Justia Labor & Employment Law Opinion Summaries

Anthony Knight was employed by Cambria Company, LLC as a process engineering technician, primarily assisting with production line functionality. In late 2022, Knight’s father passed away, leading Knight to struggle with depression. He subsequently requested and was granted leave under the Family and Medical Leave Act (FMLA) from February to April 2023. In mid-March 2023, while Knight was on FMLA leave, Cambria terminated his employment, citing elimination of his position due to a reduction in force. Cambria stated that Knight was selected for termination because of his shorter period of employment compared to other employees, and his job responsibilities were shifted to other departments without hiring a replacement.Knight filed suit in the United States District Court for the District of Minnesota, alleging that Cambria discriminated against him and interfered with his FMLA entitlements. During discovery, Cambria asserted that the decision to terminate Knight was based solely on seniority and the need to reduce headcount due to production slowdowns. The district court granted summary judgment in favor of Cambria, finding that Knight had not produced sufficient evidence of discriminatory intent or pretext, and that Cambria provided legitimate, nondiscriminatory reasons for his termination.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo. The Eighth Circuit held that Knight failed to raise a genuine dispute as to whether Cambria’s stated reasons for termination were pretextual or connected to his FMLA leave. The court found that Cambria’s reduction in force and reliance on seniority were legitimate reasons, and Knight’s evidence did not show intentional discrimination or unlawful interference with FMLA rights. Accordingly, the Eighth Circuit affirmed the district court’s judgment. View "Knight v. Cambria Company, LLC" on Justia Law

A physician assistant was employed at a medical spa operated by a corporation in Vermont, with the president as a co-defendant. The plaintiff worked part-time initially, then full-time beginning in 2018. Her employment agreement was amended that year to provide an annual salary, a bonus formula based on the employer’s gross sales for each calendar year, and paid vacation. She received bonuses in 2018 and 2019 but was terminated in December 2020 without receiving a bonus or payment for unused paid time off for that year.The plaintiff sued in the Vermont Superior Court, Chittenden Unit, Civil Division, alleging breach of contract for underpaid bonuses in 2018 and 2019, failure to pay the 2020 bonus and unused PTO, and statutory wage violations. The trial was split, with contractual claims presented to a jury and wage claims to the court. After the plaintiff’s case, the court granted judgment as a matter of law to the defendants on the 2020 claims, finding insufficient evidence for breach or violation of the implied covenant of good faith and fair dealing. The jury found for the plaintiff on her bonus claims for 2018 and 2019, awarding damages, which the court doubled under Vermont’s wage statutes. Defendants moved for judgment as a matter of law post-trial, arguing insufficient evidence of gross sales, and the trial court ultimately granted their motion after reconsideration, entering judgment for defendants on all counts.On appeal, the Vermont Supreme Court reviewed the trial court’s grant of judgment as a matter of law de novo. The Court affirmed the trial court’s decision, finding the plaintiff presented insufficient evidence that the employer’s gross sales exceeded the thresholds required for higher bonuses in 2018 and 2019. The Court also affirmed judgment for defendants on the 2020 bonus and PTO claims, holding there was no evidence of bad faith or intent to deprive the plaintiff of accrued benefits. The Court reversed the denial of attorney’s fees for defendants and remanded for reconsideration of that request. View "Rossetti v. Bare, Ltd." on Justia Law

A correctional officer with almost nineteen years of service was terminated by the state corrections department after he disclosed information about an upcoming search (“shakedown”) to his son, who was incarcerated at a different facility. The department conducted an investigation following a recorded phone call and statements gathered from both the officer and his son. The officer’s son allegedly boasted about receiving advance notice of the search, while the officer admitted in the investigation that he inadvertently shared information. After the investigation, the officer was fired for violating departmental policy. The officer attempted to appeal his termination, but filed his grievance with the wrong agency and did not follow up for over two years.The United States District Court for the Eastern District of Wisconsin dismissed the son’s First Amendment retaliation claim at the screening stage and later granted summary judgment in favor of the corrections department on the officer’s First Amendment retaliation and Fourteenth Amendment procedural due process claims. The district court determined that the officer’s speech was not protected because it did not address a matter of public concern, and that adequate pre- and post-termination procedures were available to the officer, despite his procedural missteps.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s decisions. The appellate court held that the officer’s statement about the shakedown was not protected speech under the First Amendment, as it was private and not of public concern. It also found that the officer received sufficient notice and opportunity to respond before termination, and that adequate avenues for post-termination review were available, even if he failed to properly use them. The court further concluded that the son’s claim did not state a constitutional violation. The district court’s dismissal and summary judgment orders were affirmed. View "Felton v Johnson" on Justia Law

The plaintiff worked as a Sterile Processing Technician for the defendant, a health system, and was compensated with a base hourly wage, shift differentials, weekend differentials, extra pay for additional hours, and bonuses for on-call time. The dispute centered on how overtime and holiday pay were calculated. The defendant included shift and weekend differentials and extra pay in the regular rate calculation, but excluded holiday premiums. The plaintiff, representing a certified class, alleged that the defendant’s method improperly credited regular-rate compensation toward overtime premiums and wrongly excluded holiday pay from the regular rate, in violation of the Fair Labor Standards Act (FLSA) and Wisconsin law.The United States District Court for the Eastern District of Wisconsin granted summary judgment to the defendant on all class-wide claims. The court found that the defendant’s approach to overtime calculations—using total remuneration (excluding statutory exclusions) divided by total hours worked, and then applying a 0.5 multiplier to the regular rate for overtime hours—was consistent with federal and state law. The court also concluded that statutory exclusions in § 207(e)(6) of the FLSA permitted the exclusion of holiday premiums from the regular rate. The plaintiff’s motion for reconsideration was denied, and the case was dismissed with prejudice.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the summary judgment de novo. The court held that the defendant’s methodologies for calculating overtime and excluding holiday premiums complied with both the FLSA and Wisconsin law. The court affirmed the district court’s judgment and denied the plaintiff’s request to certify a question to the Wisconsin Supreme Court regarding holiday pay exclusions. The district court’s decisions granting summary judgment and denying reconsideration were affirmed. View "Lutz v Froedtert Health, Inc." on Justia Law

David Krzesni was employed by Wellpinit School District (WSD) as Project Director for a federally funded Native Youth Community Project Grant. Prior to Krzesni’s hiring, WSD had planned a trip to Hawaii for students and staff, believing it would further the grant’s objectives. After Krzesni started, he helped facilitate funding for the trip using grant money. However, federal approval for the trip was not obtained, and the grant’s federal contact later indicated such funding would not be approved. Krzesni participated in the trip, prepared an Annual Performance Report describing it, and later learned the trip expenses had already been paid from grant funds. He also contemplated leaving his position and discussed grant compliance concerns with colleagues and the federal grant contact.The United States District Court for the Eastern District of Washington reviewed Krzesni’s claims for whistleblower retaliation under the National Defense Authorization Act (NDAA), 41 U.S.C. § 4712, and wrongful discharge under Washington law. Krzesni alleged that his contract was not renewed in reprisal for disclosures regarding the unauthorized use of grant funds for the Hawaii trip. The district court granted summary judgment for WSD and its superintendent, reasoning that Krzesni did not make protected disclosures under the NDAA and was not “discharged” under Washington law, as his contract simply expired without renewal.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s decision. The court held that Krzesni’s reporting of the Hawaii trip in the performance report and a rhetorical question to a supervisor did not constitute protected disclosures, as they did not objectively indicate misconduct. Additionally, even if a protected disclosure occurred during Krzesni’s call with the federal grant contact, WSD had already decided not to renew his contract beforehand, so no reprisal could be shown. The court further held that the nonrenewal of Krzesni’s contract was not considered a discharge under Washington law, thus defeating his wrongful discharge claim. View "KRZESNI V. WELLPINIT SCHOOL DISTRICT" on Justia Law

An employee of The Permanente Medical Group, Inc. worked remotely as a Managerial Senior Consultant. After the employer instituted a mandatory COVID-19 vaccination policy requiring all employees to be vaccinated or to obtain a valid exemption, the employee requested a religious exemption, citing her beliefs as a Christian Jew and referencing relevant religious texts. The employer initially granted her a provisional exemption but later required more information to assess the sincerity of her beliefs. When she did not fully answer the supplemental questions, particularly declining to disclose information about her medical history, the employer revoked her exemption and terminated her employment for noncompliance with the vaccine mandate.After her termination, the employee filed a lawsuit in the United States District Court for the Northern District of California, alleging violations of Title VII and California’s Fair Employment and Housing Act (FEHA), as well as a claim under the California Constitution. The district court granted the employer’s motion to dismiss her statutory claims, holding that she had failed to allege that she adequately notified the employer of the conflict between her religious beliefs and the vaccine mandate. The court reasoned that her initial exemption request and responses to supplemental questions provided insufficient notice and dismissed the complaint.On appeal, the United States Court of Appeals for the Ninth Circuit reviewed the sufficiency of the employee’s allegations regarding notice of a religious conflict. The Ninth Circuit held that to satisfy the notice requirement for a prima facie case of religious accommodation under Title VII and FEHA, an employee must provide enough information for the employer to understand an actual conflict between religious beliefs and work requirements. The court found that the employee’s allegations met this standard at the pleading stage, reversed the district court’s dismissal of her statutory claims, and remanded the case for further proceedings. View "WEISS V. PERMANENTE MEDICAL GROUP, INC." on Justia Law

Becky Joseph was employed as a Lead Installer by a Minnesota-based construction company. After being hired, she worked on projects in Nevada and experienced conflicts with several supervisors. Joseph frequently complained to management about being disrespected and not having her opinions valued, and at one point threatened to resign, but later withdrew her resignation. She was involved in a minor workplace accident and had an incident with hotel staff during a company-provided stay. After further complaints about her supervisors, Joseph alleged that the men at the company were treated as more valuable than women and referenced discrimination. The company investigated her complaints but found no substantiating evidence. Joseph was then offered a transfer to another jobsite, which she declined, choosing instead to resign.Joseph subsequently filed suit in the United States District Court for the Western District of Michigan, alleging sex discrimination and retaliation in violation of Title VII of the Civil Rights Act and Michigan’s Elliott-Larsen Civil Rights Act. The case was transferred to the District of Minnesota, where the district court granted summary judgment for the employer. The district court found that Joseph’s complaints did not mention sex discrimination until after the events in question, that there was no evidence linking the employer’s actions to discriminatory animus, and that her claims were not supported by any documentary evidence. The court also determined that Joseph’s complaints did not amount to protected activity under the retaliation statutes.On appeal, the United States Court of Appeals for the Eighth Circuit affirmed. The court held that Joseph failed to provide direct evidence or sufficient facts to support a prima facie case of discrimination or retaliation. The court determined the employer had legitimate, non-discriminatory reasons for its actions and that Joseph had not shown those reasons were pretextual. The judgment of the district court was affirmed. View "Joseph v. Thomas-Grace Const. Inc." on Justia Law

A longtime employee of the New York City Department of Finance, who suffered from chronic respiratory conditions, was permitted to work remotely during the COVID-19 pandemic. In March 2022, the City required him to work in the Manhattan office for part of the week, while allowing remote work for the other days. He requested to perform his in-office days at the Staten Island office, citing medical difficulties related to commuting and the poor ventilation at the Manhattan location. This request was denied, as were later requests to work fully remotely or to split time between home and Staten Island. Ultimately, his appeals were only partially successful, and he was required to work some days in Manhattan. He alleged these denials constituted discrimination, failure to accommodate, and retaliation under the Americans with Disabilities Act (ADA) and New York City Human Rights Law (NYCHRL).The United States District Court for the Southern District of New York dismissed all claims, finding the employee failed to plausibly allege any adverse employment action or that he could perform his essential job functions with his requested accommodations. The court also denied his request to amend his complaint, ruling that the proposed amendments did not cure these pleading deficiencies nor state a plausible claim for retaliation.On appeal, the United States Court of Appeals for the Second Circuit held that the district court was correct to dismiss the claims of discrimination and retaliation, as the employee’s allegations did not adequately show an adverse employment action tied to his disability or protected activity, nor did they plausibly suggest retaliatory intent. However, the appellate court found that the complaints included sufficient factual allegations to support a claim that the employee could perform his job with reasonable accommodation, thus plausibly pleading claims for failure to accommodate under both the ADA and NYCHRL. The court affirmed the dismissal of the discrimination and retaliation claims but vacated the dismissal of the failure-to-accommodate claims and remanded those for further proceedings. View "Cangro v. NYC Dep't of Finance" on Justia Law

A human resources manager at a Wisconsin aluminum foundry reported multiple incidents of discrimination and harassment involving both herself and other employees. She relayed complaints of inappropriate and sexist behavior by male managers, including offensive language and conduct directed at women and minorities. After raising these concerns to her supervisor and reporting her own experiences with sexist insults, she received a negative performance review citing divisiveness and lack of trust. She then complained about possible retaliation and was terminated shortly thereafter. Her starting salary as HR manager was lower than that of a subsequent male hire for a related managerial position, although their exact responsibilities differed.The United States District Court for the Eastern District of Wisconsin dismissed her hostile work environment claim at the pleading stage. After discovery, the court granted summary judgment for the employer on the remaining claims: sex discrimination, pay discrimination, and retaliation. The court found that she had not met the performance expectations required for a prima facie case of sex discrimination, failed to identify a sufficiently close comparator for pay discrimination, and had not engaged in protected activity for retaliation. She appealed the summary judgment rulings except for the hostile work environment dismissal.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s grant of summary judgment de novo. The court held that the plaintiff had offered sufficient evidence of sex discrimination and retaliation under Title VII for a reasonable jury to find in her favor, particularly considering the discriminatory workplace culture, questionable justifications for her termination, and the timing of her firing after protected activity. However, the court affirmed summary judgment for the employer on the pay discrimination claim due to insufficient evidence regarding comparators. The case was remanded for trial on the sex discrimination and retaliation claims. View "Pratt v Wisconsin Aluminum Foundry" on Justia Law

The plaintiff worked for nearly thirty years for the defendant, a union benefit fund, and served most recently as an outreach coordinator required to drive to various healthcare facilities to give presentations. After developing a vein condition that limited his ability to sit or drive for more than thirty minutes at a time, the plaintiff informed the defendant of his restrictions. The defendant responded by removing the four facilities farthest from his home from his route, but left him with assignments requiring drives longer than thirty minutes. The plaintiff requested reassignment to a different area, which the defendant refused. Unable to return to work under these conditions, the plaintiff was terminated.In the United States District Court for the Southern District of New York, the defendant was granted summary judgment on the plaintiff’s claim that the defendant failed to provide reasonable accommodations, with the court finding the defendant had sufficiently accommodated him. The plaintiff’s disability discrimination claim proceeded to trial, where a jury found for the defendant. The plaintiff then moved for a new trial under Rule 59(a), arguing the verdict was against the weight of evidence, but the district court denied the motion, concluding a reasonable jury could find the plaintiff was not terminated because of his disability.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that the district court erred in granting summary judgment on the failure-to-accommodate claim because factual questions remained about whether the accommodation provided was reasonable and whether other plausible accommodations existed. The court vacated the summary judgment, dismissed the appeal regarding the Rule 59(a) motion as not reviewable, and remanded the case for further proceedings. View "Raymond v. 1199SEIU National Benefit Fund" on Justia Law