Justia Labor & Employment Law Opinion Summaries

The plaintiff was employed as a restaurant hostess by two corporate entities. She alleged that her supervisor engaged in sexual harassment and retaliation, resulting in her constructive discharge. She brought claims under California’s Fair Employment and Housing Act (FEHA) for gender discrimination, sexual harassment, retaliation, and failure to prevent discrimination, harassment, and retaliation. The plaintiff sought to hold the sole owner of the corporate entities personally liable, arguing he was their alter ego.A jury trial was held in the Superior Court of Los Angeles County on liability, which resulted in verdicts against the two corporate defendants and awarded the plaintiff compensatory and punitive damages. The alter ego claim against the owner was tried separately to the court. The trial court applied the common law presumption of corporate separateness, requiring the plaintiff to prove that the corporations’ distinct identities should be disregarded. The court found the plaintiff failed to meet her burden and issued judgment in favor of the owner. The plaintiff appealed, contending that FEHA should alter the presumption and favor alter ego liability.The Court of Appeal of the State of California, Second Appellate District, Division One, reviewed the legal question de novo. The court held that FEHA does not modify or abrogate the common law presumption of corporate separateness. It found no statutory language, legislative history, or case law that clearly or unequivocally indicated a legislative intent to alter the presumption. The court concluded that public policy and FEHA’s purpose do not require a contrary presumption favoring alter ego liability. The judgment for the owner was affirmed, and the parties were directed to bear their own costs on appeal. View "Villasenor v. Schneiter" on Justia Law

A teachers’ association and several former teachers sued a school district after the district declined to pay retroactive salary increases and stipends to teachers who had resigned before the district approved a collective bargaining agreement (CBA). The CBA, negotiated between the teachers’ association and the school district, provided for retroactive salary adjustments and stipends for the period July 1, 2022 through June 30, 2024. The six former teachers had worked during the period covered by the retroactive provisions but resigned before the CBA’s approval in August 2023. The district paid the retroactive benefits only to those who remained employed as of the approval date, excluding the former teachers.The plaintiffs filed a verified petition for writ of mandate in the Superior Court of San Bernardino County, arguing that Education Code section 45028 required uniform pay for teachers with equivalent training and experience, absent a negotiated exception. They contended the CBA applied retroactively to all teachers who worked during the relevant period, including those who had since resigned. The district argued that only current employees and certain former employees (laid off or retired) were covered, and relied on California Teachers Assn. v. Governing Bd. of Hilmar Unified School Dist. to support its interpretation. The trial court denied the petition, finding the CBA did not expressly include former employees and concluding that only active teachers were entitled to retroactive increases.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case de novo. It held that because the CBA did not restrict retroactive benefits to current employees and no negotiated criterion excluded resigned teachers, the district violated section 45028’s uniformity requirement by denying the former teachers retroactive payments. The judgment was reversed, and the trial court was directed to issue a writ compelling the district to pay the retroactive salary adjustments and stipends, plus associated employer contributions, to the former teachers. View "Trona Teachers Assn. v. Bd. of Trust. Trona Jt. Uni. Sch. Dist." on Justia Law

An employee who worked for a company from May 2021 until his termination in January 2024 signed an arbitration agreement at the start of his employment. This agreement required any employment-related disputes to be resolved through binding arbitration on an individual basis, with a waiver of class and collective actions. In November 2024, the employee notified the Labor and Workforce Development Agency (LWDA) of alleged Labor Code violations by his employer. After the LWDA did not respond within the statutory period, he became authorized to pursue a civil action for penalties under the Private Attorneys General Act (PAGA), acting as a proxy for the state. He subsequently filed a complaint in Stanislaus County Superior Court asserting only nonindividual PAGA claims—claims on behalf of other aggrieved employees and not for his own individual recovery—for various Labor Code violations.The employer responded by filing a motion to compel arbitration, arguing that PAGA required the inclusion of individual claims and that the arbitration agreement should apply. The Superior Court denied this motion, noting procedural irregularities and emphasizing that binding precedent allowed PAGA actions consisting solely of nonindividual claims. The court referenced a split in authority on whether PAGA actions could be limited to nonindividual claims, but ultimately relied on decisions holding such actions permissible, especially after recent statutory amendments.On appeal, the California Court of Appeal, Fifth Appellate District, affirmed the trial court’s decision. The appellate court held that, under the version of PAGA effective July 1, 2024, an aggrieved employee may bring a PAGA action consisting only of nonindividual claims and that these claims are not subject to arbitration, even if an arbitration agreement exists. The court further found that the statutory amendments did not require an employee to include individual claims, and that denying arbitration of nonindividual PAGA claims does not violate federal or state policy favoring arbitration. The denial of the motion to compel arbitration was affirmed. View "Castillo v. Belkorp AG, LLP" on Justia Law

The plaintiff, a former employee, brought claims against her employer alleging discrimination and retaliation under the California Fair Employment and Housing Act (FEHA), as well as wrongful discharge and breach of contract. After the employer prevailed on a motion for summary judgment, the trial court entered judgment in its favor, stating that the employer as the prevailing party could recover costs upon filing a memorandum of costs. The employer submitted a memorandum seeking over $15,000 in costs, which the trial court approved in an amended judgment when the plaintiff did not timely object.Following this, the plaintiff appealed solely on the issue of costs, not contesting the dismissal of her claims. She argued that, under FEHA, a prevailing defendant may only recover costs if the court expressly finds the action was frivolous, unreasonable, or groundless, as required by Government Code section 12965, subdivision (c)(6). The employer countered that the trial court’s judgment sufficiently implied such a finding, and that the plaintiff had waived her objections by not responding earlier. The Court of Appeal examined whether the trial court followed the proper procedure for awarding costs in FEHA cases.The Court of Appeal of the State of California, First Appellate District, Division Four, held that a prevailing defendant in a FEHA case cannot be awarded costs absent an express finding that the plaintiff’s action was frivolous, unreasonable, or groundless. The court found no such finding in the record, and determined that the trial court appeared to have applied the general rule for cost awards, not the heightened FEHA standard. Therefore, the appellate court reversed the amended judgment as to costs and remanded for further proceedings to determine whether the employer is entitled to costs under the correct legal standard. The plaintiff was awarded costs on appeal. View "San Diego-Tomas v. Aspire Bakeries, LLC" on Justia Law

A property management company in Los Angeles employed an individual from April 2023 to September 2024. As part of the hiring and onboarding process, the employee was required to sign an arbitration agreement that mandated all employment-related claims be resolved through binding arbitration and included a waiver of class and representative actions. The employee later filed a class action lawsuit against the employer, alleging wage-and-hour violations and unfair business practices.The employer responded by filing a motion in the Superior Court of Los Angeles County to compel arbitration of the employee's individual claims, dismiss the class claims, and stay the action. The employer made clear that the Federal Arbitration Act (FAA) did not apply and relied on California law. The employee opposed, arguing that under California Labor Code section 432.6, it is illegal for an employer to require an employee to sign an arbitration agreement as a condition of employment unless the agreement is enforceable under the FAA. The Superior Court denied the employer’s motion, finding that the arbitration agreement was required as a condition of employment, thus violating section 432.6, and that, since the FAA did not apply, the agreement was unenforceable under California law.On appeal, the Court of Appeal of the State of California, Second Appellate District, Division Four, affirmed the trial court’s order. The appellate court held that, under California law, an arbitration agreement required as a condition of employment in violation of section 432.6 is unenforceable unless it is otherwise enforceable under the FAA. Because the parties agreed the FAA did not apply and the agreement was required as a condition of employment, the employer could not enforce it. The court affirmed the denial of the motion to compel arbitration. View "Molina v. Triumph Residential Services, Inc." on Justia Law

Douglas Smith, a long-term high school science teacher, refused to comply with his employer’s COVID-19 vaccination mandate due to his religious beliefs. The Burbank Unified School District granted his request for a religious exemption but placed him on indefinite unpaid leave, stating that no other accommodation could be provided without undue hardship. Smith requested alternative accommodations such as masking and weekly PCR testing, but the District denied these, citing concerns about health and safety for staff and students. After a year on unpaid leave, Smith found employment at a school without a vaccine mandate and eventually resigned from the District.The Superior Court of Los Angeles County reviewed Smith’s claims under the Fair Employment and Housing Act (FEHA), which included religious discrimination, failure to prevent discrimination, and retaliation. The District moved for summary judgment, arguing that unpaid leave was the only reasonable accommodation that did not pose an undue hardship, given the nature of Smith’s teaching responsibilities and the operational impacts of allowing unvaccinated teachers on campus. The trial court found that Smith established a prima facie case for religious discrimination, but concluded the District met its burden in showing that alternative accommodations were not feasible, and thus granted summary judgment in favor of the District.The Court of Appeal of the State of California, Second Appellate District, Division Eight, independently reviewed the summary judgment. It held that, under FEHA, unpaid leave can be a reasonable accommodation where other options pose an undue hardship, especially given the District’s obligation to protect health and safety during the pandemic. The Court affirmed the trial court’s judgment, specifying that the parties would bear their own costs on appeal. View "Smith v. Burbank Unified School Dist." on Justia Law

Alexander Bauer, an employee of Evans Plumbing, Inc., was injured on a construction site after falling from a second-story balcony. He alleged that Scott Myers and Sons Roofing and Construction, LLC had negligently reinstalled a temporary wood railing, which caused his fall. Bauer received workers’ compensation benefits for his injuries and subsequently filed a civil suit against Myers for negligence, recklessness, and gross negligence. Myers argued that because both it and Evans were contracted by Stack Construction, LLC, they were co-employees under Idaho’s Worker’s Compensation Law and therefore immune from suit under the exclusive remedy rule.The District Court of the Fifth Judicial District, Twin Falls County, reviewed Myers’ motion for summary judgment. The court determined that Myers was a subcontractor of Stack based on the contract language, making Myers Stack’s employee for purposes of the Act. As a result, the court held that Myers was entitled to exclusive remedy immunity and dismissed Bauer’s claims.On appeal, the Supreme Court of the State of Idaho examined whether Myers’ status as a subcontractor or independent contractor was determinative for exclusive remedy immunity. The court clarified that the right to control test, not mere contract labels, must be applied to distinguish between employees and independent contractors under the Act. The court found that the district court erred by failing to apply this test. The Supreme Court reversed the district court’s grant of summary judgment and remanded the case for further proceedings, holding that the right to control test must be used to resolve whether Myers was an employee or independent contractor for purposes of Idaho’s Worker’s Compensation Law. View "Bauer v. Scott Myers and Sons Roofing and Construction" on Justia Law

A sanitation worker employed by a District of Columbia government agency sustained a right ankle injury in 1993 after stepping into an uncovered drain while performing his duties. The injury led to ongoing physical problems, and the worker received temporary total disability benefits for an extended period. As the statutory cap on temporary benefits approached in 2020, he sought a determination of permanent disability status. Medical evidence was mixed: while government physicians attributed his ongoing impairments to factors unrelated to the original injury, his treating doctors linked his broader decline to the workplace accident.An Administrative Law Judge (ALJ) concluded that the worker’s only compensable permanent injury was to his right ankle, a scheduled body part under the Comprehensive Merit Personnel Act (CMPA), and awarded a schedule award. The worker appealed to the Compensation Review Board (CRB), arguing for a permanent total disability (wage-loss) award. The CRB disagreed with the ALJ’s approach, holding that the worker could qualify for a wage-loss award if he could demonstrate permanent total disability, even if the disability stemmed from a scheduled body part, and remanded for further proceedings. On remand, the ALJ awarded a wage-loss benefit, which the CRB affirmed. The government agencies then sought review by the District of Columbia Court of Appeals.The District of Columbia Court of Appeals held that under the CMPA, a claimant who is permanently totally disabled due to an injury to a scheduled body part is not limited to a schedule award and may seek a wage-loss award if they can prove entitlement. The court vacated the CRB's order and remanded for the ALJ to determine eligibility for a wage-loss award under the proper statutory factors. View "District of Columbia Department of Public Works v. District of Columbia Department of Employment Services" on Justia Law

An IT analyst who is openly gay was hired by a large, Catholic-affiliated nonprofit based in Maryland. At the time of hiring, he was told his husband would be covered under the organization’s dependent health benefits. However, several months after his employment began, the organization informed him that providing benefits to his same-sex spouse was contrary to its religious beliefs and terminated those benefits. The employee declined alternative compensation and ultimately resigned from the organization after several years.The employee sued in the United States District Court for the District of Maryland, bringing claims under federal and state employment discrimination laws, including Title VII, the Equal Pay Act, and the Maryland Fair Employment Practices Act (MFEPA). The district court granted summary judgment for the employee on the Title VII and Equal Pay Act claims and, after certifying questions to the Maryland Supreme Court regarding the scope of the MFEPA’s religious exemption, held a bench trial and entered judgment for the employee on the remaining MFEPA claim. The parties stipulated to damages, but the employer reserved the right to appeal on liability.The United States Court of Appeals for the Fourth Circuit reviewed the employer’s statutory and constitutional defenses. The court held that Title VII’s religious employer exemption does not shield religious organizations from liability for discrimination based on sex, even if the employment decision is rooted in religious belief. Similarly, under MFEPA, the court found the exemption applies only to employees whose duties directly further the core mission of the organization; the employee’s roles did not meet this test. The court also held that the Religious Freedom Restoration Act does not apply to suits between private parties. Constitutional arguments based on the First Amendment’s Religion Clauses and church autonomy doctrine were rejected as grounds for immunity. The Fourth Circuit affirmed the district court’s judgment on Title VII and MFEPA claims and dismissed the Equal Pay Act appeal as moot. View "Doe v. Catholic Relief Services" on Justia Law

The plaintiff, who had several drug-related convictions dating back more than a decade, applied for an office assistant position at a university. After a conditional job offer, the university initiated a background check, during which the plaintiff briefly worked part-time. The background check revealed the plaintiff's criminal history. The university sent a notice advising that his convictions might disqualify him, granting five business days to submit evidence of rehabilitation or challenge the findings. The plaintiff responded with hostile emails but did not provide evidence of rehabilitation. The university ultimately denied him the position, citing his failure to respond substantively and his unprofessional communications.The plaintiff filed suit in the Superior Court of Los Angeles County, asserting claims under the California Fair Employment and Housing Act (FEHA), including discrimination under the Fair Chance Act (FCA), retaliation, and failure to prevent retaliation. The trial court granted summary adjudication for the university on the retaliation and failure to prevent retaliation claims, finding the plaintiff did not engage in protected activity and no causal nexus existed between his complaints and the adverse employment action. The court also found that while the university failed to provide the full five-day response period required by the FCA, the plaintiff had to prove this procedural error caused him harm. The issue of harm was tried before a jury, which found the university would have made the same decision even if the plaintiff had been given the full response period.On appeal, the California Court of Appeal, Second Appellate District, Division Two, affirmed the trial court’s judgment. The Court held that the plaintiff did not establish a prima facie case for retaliation or failure to prevent retaliation, and that the university properly followed FCA procedures except for the response period, but the procedural violation did not cause harm. The Court clarified that courts are not to second-guess the employer’s individualized assessment under the FCA and that actual harm must be shown for recovery. View "McInerney v. Regents of the Univ. of California" on Justia Law