Justia Labor & Employment Law Opinion Summaries

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

Employees participating in a 401(k) plan offered by their employer, a clinical laboratory company, brought a class action alleging that the plan’s fiduciaries breached their duties under ERISA by retaining two particular investment options: the Fidelity Freedom Funds and the Invesco Global Real Estate Fund. The plaintiffs argued that these funds underperformed compared to alternatives, were riskier, and that the plan’s managers failed to remove them despite subpar performance. They also claimed that internal policy statements required the funds’ removal and that the plan’s managers failed in their duty to monitor investments and breached trust obligations.The United States District Court for the District of New Jersey initially denied a motion to dismiss the case, allowing discovery to proceed. After discovery, the District Court granted summary judgment in favor of the defendants. The court found that the plan’s fiduciaries had fulfilled their obligations by hiring investment advisors, regularly reviewing investment performance, seeking relevant training, and following up on concerns regarding the challenged funds. The court concluded there was no breach of fiduciary duty or related failures.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s grant of summary judgment de novo, considering all facts and inferences in favor of the plaintiffs. The Third Circuit held that ERISA’s fiduciary standard is process-oriented, not outcome-based. The Court found that the fiduciaries had used a prudent process—hiring advisors, critically assessing their recommendations, meeting with fund managers, and maintaining regular oversight—even if the investments did not always outperform alternatives. The Court further held that internal policy statements were nonbinding and that the fiduciaries did not abuse their discretion. Consequently, the Third Circuit affirmed the District Court’s summary judgment in favor of the defendants on all claims. View "Johnson v. Quest Diagnostics Inc" on Justia Law

A locomotive engineer had longstanding concerns about her employer’s train scheduling practices, believing they led to unsafe conditions by pressuring employees to cut corners. Over a two-year period, she reported these concerns to her union, federal and state agencies, and the Governor’s office. Following a fatal train crash, she raised the issue again at a safety meeting attended by Liberty Mutual Insurance and New Jersey Transit employees. The specifics of this meeting, including which company personnel attended or knew about her participation, remained unclear.After the safety meeting, the engineer committed two significant infractions: first, she operated a train at a speed well above the limit, resulting in suspension after a disciplinary hearing. Her suspension was upheld by internal review boards. Later, she ran a train through a stop signal, leading to her termination after another disciplinary process. The identities of those responsible for the disciplinary decisions were uncertain, and testimony indicated that the signatory on her termination notice was absent at the time. A review board subsequently upheld the termination. After exhausting administrative remedies, the engineer filed suit under the Federal Railroad Safety Act, alleging retaliation for her whistleblowing. The United States District Court for the District of New Jersey granted summary judgment for the employer, finding insufficient evidence of retaliation.The United States Court of Appeals for the Third Circuit reviewed the case de novo. It held that the employee failed to provide evidence that any person involved in the decision to discipline or terminate her knew of her protected activity. The court clarified that, under the Federal Railroad Safety Act, a plaintiff must show knowledge of protected activity by an agent who influenced the adverse action. Because such evidence was lacking, the court affirmed the District Court’s grant of summary judgment for the employer. View "Asay v. New Jersey Transit Rail Operations Inc" on Justia Law

An employee suffered significant hand injuries while working for Wyoming Waste Systems when his hand was caught in the pinch point of a garbage truck’s lift arms. The injured employee, who was being trained by a more experienced colleague, exited the truck to vomit while the lift arms were lowered. The colleague, seated in the passenger seat, engaged the controls to raise the lift arms without knowing the injured employee’s location, resulting in the injury.The injured employee brought suit against his co-worker, alleging liability under the Wyoming Worker’s Compensation Act, claiming the co-worker acted willfully and wantonly to cause the harm. The District Court of Fremont County granted summary judgment to the defendant, finding him immune under the Act. The court determined there was insufficient evidence to show the defendant had “knowledge of the hazard or serious nature of the risk involved,” or that he acted with willful and wanton misconduct.The Supreme Court of Wyoming reviewed the district court’s summary judgment order de novo. It applied established precedent and the statutory standard for co-employee liability, requiring proof of intentional or reckless conduct with knowledge of a specific, high-probability risk. The Supreme Court found that the plaintiff did not present evidence that the defendant had particularized knowledge of the specific danger to the plaintiff at the moment of the incident, nor that the risk was obvious or highly probable. The court held that violations of general safety rules and evidence of negligence do not meet the threshold for willful and wanton misconduct required to overcome co-employee immunity. Accordingly, the Supreme Court affirmed the district court’s grant of summary judgment in favor of the defendant. View "Courtney v. Meyer" on Justia Law

A deputy sheriff sergeant was terminated from his employment after an incident where he encountered two individuals with active “time pay” warrants for failure to pay fines. Despite confirming the existence and validity of the warrants, which were issued by a county court and directed to any law enforcement officer, he told the individuals that he would not arrest them because he believed doing so would be pointless. The interaction was recorded on his body camera. After the sheriff’s office conducted an internal investigation, the sergeant was found to have violated standard operating procedures by neglecting his duty.The sergeant appealed the termination to the county sheriff’s merit commission, which upheld the decision after a hearing. He then filed a petition in error with the District Court for Lancaster County, arguing that the evidence did not support his termination, that due process was denied because he was not given notice regarding issues of credibility or prior investigations, that the commission’s decision was void for untimely delivery, and that he had not waived any objections by failing to object during the administrative hearing. The district court found sufficient evidence supported the commission’s decision, determined the procedures were constitutionally adequate, rejected the argument about untimely delivery because no specific deadline for notification was violated, and concluded there was no prejudice regarding any waiver issue.The Nebraska Supreme Court reviewed the case. It held that sufficient evidence supported the finding that the sergeant neglected his statutory duty to execute the warrants, which justified termination under the governing procedures. The court also held that due process requirements were satisfied, as the sergeant received notice of the charges, an explanation of the evidence, and an opportunity to be heard. The court affirmed the district court’s judgment, finding no prejudicial error in the proceedings. View "Schmuecker v. Lancaster County" on Justia Law

The plaintiff sued his former employer for multiple Labor Code violations, including overtime wage, rest period, separation earnings, wage statement, and recordkeeping violations, under California’s Private Attorneys General Act (PAGA). The employer conceded liability for certain violations, and the parties stipulated to most relevant facts, leaving the amount of civil penalties as the main issue for trial. The plaintiff argued for maximum PAGA penalties totaling over $55 million, while the employer argued for substantial reductions based on the technical nature of the violations and corrective actions taken. The plaintiff also sought over $1.5 million in attorney fees, including a lodestar multiplier.The Superior Court of Orange County, after summary adjudication and trial briefs, awarded $515,965 in civil penalties, applying reductions based on factors such as the absence of unpaid wages for some violations, the employer’s good faith efforts to correct issues, and the relatively small amounts of lost wages. For the wage statement issue, the court found substantial compliance and imposed a reduced penalty. For rest period and overtime-related issues, penalties were further reduced due to the technical nature of violations and corrective actions. The court awarded full penalties for the bonus pay issue. Regarding attorney fees, the court accepted the lodestar but applied a negative multiplier to account for inflated billing rates and the relatively straightforward nature of the litigation, awarding $733,440 in fees.The California Court of Appeal, Fourth Appellate District, Division Three, affirmed the judgment. The court held that the Labor Code does not mandate any particular method for reducing PAGA penalties, allowing trial courts discretion to apply reductions on a per employee or per pay period basis. The court found no abuse of discretion in the trial court’s calculation of penalties or application of a negative fee multiplier. The final judgment and fee award were affirmed. View "Taduran v. James R. Glidewell, Dental Ceramics" on Justia Law

Two journalists, both of Iraqi national origin, worked for a Virginia-based media company operating Arabic-language broadcasts targeting the Middle East and North Africa. The company maintained a mandatory Code of Ethics and social media policy requiring its journalists to remain neutral both in their reporting and in personal social media posts. Both journalists violated these policies by posting political content on social media, and after refusing direct orders to remove the posts, each was terminated. They alleged that the company enforced its policies more harshly against Iraqi journalists than non-Iraqi journalists and that their terminations were discriminatory under Title VII of the Civil Rights Act of 1964.Each journalist filed a separate lawsuit in the United States District Court for the Eastern District of Virginia, asserting claims of national origin discrimination. Both district courts granted the employer’s motions to dismiss, finding that the complaints failed to allege sufficient facts to plausibly support a claim of discrimination. Specifically, the courts found that neither plaintiff identified non-Iraqi employees who engaged in similarly insubordinate conduct—such as violating the same policies after direct warnings—yet were treated more favorably.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed both cases de novo. The court affirmed the district courts’ decisions, holding that the plaintiffs’ complaints did not state plausible claims for relief under Title VII. The court found that the facts alleged showed the plaintiffs were terminated for insubordination and repeated policy violations, not because of their national origin, and that the comparator allegations were too generalized to support an inference of discrimination. The court also held that the district court did not abuse its discretion in denying one plaintiff leave to amend, as no request for leave was made and amendment would have been futile. The judgments of dismissal were affirmed. View "Aljizzani v. Middle East Broadcasting Networks, Inc." on Justia Law

The appellant, Mark Justman, sought to recover accidental death life insurance benefits following the death of his wife, Karen Justman, who died from septic shock caused by a bacterial infection after eating raw oysters. At the time of her death, she was employed by Accenture LLP and was covered by both basic and optional accidental death and dismemberment (AD&D) insurance through a group plan. Prudential Insurance Company of America served as the Claims Administrator in 2021, while Accenture was designated as the Plan Administrator. After Prudential denied Justman’s claim on the grounds that the death was due to illness rather than an accident, Justman exhausted Prudential’s administrative appeals process without success.Justman then filed suit in the United States District Court for the Eastern District of Pennsylvania against both Prudential and Accenture, asserting wrongful denial of benefits under ERISA § 502(a)(1)(B) and breach of fiduciary duty for allegedly failing to provide required summary plan descriptions (SPDs). Prudential settled, leaving only Accenture as a defendant. The District Court dismissed Justman’s claims, finding insufficient factual allegations that Accenture controlled the benefits determination or failed to provide SPDs within statutory deadlines. The court allowed Justman to amend his complaint multiple times but found that further amendment would be futile and dismissed the case with prejudice.On appeal, the United States Court of Appeals for the Third Circuit affirmed the District Court’s rulings. The Third Circuit held that a proper defendant in an ERISA § 502(a)(1)(B) claim is the entity with authority over benefits determinations, which in this case was Prudential, not Accenture. The court also concluded that Justman’s claims regarding failure to provide SPDs and breach of fiduciary duty were not plausibly pleaded. The Third Circuit found no abuse of discretion in the denial of leave to amend or reconsideration and affirmed the dismissal with prejudice. View "Justman v. Accenture LLP" on Justia Law

Several unions representing approximately 800,000 federal civilian employees challenged an executive order issued by the President in March 2025. This order, Executive Order 14,251, invoked statutory authority to exclude various federal agencies and subdivisions from collective bargaining rights, citing national security concerns. The agencies affected included the Departments of State, Justice, Veterans Affairs, and others, and the order was accompanied by White House and Office of Personnel Management statements which asserted that union activities impeded national security functions. The unions alleged that the President’s action constituted unlawful retaliation against them for engaging in protected First Amendment activities, including lawsuits and public criticism of the Administration.The case originated in the United States District Court for the Northern District of California. There, the judge granted a preliminary injunction, enjoining the enforcement of Executive Order 14,251 on the grounds that the unions raised a serious question as to whether the order was issued in retaliation for their protected speech. The district court focused on statements in the White House’s supporting materials, finding these reflected hostility toward the unions’ activities. The court did not address the merits of the unions’ other claims.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the district court’s preliminary injunction. The Ninth Circuit agreed that the district court had jurisdiction to hear the unions’ claims, rejecting the government’s argument that the unions were required to pursue administrative remedies before the Federal Labor Relations Authority. However, the Ninth Circuit vacated the preliminary injunction. The appellate court held that, even if the unions made a prima facie showing of retaliation, the government demonstrated that the President would have issued the order regardless of the unions’ protected conduct, due to legitimate national security concerns. Because the unions did not show a likelihood of success or serious questions on the merits, the preliminary injunction was vacated. View "AMERICAN FEDERATION OF GOVERNMENT EMPLOYEES, AFL-CIO V. TRUMP" on Justia Law