Justia Labor & Employment Law Opinion Summaries

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

A 72-year-old employee was terminated from her job at a convenience store following an incident in which she was confronted by an armed robber during her shift. The robber, after demanding cigarettes, approached the employee with knives, prompting her to extend her arms defensively. The robber then took the cigarettes and left. Subsequently, the employer fired the employee for violating its policy against confronting shoplifters. The employee sued, alleging wrongful discharge for exercising her right to self-defense under Colorado law and claiming the termination violated public policy.After the case was removed to the United States District Court for the District of Colorado, the employer moved for summary judgment, arguing both that the employee had not acted in self-defense and that Colorado did not recognize self-defense as a public-policy exception to at-will employment. The district court granted summary judgment for the employer, finding no such public-policy exception. On appeal, the Tenth Circuit reversed and remanded, identifying unresolved factual issues regarding whether the employee had acted in self-defense and whether that was the reason for her termination. The district court then denied summary judgment, finding disputed material facts suitable for jury determination. The employee requested certification of a legal question to the Supreme Court of Colorado, which was granted.The Supreme Court of Colorado, en banc, answered the certified question in the affirmative. The Court held that both Colorado’s statutory and constitutional rights to self-defense constitute a clear public policy, and that employees cannot be lawfully terminated for lawfully exercising self-defense in response to an unprovoked attack at work. The Court recognized a narrow public-policy exception to the at-will employment doctrine for such circumstances and returned the case to the district court for further proceedings. View "Moreno v. Circle K Stores, Inc." on Justia Law

Several patients sustained work-related injuries and began receiving workers’ compensation benefits. Their treating physicians, Drs. Purewal and Jalali, wrote prescriptions that were filled by 700 Pharmacy. The State Workers’ Insurance Fund, acting as the insurer for the patients’ employers, refused to pay for these prescriptions, arguing that the Anti-Referral Provision of the Workers’ Compensation Act (WCA) barred payment because the physicians had a financial interest in the pharmacy and thus engaged in unlawful self-referrals.A hearing officer from the Bureau of Workers’ Compensation Fee Review Hearing Office addressed the Pharmacy’s fee review applications. The hearing officer found that the Anti-Referral Provision made it unlawful for providers to refer patients for “goods or services” if they had a financial interest in the receiving entity. Relying on state regulations and the federal Stark Law, the hearing officer determined that prescription drugs and pharmaceutical services fell within the meaning of “goods or services,” thus denying the Pharmacy’s claims for payment. The Commonwealth Court affirmed, finding that the phrase “goods or services” acted as a catchall, including prescription drugs and professional pharmaceutical services within the self-referral ban.The Supreme Court of Pennsylvania reviewed these consolidated appeals. Applying principles of statutory interpretation, the court held that the Anti-Referral Provision’s prohibition on self-referrals is limited to the eight specifically enumerated categories of services and does not extend to prescription drugs or professional pharmaceutical services. The court reasoned that the statute’s plain language and structure do not support reading “goods or services” as a catchall encompassing unlisted services. The court reversed the Commonwealth Court and remanded for proceedings consistent with its decision. The main holding is that the Anti-Referral Provision does not bar payment for prescription drugs and pharmaceutical services provided under these circumstances. View "700 Pharm. v. Bur of WC" on Justia Law

During the COVID-19 pandemic, the Superintendent of Hamtramck Public Schools took voluntary medical leave under the Family and Medical Leave Act (FMLA). When she prepared to return, the school district placed her on paid administrative leave pending an investigation into alleged misconduct. While on leave, she filed charges of discrimination with government agencies and was not allowed to return to her duties for over a year. She alleged that these actions were the result of retaliation and discrimination after she had involuntarily reassigned several teachers, which had sparked conflict with the school board and teachers’ union.While still on paid leave, the Superintendent filed suit in the United States District Court for the Eastern District of Michigan against the school district, several board members, and the teachers’ union, alleging multiple claims including discrimination based on disability, sex, and national origin, as well as retaliation. She attempted to amend her complaint multiple times. The district court denied her motion to file a Fourth Amended Complaint, holding that the proposed amendments were futile, and granted the defendants’ motions to dismiss the original complaint with prejudice. She then appealed.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s denial of leave to amend de novo. The appellate court held that the district court erred in finding that her proposed claims for FMLA retaliation and Title IX sex discrimination were futile. The Sixth Circuit concluded that her allegations plausibly stated claims under both statutes, applying the correct legal standards. The appellate court vacated the district court’s dismissal, reversed its futility determination, and remanded the case so the plaintiff could proceed with her amended complaint. View "Ahmed v. Hamtramck Public Schools" on Justia Law

Hourly workers at a brewing company’s Williamsburg, Virginia facility alleged that the company failed to pay them for various pre- and post-shift activities, including donning and doffing personal protective equipment, complying with COVID-19 protocols, attending shift-handoff meetings, and handling tools. The company used an electronic badge system for entry but compensated employees based on scheduled shift hours, not actual time on site. Different employees performed these tasks at different times and locations, with some tasks done at home, some during shift hours, and some on the premises outside shift hours. The company committed to pay for all hours actually worked, provided employees notified management about extra time worked.The plaintiffs filed suit under the Virginia Wage Payment Act, the Virginia Overtime Wage Act, and the Fair Labor Standards Act, seeking class certification for wage and hour claims. The United States District Court for the Eastern District of Virginia certified the class, finding that common questions predominated, such as whether the company’s policy resulted in uncompensated mandatory work. The district court’s class definition included all hourly employees at the facility within the relevant timeframe, and it denied the company’s motion to decertify the FLSA collective action.The United States Court of Appeals for the Fourth Circuit reviewed the case. It held that the district court erred by certifying the class without adequately considering significant variations among employees regarding their pre- and post-shift activities, the timing and location of those activities, and the applicable legal standards over time. The appellate court found that the class definition was overly broad and failed to account for differences among employees. Consequently, the Fourth Circuit vacated the class certification order and remanded for further proceedings, allowing the district court to consider narrower subclasses or to deny certification entirely. The appeal regarding the FLSA collective action was dismissed for lack of jurisdiction. View "Overby v. Anheuser-Busch, LLC" on Justia Law

Three named plaintiffs, all working for Schlumberger in oilfield drilling positions, challenged their employer’s compensation system under the Fair Labor Standards Act. Their pay structure included both a fixed, predetermined salary paid biweekly and substantial additional daily or activity-based payments, which often comprised the majority of their earnings. The plaintiffs regularly worked more than forty hours per week but did not receive overtime pay. They brought a collective action, arguing that their hybrid compensation arrangement did not meet the requirements for the Fair Labor Standards Act’s “salary basis” exemption, and therefore they were entitled to overtime pay.The United States District Court for the Western District of Texas denied Schlumberger’s motion for partial summary judgment, finding that material factual disputes prevented judgment as a matter of law on whether the plaintiffs were paid on a salary basis. The court allowed notice to a proposed collective of Directional Drillers but denied notice to another group, and it later certified an interlocutory appeal due to the unsettled state of the law regarding hybrid pay schemes.On interlocutory appeal, the United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of summary judgment de novo. The Fifth Circuit held that the hybrid compensation plan, which included a guaranteed, predetermined salary paid on a weekly or less frequent basis, satisfied the regulatory requirements for the salary basis exemption under 29 C.F.R. § 541.602(a), regardless of additional day-based or incentive payments. The court reversed the district court’s decision and ordered summary judgment for Schlumberger as to the named plaintiff Guilbeau, finding him overtime-exempt. However, the court remanded the case for further proceedings regarding other collective members, as their exemption status required additional individualized determinations. View "Guilbeau v. Schlumberger Technology" on Justia Law

A tenured professor at a university was terminated in 2022 following a classroom incident where students objected to terminology used in an assigned reading and a subsequent discussion of LGBTQ+ rights in Latin America. The professor alleged that her Department Chair encouraged students to submit complaints against her, and that there was a coordinated effort to undermine her reputation. After complaints were submitted, the university held a student meeting about the professor’s conduct, restricted some of her duties, and ultimately terminated her employment "for cause," citing continued misconduct and failure to fulfill faculty responsibilities. The professor appealed her termination to the Faculty Hearing Board, which upheld the decision by a narrow margin, citing procedural issues but attributing them to outdated dismissal procedures rather than prejudice. The Board found her teaching was not culturally responsive and noted longstanding concerns about her interaction with students. The minority opinion of the Board disagreed, finding the process unfair. The university’s Board of Trustees unanimously affirmed the termination.The professor then filed a verified complaint in Rhode Island Superior Court against the university, its Board of Trustees, and several colleagues. She alleged violations of federal and state anti-discrimination laws, as well as state tort and contract claims related to her termination. The university removed the case to the United States District Court for the District of Rhode Island and moved to dismiss. The district court dismissed the federal and state anti-discrimination claims for failure to state a claim, finding insufficient factual allegations connecting protected characteristics to the termination. The court declined to exercise supplemental jurisdiction over the state claims and remanded them to state court.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s judgment. The First Circuit held that the professor failed to plead sufficient facts to make her discrimination, hostile work environment, and retaliation claims plausible, and found no error in the district court’s consideration of certain documents. View "Crawford v. Salve Regina University" on Justia Law

A law firm filed a class action complaint in San Francisco Superior Court on behalf of an employee and similarly situated individuals, alleging wage and hour violations against several beverage distribution companies. This followed the same firm’s earlier, nearly identical class action complaint in Los Angeles County Superior Court, with overlapping claims and parties. The San Francisco action was amended to add claims under the Private Attorneys General Act. After the defense raised concerns about duplicative litigation, the defendants moved to stay the San Francisco case, arguing that the later-filed action was duplicative and should be stayed under the doctrine of exclusive concurrent jurisdiction.The San Francisco Superior Court found substantial overlap between the two cases and granted the stay. In its tentative ruling, the court identified significant misconduct by the plaintiff’s attorneys, including fabricated legal citations and misrepresentations in their opposition to the motion to stay. The court issued an order to show cause regarding sanctions under Code of Civil Procedure section 128.7 and the attorneys’ ethical duties. The firm’s attorneys and a contract attorney responded, denying intentional misconduct and attributing errors to reliance on the contract attorney’s work and alleged citation-checking issues with legal research software. However, the court found their explanations lacking credibility, emphasized their responsibility as counsel of record, and imposed monetary sanctions jointly and severally against the firm and three attorneys, payable to both the defendants and the court.The California Court of Appeal, First Appellate District, Division Two, reviewed the attorneys’ appeal of the sanctions order. The court held that the attorneys had forfeited their procedural challenges by not raising them in the trial court and found no abuse of discretion in imposing sanctions for filing a pleading with fabricated authority and failing to meet ethical and professional obligations. The appellate court affirmed the sanctions order. View "Quinteros v. Harbor Distributing" on Justia Law