Justia Labor & Employment Law Opinion Summaries

The plaintiff was employed as a Change Analyst by a utility company, with responsibilities requiring travel throughout a multi-state service territory. Amid the COVID-19 pandemic in July 2020, the plaintiff took a vacation to Ohio and California and, upon its conclusion, sought to work remotely from outside his designated territory. Although company policy permitted temporary remote work from outside the service area, it required supervisory approval, which the plaintiff had not obtained. When notified by the company’s Human Resources Director that he would be deemed to have resigned unless he immediately returned to his territory, the plaintiff, for the first time, disclosed a preexisting condition and requested a reasonable accommodation to work remotely, citing COVID-19 risks. He provided a brief doctor’s note but did not supply further documentation or assert any reason he could not work remotely from within his service territory. After failing to return or provide sufficient medical documentation, his employment was terminated.The United States District Court for the District of Massachusetts granted summary judgment in favor of the employer on the plaintiff’s claims of retaliation under Massachusetts law and the Family and Medical Leave Act, finding no causal connection between the plaintiff’s protected activity and his termination. The district court determined that the employer had already decided to terminate the plaintiff before he engaged in any protected conduct.Reviewing the case de novo, the United States Court of Appeals for the First Circuit affirmed. The court held that the clear chronological order of events precluded any finding that the plaintiff’s request for accommodation or invocation of FMLA rights caused his termination. The court found that the adverse employment action was determined before the protected activity occurred and that the employer’s actions showed consideration for, rather than retaliation against, the plaintiff’s rights. The grant of summary judgment was affirmed in full. View "Harris v. National Grid USA Service Company, Inc." on Justia Law

Two married tenured professors at California State University, Chico alleged that they were subjected to harassment and discrimination by their department chair, with one professor experiencing conduct targeted at her gender and Korean ancestry. Despite their reports to university administration, the university did not intervene. As a result, one professor suffered serious mental health consequences, leading their doctor to recommend that she not work in the same environment as the chair. The university’s lack of response allegedly forced both professors to resign and accept positions at another university. After their resignation, the university initiated an investigation into one professor for an alleged violation of student privacy laws and communicated these allegations to the new employer, which the professors claimed was intended to sabotage their new employment. There were also alleged delays in transferring their lab equipment.The professors filed suit in the Superior Court of Butte County, asserting, among other claims, retaliation and whistleblower retaliation under California law. The university filed a special motion to strike these two causes of action under California’s anti-SLAPP statute, arguing that the claims were based in part on communications protected by the statute. The trial court denied the motion, finding the university’s actions involved an official proceeding but also concluding that the professors demonstrated a likelihood of prevailing on their claims.The California Court of Appeal, Third Appellate District, reviewed the case and affirmed the trial court’s denial of the anti-SLAPP motion. The appellate court held that the university failed to carry its burden to show that all actions underlying the challenged causes of action were protected activity. The court clarified that the presence of some protected communications within the allegations does not mean the entire cause of action arises from protected activity. The judgment denying the anti-SLAPP motion was therefore affirmed. View "Pechkis v. Trustees of the Cal. State University" on Justia Law

Several former executives and employees of a storage company were terminated or allegedly constructively terminated and subsequently brought claims against the company and its principals for wrongful termination, retaliation, harassment, and related causes of action. The company, in turn, sued two of the former executives, alleging breach of contract and misuse of confidential information, including forwarding company emails to personal accounts. The emails at issue contained communications from the company’s legal counsel and were allegedly attorney-client privileged. After their terminations, the former employees provided these emails to their attorney for use in their lawsuits against the company.The Superior Court of Orange County considered the company’s motions to disqualify the law firm representing the former employees, based on the firm’s possession and use of the disputed emails. The court found the emails were privileged and that the company held the privilege. However, it denied the motions, reasoning that the employees had been intended recipients of the emails, that privileged content would not be used to the company’s disadvantage, and that the emails were central to both parties’ claims.On appeal, the California Court of Appeal, Fourth Appellate District, Division Three, held that the trial court abused its discretion. The appellate court determined that the proper analytical framework for attorney disqualification, as set forth in State Comp. Ins. Fund v. WPS, Inc., should apply not only to inadvertently disclosed privileged material but also to situations where an attorney receives material that was impermissibly taken from the privilege holder without authorization. The appellate court found the trial court erred in its legal analysis, failed to properly apply the relevant standard regarding future prejudice, and made unsupported findings. The court reversed the trial court’s orders and remanded for reconsideration of the disqualification motions under the correct legal standards. View "Guardian Storage Centers v. Simpson" on Justia Law

A former employee brought a class action lawsuit against her former employer, alleging violations of California wage and hour laws and other employment-related statutes. After the complaint was filed, the employer entered into approximately 954 individual settlement agreements with other employees, providing cash payments in exchange for releases of claims. The plaintiff did not sign such an agreement but moved for class certification and later sought to invalidate the individual settlements on the grounds of fraud and coercion, arguing the employer misrepresented the litigation’s status and the scope of the settlements.The Superior Court of San Bernardino County partially granted the motion, ruling that the individual settlement agreements were voidable due to fraud or duress and ordered that a curative notice be sent to affected employees. The court’s notice advised that employees could rescind their agreements and join the class action, but did not require immediate repayment of settlement funds to the employer. The employer objected, arguing the notice should have informed employees that they might be required to return the settlement money if they rescinded and the employer ultimately prevailed in the litigation. The trial court declined to include this language, instead following certain federal cases that allowed offsetting the settlement amount against any recovery but did not require repayment before judgment.The California Court of Appeal, Fourth Appellate District, Division Two, reviewed the case on a writ. The court held that under California Civil Code sections 1689, 1691, and 1693, employees who rescind their settlement agreements may be required to repay the consideration they received, but repayment can be delayed until final judgment unless the employer shows substantial prejudice from delay. The court also found the trial court retains equitable authority to adjust repayment at judgment under section 1692. The appellate court directed the trial court to reconsider the curative notice in accordance with these principles. Each side was ordered to bear their own costs on appeal. View "The Merchant of Tennis, Inc. v. Superior Court" on Justia Law

Energy Harbor Nuclear Corporation operated a power plant in Pennsylvania, where its employees were represented by the International Brotherhood of Electrical Workers, Local 29. After a 2021 dispute over health care benefit contributions, an arbitrator found that Energy Harbor had underpaid and ordered it to make additional contributions for 2021. Later, the parties entered into a new collective-bargaining agreement (CBA) on October 1, 2021, which included a broad arbitration clause and a merger clause voiding prior agreements not incorporated into the new CBA. When the union later alleged that Energy Harbor similarly underpaid contributions for 2022, it filed a grievance, contending that Energy Harbor failed to adjust 2022 contributions as required by the prior arbitration award.The United States District Court for the Western District of Pennsylvania reviewed the matter after the union sought to compel arbitration. The District Court, adopting a magistrate judge’s recommendation, held that the broad arbitration clause in the new CBA covered the dispute regarding the 2022 contributions. The court reasoned that because the grievance referenced the contribution-increase provision of the CBA, the dispute was subject to arbitration, and found no evidence that the parties intended to exclude such claims from arbitration.On appeal, the United States Court of Appeals for the Third Circuit reversed. The Third Circuit held that, although the arbitration clause was broad, the union’s grievance regarding 2022 contributions did not arise under the new CBA but instead relied on the prior arbitration award, which was not incorporated into the new agreement. The court concluded that the dispute had “nothing to do with” the rights under the CBA because there was no evidence of a required increase in Energy Harbor’s health care plan costs from 2021 to 2022. The Third Circuit reversed and remanded with instructions to grant summary judgment for Energy Harbor. View "International Brotherhood of Electrical Workers Local Union 29 v. Energy Harbor Nuclear Corp" on Justia Law

On the evening of October 2, 2024, an employee was jogging in the parking lot of a Walmart distribution center when he was struck by a tractor-trailer driven by another Walmart employee who was performing his job duties. Both individuals were employed by Walmart at the time of the incident. The injured employee subsequently filed suit against Walmart and the co-employee, seeking damages under various tort theories, including negligence, wantonness, and co-employee liability.The case was first heard in the Pike Circuit Court. Walmart responded to the complaint by raising the defense that the employee’s claims were barred by the exclusive-remedy provisions of Alabama’s Workers’ Compensation Act, as the injured employee had already accepted workers’ compensation and medical benefits for the incident, while represented by counsel, and had not reserved any right to pursue other remedies. The trial court granted summary judgment in favor of Walmart and the co-employee, finding the acceptance of workers’ compensation benefits estopped the employee from pursuing additional remedies and that there was no evidence of willful conduct by the co-employee.On appeal, the Supreme Court of Alabama reviewed the trial court’s decision de novo. The Supreme Court affirmed the summary judgment, holding that the employee’s acceptance of workers’ compensation benefits constituted an election of remedies that precluded him from seeking damages through a civil tort action against Walmart. The Court also held that, under Alabama law, co-employees are immune from civil liability except in cases of willful conduct, and the plaintiff failed to present substantial evidence of willful conduct by the co-employee. Thus, the Supreme Court affirmed the trial court’s summary judgment in favor of both Walmart and the co-employee. View "Duke v. Walmart, Inc." on Justia Law

A former high-level employee left her position at a company after receiving incentive equity agreements that included non-compete, non-solicitation, and confidentiality provisions. She subsequently joined a competitor. The company alleged that she breached those provisions by working for the competitor and that, in the short time since her move, at least five important clients had also moved to the competitor, an unusual loss rate for the business. The employee’s role at her former employer was not confined to a single region, and she was involved in high-level strategic decisions affecting company operations nationwide. The restrictive covenants at issue included an 18-month, nationwide non-compete and were supported by incentive units that would vest over time or upon sale of the company.After the company filed suit, the Court of Chancery of the State of Delaware denied a temporary restraining order but expedited proceedings. The defendants moved to dismiss. The company amended its complaint with more detailed allegations. The Court of Chancery granted the motion to dismiss, holding that the non-compete was unenforceable due to its breadth and the minimal value of the consideration provided, and that the allegations of breach of the non-solicitation and confidentiality provisions were conclusory. It also dismissed related tortious interference claims.On appeal, the Supreme Court of the State of Delaware reviewed the dismissal de novo. The Supreme Court held that the Court of Chancery improperly drew inferences against the employer at the pleading stage and failed to credit factual allegations supporting the claims. The Supreme Court found it was reasonably conceivable that the non-compete, non-solicitation, and confidentiality provisions could be enforceable, and that the complaint sufficiently alleged breaches. The Supreme Court reversed and remanded for further proceedings, limiting its holding to the adequacy of the pleadings and expressing no view on ultimate enforceability. View "Payscale Inc. v. Norman" on Justia Law

An individual brought suit against her employer, a Delaware corporation, alleging various claims of discrimination based on age and disability under state and federal law. The employment contract between the parties included an arbitration provision, specifying that all employment-related disputes were to be resolved through binding arbitration under the Federal Arbitration Act (FAA), in accordance with procedures outlined in the California Arbitration Act. The contract also incorporated JAMS rules, which assign the arbitrator authority to resolve issues regarding the validity and enforceability of the arbitration agreement itself.The United States District Court for the Southern District of California reviewed the employer’s motion to compel arbitration. The court recognized that the arbitration agreement, by incorporating the JAMS rules, delegated questions about the agreement's validity to an arbitrator. However, relying on California state court decisions, the district court determined that the presence of a severability clause—allowing a court or other competent body to sever invalid provisions—negated a “clear and unmistakable” delegation to the arbitrator. Consequently, the district court concluded it was responsible for determining validity and found the arbitration agreement unconscionable, denying the motion to compel arbitration.The United States Court of Appeals for the Ninth Circuit reviewed the district court’s judgment de novo. The appellate court held that the contract’s delegation clause, by clearly incorporating JAMS rules, unmistakably reserved the issue of the arbitration agreement’s validity for the arbitrator. The existence of a severability clause did not undermine this delegation. The Ninth Circuit reversed the district court’s denial of the motion to compel arbitration, vacated its unconscionability judgment, and remanded with instructions to compel arbitration and stay the case pending arbitration. View "SANDLER V. MODERNIZING MEDICINE, INC." on Justia Law

The plaintiffs in this case were former hourly employees of Amazon who worked in the company’s Illinois distribution warehouses. In March 2020, in response to the COVID-19 pandemic, Amazon required all hourly, nonexempt employees to undergo mandatory medical screenings before clocking in for their shifts. These screenings included temperature checks and health questions, and typically took 10 to 15 minutes, sometimes causing employees to clock in after their scheduled start time. Plaintiffs alleged that Amazon violated wage laws by not compensating employees for the time spent in these screenings, arguing the screenings were necessary to their work and primarily benefited Amazon by enabling continued operations during the pandemic.The plaintiffs initially filed a class-action complaint in the Circuit Court of Cook County, asserting claims under both the federal Fair Labor Standards Act (FLSA) and the Illinois Minimum Wage Law. Amazon removed the case to the United States District Court for the Northern District of Illinois, which dismissed the complaint. The district court held that the FLSA claims were barred by the Portal-to-Portal Act (PPA), which excludes certain preshift activities from compensable time, and summarily concluded the state law claims failed for the same reason. Plaintiffs appealed to the United States Court of Appeals for the Seventh Circuit, which certified to the Supreme Court of Illinois the question of whether Illinois’s Minimum Wage Law incorporates the PPA’s exclusion for preliminary and postliminary activities.The Supreme Court of Illinois held that section 4a of the Illinois Minimum Wage Law does not incorporate the PPA’s exclusion for preliminary and postliminary activities. The court reasoned that the plain language of the statute and relevant state regulations do not contain such an exclusion and that the Illinois Department of Labor explicitly defines compensable hours to include all time an employee is required to be on the premises. The court thus answered the certified question in the negative. View "Johnson v. Amazon.com Services, LLC" on Justia Law

A realty management company in New Jersey hired an individual to serve as superintendent for two buildings. When the employee applied for the position, he provided an invalid Social Security number. Initially paid in cash, his compensation arrangement changed to a rent-free apartment in exchange for his labor after the employer learned of the invalid Social Security number. The employee continued to perform superintendent duties for several years without receiving regular wages. The employer did not maintain records of the employee’s hours or wages. After being terminated, the employee filed a claim alleging violations of New Jersey’s wage and hour laws for unpaid wages and overtime.The Superior Court, Law Division, following a bench trial, dismissed the employee’s claims with prejudice, finding that he was not credible due to his use of an invalid Social Security number and had not provided specific evidence of hours worked. The Appellate Division affirmed, concluding that the employee, as an undocumented worker, could not have an employee-employer relationship under federal law and was thus barred from relief. The court also found the barter arrangement established a relationship outside the scope of wage and hour protections.The Supreme Court of New Jersey reversed, holding that neither the employee’s undocumented status nor the barter arrangement precluded his right to recover wages for work already performed. The Court ruled that federal immigration law does not conflict with or preempt state wage and hour laws in requiring payment for work actually performed. Employers have the statutory duty to keep records, and failure to do so results in a rebuttable presumption in favor of the employee’s claim. The Court also held that evidence of an invalid Social Security number should be carefully scrutinized for prejudice under evidence rules. The case was remanded to the trial court for a determination of damages. View "Lopez v. Marmic LLC" on Justia Law