan Police Dep't v. District of Columbia Public Employee Relations Board" on Justia Law

A laboratory director at the Whitehead Institute for Biomedical Research and a tenured professor at MIT met a graduate student who later became a fellow at Whitehead. During her academic progression, the professor made sexualized comments to her and later engaged in a sexual relationship with her, which she felt unable to end due to his influence over her career. After the relationship ended, he continued making inappropriate comments. A culture survey at Whitehead suggested that he fostered or participated in sexually explicit and inappropriate discussions and threatened those who reported his conduct. An independent investigation found he had violated Whitehead policies, including its sexual harassment policy, leading to his resignation and MIT placing him on leave.While MIT’s investigation was ongoing, the professor sued the student, Whitehead, and its director for defamation and other claims. The student filed a counterclaim against the professor for sexual harassment under the Massachusetts sexual harassment statute (G. L. c. 214, § 1C). The Superior Court dismissed this counterclaim, holding that the statute did not permit claims against individuals, only institutions. The Appeals Court affirmed, reasoning the statute only applied to educational institutions.The Supreme Judicial Court of Massachusetts granted further appellate review and considered whether the sexual harassment statute permits claims against individual perpetrators in the academic context. The court held that the statute does allow such claims, noting its plain language and remedial purpose. The court reversed the Superior Court’s dismissal of the counterclaim and remanded for further proceedings, explicitly holding that victims of sexual harassment in academic settings may bring actions against individual harassers under the statute. View "Sabatini v. Knouse" on Justia Law

A Massachusetts resident was hired by a staffing company authorized to do business in Massachusetts and assigned to work for a New Hampshire corporation at a job site in Maine. The staffing company and the New Hampshire corporation had an agreement stating that the staffing company would provide employees, pay their wages and benefits, and handle workers’ compensation. The New Hampshire corporation supervised the employees on site. While working in Maine, the employee was injured. He filed a workers’ compensation claim in Massachusetts against the staffing company, which was settled.Subsequently, the employee filed a negligence lawsuit against the New Hampshire corporation in the Cumberland County Superior Court in Maine. The corporation moved for summary judgment, arguing that it was immune from suit under Maine’s Workers’ Compensation Act, specifically 39-A M.R.S. § 104, which provides immunity to employers using temporary help services under certain conditions. The Superior Court denied the motion, concluding that Massachusetts law governed the immunity issue, not Maine law, and that under Massachusetts law, the corporation was not immune. The corporation appealed.The Maine Supreme Judicial Court reviewed the denial of summary judgment, applying Maine’s choice of law rules. It determined that Massachusetts law governed the workers’ compensation immunity issue because Massachusetts had the most significant relationship to the parties and the occurrence. The Court further held that, under Massachusetts law, the New Hampshire corporation did not qualify for immunity because it was not contractually liable for workers’ compensation benefits to the injured employee. The Court affirmed the Superior Court’s denial of summary judgment, making clear that the corporation was not entitled to immunity from the employee’s negligence claim under the applicable law. View "Valmont-Oliver v. Envirovantage, Inc." on Justia Law

Angela Kendall was employed as a production operator by a manufacturing company that required physical tasks such as standing for up to 12 hours, lifting, bending, and reaching. In 2021, after suffering from back pain and being diagnosed with muscle spasms and potential sciatica, Kendall received a temporary workplace accommodation allowing her to sit occasionally during her shifts. Over time, her medical restrictions increased, including limitations on standing, bending, lifting, and other physical activities. After exhausting her leave and with no foreseeable return to unrestricted work, her employment was terminated.Kendall filed discrimination charges, alleging her employer failed to accommodate her disability and retaliated in violation of the Americans with Disabilities Act (ADA), and discriminated based on sex in violation of Title VII. The United States District Court for the Eastern District of Missouri granted summary judgment to the employer on all claims, finding that Kendall was not qualified for her position because she could not perform its essential functions, even with reasonable accommodation, and that there was no evidence of adverse employment action based on retaliation or sex.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. The court held that standing for extended periods, lifting, bending, and other physical tasks were essential functions of the production operator position, as evidenced by the job description and employer’s expectations. Kendall’s medical restrictions prevented her from performing these essential duties, and allowing her to sit as needed was not a reasonable permanent accommodation. The court also found that Kendall failed to establish a prima facie case of sex discrimination because she was not qualified for her position at the time of termination. Accordingly, the Eighth Circuit affirmed the district court’s judgment in favor of the employer. View "Kendall v. Zoltek Corporation" on Justia Law

The plaintiff, who served as chief of a town fire department, alleged that his employer retaliated against him in violation of state anti-discrimination law after he complained about the treatment of his niece, a probationary firefighter. The niece, along with another woman, was hired by the department, and concerns were raised by supervisors about her performance during training. The chief recused himself from her hiring and training processes due to potential conflicts of interest, but later advocated for her to receive remedial training, as had been provided to other male firefighters with similar deficiencies. After raising concerns about what he viewed as unfair treatment of his niece compared to male colleagues, the chief found himself subject to a series of adverse employment actions, including denial of a contract renewal, an internal investigation, administrative leave, and ultimately, circumstances that led to his resignation.Previously, the plaintiff filed federal claims, including retaliation and age discrimination, in the United States District Court for the District of Massachusetts. That court granted summary judgment for the town on all claims, and the United States Court of Appeals for the First Circuit affirmed as to the federal claims, but dismissed the remaining state law claims without prejudice. The plaintiff then refiled his state law claims in the Superior Court in Plymouth County. The Superior Court granted summary judgment to the town on some claims but allowed the retaliation claim to proceed to trial. A jury found for the plaintiff, awarding both compensatory and punitive damages. The trial judge denied the town’s motion for judgment notwithstanding the verdict or for a new trial.On further review, the Supreme Judicial Court of Massachusetts held that there was sufficient evidence for the jury to find that the town retaliated against the plaintiff for his complaints of gender discrimination. Although the jury instructions improperly blended pretext and mixed-motive frameworks, the Court determined that this did not prejudice the outcome, as the jury made clear findings on causation and intentional retaliation. The Court affirmed the judgment and the damages awarded to the plaintiff. View "Robinson v. Marshfield" on Justia Law

The case involves a dispute between two unions representing Department of Veterans Affairs (VA) employees and the VA itself, along with the VA Secretary. The core issue centers on the VA’s termination of a collective bargaining agreement (CBA) that was signed in August 2023 and set to last three years. The termination followed a March 2025 executive order by President Trump that excluded the VA from coverage under the Federal Service Labor-Management Relations Statute (FSLMRS), citing national security. The VA Secretary then terminated the CBA, prompting the unions to file suit, alleging violations of the Administrative Procedure Act (APA) and the First Amendment.Prior to this case, unions not party here challenged the executive order in the U.S. District Court for the Northern District of California, which issued a preliminary injunction. That injunction was later stayed and ultimately vacated on appeal by the Ninth Circuit. In the present case, the U.S. District Court for the District of Rhode Island granted a preliminary injunction requiring the VA to reinstate the CBA and later issued an enforcement order when the VA attempted to re-terminate the agreement. The district court found that the termination was likely retaliatory and arbitrary and capricious.On appeal, the United States Court of Appeals for the First Circuit reviewed requests to stay both the preliminary injunction and the enforcement order. The First Circuit denied the VA’s request to stay the preliminary injunction, finding the VA had not made a strong showing of likely success on appeal. However, the court granted a partial stay of the enforcement order, holding that the district court likely lacked jurisdiction to order specific compliance with every term of the CBA under threat of contempt. The court otherwise denied the VA’s requests. View "American Federation of Gov't Employees Local 2305 v. United States Department of Veterans Affairs" on Justia Law

A correctional officer who also served as a union representative at a state prison was disciplined after posting materials related to her own prior disciplinary action on a union bulletin board. The materials, which included the surnames of other officers, were visible to inmate workers and were perceived by prison management as potentially fostering a “code of silence” among correctional staff. The officer was suspended for 60 workdays for this posting. She appealed the discipline to the State Personnel Board (SPB), arguing her posting was protected speech regarding the Department’s disciplinary practices. Separately, her union filed a grievance, claiming the suspension violated the memorandum of understanding (MOU) and the Ralph C. Dills Act, which prohibit retaliation for protected union activities.The SPB ultimately upheld the suspension, determining that the posting constituted inexcusable neglect of duty and failure of good behavior, and justified the imposed penalty. The question of whether the discipline was retaliatory under the Dills Act was reserved for arbitration. The arbitrator later found in favor of the union, concluding the Department had retaliated against the officer for protected union activity and failed to prove it would have imposed the same discipline absent that activity. The arbitrator ordered the Department to rescind the discipline and make the officer whole, including backpay.The California Court of Appeal, Third Appellate District, reviewed the trial court’s decision that had struck the arbitrator’s remedy of rescinding the discipline and making the officer whole. The appellate court held that the arbitrator did not exceed her powers by issuing this award and that no explicit public policy or constitutional provision barred the arbitrator’s remedial authority under the MOU and Dills Act. The court reversed the trial court’s judgment and directed entry of a new judgment confirming the arbitration award in its entirety. View "Dept. of Human Resources v. Cal. Correctional Peace Officers" on Justia Law

A semitruck driver suffered a left shoulder injury while unloading his truck at work. Medical treatment revealed a traumatic rotator cuff tear, and the employee underwent surgery that included a distal clavicle excision. After surgery, he continued to experience symptoms but was eventually cleared to return to work. Two physicians evaluated the extent of permanent impairment: the treating surgeon, who assigned 6% impairment and did not attribute the clavicle excision to the work injury, and an independent medical examiner, who assigned 19% impairment, including 10% for the clavicle excision based on the American Medical Association (AMA) Guides.At the arbitration hearing before the Iowa Workers’ Compensation Commission, the deputy commissioner credited the independent medical examiner’s causation opinion but disagreed with his interpretation of the AMA Guides. The deputy concluded that the 10% impairment figure for the clavicle excision should be multiplied by 25%, as specified in another table in the Guides, resulting in an overall lower impairment rating. Both parties petitioned for judicial review. The Iowa District Court for Polk County affirmed the commissioner's decision, reasoning that the commissioner correctly applied the Guides over the experts’ interpretations. On appeal, the Iowa Court of Appeals, in a split decision, upheld the district court’s ruling regarding the impairment calculation and alternate medical care.The Supreme Court of Iowa granted further review only on the issue of permanent partial disability benefits. The court held that while the commissioner may select among expert views, the legal interpretation of the AMA Guides is a judicial function. The court concluded that the commissioner erred by applying the 25% multiplier to the clavicle excision impairment rating, as the specific table in the AMA Guides for this procedure does not require it. The case was remanded for proceedings consistent with this interpretation. View "Koeller v. Cardinal Logistics Management Corporation and Ace American Insurance Company" on Justia Law