Justia Labor & Employment Law Opinion Summaries

An airline employee, who began working in 1996 and served as a union representative, was terminated in 2023 after allegedly violating both company policy and the terms of a Last Chance Agreement (LCA) he had previously entered into. The LCA was signed following an earlier incident in which he admitted to theft, and it stipulated that any further violation of company policy during its term would result in immediate termination. In October 2023, the employee entered a restricted area in violation of company policy, leading to his discharge.Following his termination, the employee filed a lawsuit in the United States District Court for the Northern District of Texas, alleging retaliatory termination under the Railway Labor Act (RLA) and asserting that his termination was motivated by anti-union animus due to his activities as a union representative. The airline moved to dismiss the complaint, arguing that the dispute was a “minor” one under the RLA, which meant it was subject to mandatory arbitration as outlined in the collective bargaining agreement (CBA), thus depriving the federal court of subject-matter jurisdiction. The district court agreed and granted the airline’s motion to dismiss under Rule 12(b)(1), finding that the dispute was minor and did not fall within any exceptions allowing for judicial intervention.On appeal, the United States Court of Appeals for the Fifth Circuit reviewed whether the district court properly dismissed the case for lack of subject-matter jurisdiction. The Fifth Circuit affirmed the district court’s decision, holding that the dispute was a minor one under the RLA because it could be resolved by interpreting the LCA and CBA, and that none of the exceptions to exclusive arbitral jurisdiction applied. The court also found no sufficient evidence of anti-union animus to invoke an exception to arbitral exclusivity. View "Reardon v. American Airlines" on Justia Law

A franchisee brought several claims against a franchisor and related parties, including allegations of breach of contract, unjust enrichment, violations of Florida law, and Fair Labor Standards Act (“FLSA”) violations. The parties settled, with the franchisee receiving $50,000 and both sides signing a mutual release that broadly barred any future claims. The agreement was not approved by a court or the Department of Labor and contained a confidentiality provision. Subsequently, the franchisee initiated a separate action for fraudulent transfer and other non-FLSA claims, arguing these were not barred by the settlement’s release.After the settlement, the franchisee filed a supplemental complaint in the United States District Court for the Middle District of Florida, alleging fraudulent transfer and related non-FLSA claims. The franchisor responded with a motion for judgment on the pleadings, citing the settlement’s release. The franchisor also filed counterclaims, including breach of contract based on the franchisee’s new filings. The franchisee attempted to amend his complaint to add a claim for rescission, arguing fraudulent inducement, but the magistrate judge denied this motion, finding it was inadequately pleaded and untimely. The franchisee did not properly object to this denial before the district judge.The United States Court of Appeals for the Eleventh Circuit considered whether the unapproved settlement agreement barred the non-FLSA claims. The court held that, while FLSA claims cannot be waived or settled without court or Department of Labor approval, non-FLSA claims may be released according to state contract law. The court found the release enforceable under Florida law as to non-FLSA claims and affirmed the district court’s dismissal of the fraudulent transfer claims and grant of summary judgment to the franchisor on its counterclaims. The court also ruled the franchisee had waived his right to appeal the denial of his motion to amend. View "O'Neal v. American Shaman Franchise Systems, Inc." on Justia Law

A group of current and former warehouse workers employed by the defendants in Connecticut alleged that their employer failed to compensate them for time spent undergoing mandatory security screenings before leaving the workplace at the end of their shifts. The procedures required employees to pass through security—sometimes involving metal detectors, divesting tables, or X-ray machines—before being allowed to exit the premises. The length of these screenings varied, but employees were required to remain on the employer’s property during the process.After the workers filed a class action complaint in the Connecticut Superior Court, the defendants removed the case to the United States District Court for the District of Connecticut. The District Court granted summary judgment in favor of the employer, concluding that Connecticut’s wage laws were intended to align with federal law, specifically the Fair Labor Standards Act (FLSA) as amended by the Portal-to-Portal Act, and that, under federal law, such security screenings are not compensable. The workers appealed, and the United States Court of Appeals for the Second Circuit certified two questions to the Supreme Court of Connecticut regarding the interpretation of Connecticut’s wage laws.The Supreme Court of Connecticut held that, under the unambiguous language of Connecticut law, employers must compensate employees for all time required on the employer’s premises, including time spent undergoing mandatory security screenings. The Court further determined that Connecticut law does not recognize a de minimis exception that would allow employers to disregard small amounts of time as noncompensable. Thus, the Court answered the first certified question in the affirmative and the second in the negative, clarifying that Connecticut wage laws are more protective than federal law in this respect. View "Del Rio v. Amazon.com Services, Inc." on Justia Law

An employee working as a prep cook at a restaurant was injured during a physical altercation with a co-worker. The altercation arose out of a workplace argument that escalated, resulting in the co-worker striking the employee and causing significant injury. The injured employee filed a workers’ compensation claim, while the employer and its insurer denied liability, asserting the “initial physical aggressor” defense under California Labor Code section 3600(a)(7), arguing that the employee was the initial physical aggressor and thus barred from recovery.The matter was tried before a Workers’ Compensation Administrative Law Judge (WCJ), who heard testimony from all involved and found that the employee was the initial physical aggressor, based largely on the credibility of eyewitnesses. The WCJ denied the employee’s claim for compensation. The employee timely filed a petition for reconsideration with the Workers’ Compensation Appeals Board (WCAB). Although the petition was filed and transmitted within the statutory 60-day period, the WCAB did not review it until after the deadline. The WCAB ultimately granted reconsideration, rescinded the WCJ’s denial, and found that the “initial physical aggressor” defense had not been proven, thus allowing the employee’s claim.The California Court of Appeal, Sixth Appellate District, reviewed the WCAB’s order. The court held that under former section 5909 of the Labor Code, the WCAB lost jurisdiction to act on the petition for reconsideration after the 60-day statutory period elapsed, unless grounds for equitable tolling were present. The court concluded that equitable tolling was not warranted here because there was no evidence of reasonable diligence or special circumstances justifying such relief. Therefore, the court reversed the WCAB’s order and decision after reconsideration. View "Zenith Insurance Co. v. Workers' Compensation Appeals Bd." on Justia Law

A former employee of a bank holding company, who participated in a company-sponsored retirement savings plan, brought suit alleging that the bank, the plan’s administrative committee, and a subsidiary breached their fiduciary duties under ERISA, resulting in financial loss to his plan distribution. After the employee’s separation and payout, the company amended the plan in early 2024 to add a retroactive arbitration clause that required all claims to proceed individually in arbitration, barred class or representative actions, and included a jury trial waiver and a provision that only individual relief could be awarded.The United States District Court for the Western District of Texas denied the defendants’ motion to compel arbitration, holding that the arbitration agreement was not valid under Texas law due to lack of consideration. The company appealed, arguing that the plan’s consent, not the individual participant’s, was sufficient to bind parties to arbitration for claims brought on behalf of the plan under 29 U.S.C. § 1132(a)(2), and that the arbitration clause was enforceable. The company also preemptively addressed potential objections under the effective vindication doctrine and claims that the arbitration provisions unlawfully limited statutory remedies.The United States Court of Appeals for the Fifth Circuit reversed the denial of arbitration as to the § 1132(a)(2) claim, holding that the plan’s consent through its unilateral amendment provision was sufficient to bind the participant to arbitration for plan-based claims, but affirmed the denial as to the participant’s individual claims because he had not consented. The court further held that the arbitration clause’s prohibition on representative actions and its limitation to individual relief violated the effective vindication doctrine, and voided the standard-of-review provision to the extent it applied to fiduciary-breach claims. The case was remanded for the district court to determine whether the offending arbitration provisions could be severed. View "Parrott v. International Bank" on Justia Law

The plaintiff worked as an Agency Manager for a group of insurance companies collectively known as Texas Farm Bureau. In this role, he supervised a team of insurance agents and was classified as an independent contractor. He determined his own work schedule, was not required to report his hours, and was paid through commissions rather than a salary or hourly wage. From 2016 to 2018, his earnings ranged from $552,000 to $627,000 per year. The plaintiff filed suit, claiming he was misclassified and seeking unpaid overtime under the Fair Labor Standards Act, arguing he should have been treated as an employee.The United States District Court for the Western District of Texas ruled at summary judgment that the plaintiff should have been classified as an employee and was owed at least 816 hours of overtime. The only issue left for trial was whether the employer knew or should have known about the plaintiff’s overtime work. A jury found that the employer neither had actual nor constructive knowledge of any overtime. The plaintiff’s motions for judgment as a matter of law and for a new trial were denied by the district court.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s denial of these motions. The appellate court held that an employee seeking overtime pay must prove the employer had actual or constructive knowledge of the overtime work. The court found that allowing an employee to set his own hours does not, by itself, establish employer knowledge of overtime. The lack of a timekeeping system did not constitute constructive knowledge, nor did it shift the burden of proof to the employer. The appellate court also held that the district court’s jury instruction, which required the employee to notify the employer of overtime, was proper. The Fifth Circuit affirmed the district court’s rulings. View "Merritt v. Texas Farm Bureau" on Justia Law

A Black man worked as a truck salesman at a Florida business where he was the only nonwhite employee. He observed that his supervisors and colleagues frequently made derogatory, racially charged comments about nonwhite customers, including the use of slurs for various ethnic groups and stereotypes about Black customers. These comments occurred nearly every time a nonwhite customer entered the business, which happened often. The employee was also the subject of racial slurs behind his back and was sometimes called “boy” in a heated workplace dispute. He reported these incidents to his supervisor, but no corrective action was taken. Over time, his managers began documenting performance and attendance issues, and he was ultimately terminated and replaced by a white employee.The United States District Court for the Northern District of Florida granted summary judgment to the employer on all claims, finding the employee did not provide sufficient evidence of discriminatory or retaliatory termination or a racially hostile work environment.On appeal, the United States Court of Appeals for the Eleventh Circuit reviewed the case de novo. The court affirmed summary judgment in favor of the employer on the claims of discriminatory and retaliatory termination. It held the employee failed to present substantial evidence that his termination was motivated by racial animus or retaliation for protected complaints, and the employer articulated legitimate, nondiscriminatory reasons for its actions.However, the Eleventh Circuit vacated the summary judgment on the hostile work environment claim and remanded for further proceedings. The court held that the employee presented substantial evidence that he was subjected to a racially hostile work environment, including pervasive use of racial slurs and discriminatory conduct towards nonwhite individuals, sufficient for a reasonable jury to find in his favor on that claim. View "Melton v. I-10 Truck Center, Inc." on Justia Law

An employee at a quarry died after falling through an unsecured catwalk gate into dangerous machinery. The machinery, used for processing lime, was typically secured by metal linchpins, but at the time of the accident, the gate was fastened only with a metal wire instead of the pins. The worker’s family brought suit against two of his co-employees, a supervisor and a safety director, alleging gross negligence for failing to prevent the accident. Both defendants testified that they did not know the securing pins were missing, and there had been no prior similar accidents since safety rails were installed decades earlier.After a jury trial in the Iowa District Court for Benton County, the plaintiffs were awarded damages totaling approximately $2.84 million. The district court denied the defendants’ post-trial motions. On appeal, the Iowa Court of Appeals affirmed, reasoning that the evidence supported the conclusion that injury was probable under the circumstances, and relied in part on what the defendants should have known.The Supreme Court of Iowa reviewed the case and determined that, under Iowa law, recovery for co-employee gross negligence requires proof that the defendants had actual knowledge of the specific peril—the missing pins that left the gate unsecured. The court found that there was no evidence either defendant actually knew about the missing pins or unsecured gate. As a result, the legal standard for gross negligence was not met. The Supreme Court of Iowa vacated the decision of the court of appeals, reversed the judgment of the district court, and remanded the case for dismissal, holding that the plaintiffs’ exclusive remedy was under the state’s workers’ compensation statute. View "Griffith v. Kulper" on Justia Law

Andrew Sangster, on behalf of a class of flight instructors, filed suit against the University of North Dakota alleging that instructors were not paid for all hours worked. Sangster claimed the university compensated instructors only for student contact hours and excluded other work-related tasks such as scheduling, pre- and post-flight procedures, recordkeeping, and waiting at the airport. He sought damages for violations of the Fair Labor Standards Act (FLSA), North Dakota wage laws, unjust enrichment, and conversion.The District Court for Cass County reviewed the university’s motion to dismiss, which argued the court lacked jurisdiction because Sangster failed to give timely notice to the Office of Management and Budget as required by North Dakota law. Sangster admitted he had not provided this notice but contended his claims were contractual and thus exempt from the notice requirement. The district court denied the motion to dismiss with respect to the FLSA, state wage law, and unjust enrichment claims, finding them contractual in nature. The conversion claim was dismissed because Sangster conceded the notice requirement applied.The Supreme Court of the State of North Dakota subsequently reviewed the district court’s decision upon the University’s petition for a supervisory writ. The Supreme Court exercised its discretionary supervisory jurisdiction, holding that Sangster’s claims for relief under the FLSA, North Dakota wage laws, and unjust enrichment were not contractual in nature and therefore not authorized by N.D.C.C. ch. 32-12. The Supreme Court concluded that because Sangster had not complied with the statutory notice requirements for noncontractual claims, the district court lacked subject matter jurisdiction. The court granted the supervisory writ and directed the district court to dismiss Sangster’s case for lack of jurisdiction. View "UND v. Whelan" on Justia Law

Several health care facilities and their affiliates faced administrative complaints from the General Counsel of the National Labor Relations Board (NLRB) in 2012 for alleged unfair labor practices. The proceedings were assigned to Administrative Law Judge (ALJ) Kenneth Chu, who developed the factual record over multiple hearings. During this period, the Supreme Court’s decision in NLRB v. Noel Canning invalidated certain NLRB Board appointments, calling into question ALJ Chu’s own appointment. The Board later “ratified” prior actions, including Chu’s appointment, after regaining a lawful quorum. Administrative proceedings were delayed for several years due to interlocutory appeals and COVID-19, and ultimately resumed in 2023. Shortly before resumption, the plaintiffs sought to halt the proceedings, arguing the ALJ was unlawfully appointed and protected from removal in a manner unconstitutional under the separation of powers.The plaintiffs initially sought relief in the United States District Court for the District of New Jersey, which denied a temporary restraining order and transferred the case to the United States District Court for the District of Connecticut. There, the plaintiffs moved for a preliminary injunction, again raising constitutional arguments regarding the ALJ’s appointment and removal protections. The District of Connecticut denied the injunction, finding the plaintiffs had not shown a clear likelihood of success on the merits. Proceedings before ALJ Chu concluded in May 2024, after which Chu retired and the NLRB Board assumed de novo review of the case.The United States Court of Appeals for the Second Circuit reviewed the appeal. It assumed jurisdiction but declined to address the likelihood of success on the merits, instead affirming the district court’s denial of a preliminary injunction on the ground that the plaintiffs could not demonstrate irreparable harm. The court held that, because all proceedings before the challenged ALJ had concluded and the Board (now lawfully constituted) would conduct de novo review, there was no risk of irreparable injury warranting injunctive relief. The order was affirmed. View "Care One, LLC v. NLRB" on Justia Law