Justia Labor & Employment Law Opinion Summaries

Support staff who worked at a psychiatric hospital in Louisiana operated by Acadia-affiliated entities allege that, while they were provided with nominal meal breaks, they were functionally required to remain on call due to company policies and ethical obligations. As a result, they claim they were not properly compensated for this time. The plaintiffs, a former nurse supervisor and a former mental health technician, brought suit on behalf of themselves and similarly situated employees. Their claims included violations under the Fair Labor Standards Act (FLSA) and Louisiana state-law torts, specifically unjust enrichment and conversion.The United States District Court for the Eastern District of Louisiana certified both an FLSA collective action and a Rule 23(b)(3) class action for the state-law claims. Acadia sought interlocutory review of the class certification under Federal Rule of Civil Procedure 23(f). The Fifth Circuit Court of Appeals was presented with Acadia’s appeal challenging both the collective and class certification decisions.The United States Court of Appeals for the Fifth Circuit determined that it lacked jurisdiction to review the FLSA collective action certification at this stage, as Rule 23(f) provides for interlocutory review only of class certification orders, not collective actions. The court declined Acadia’s request to exercise pendent appellate jurisdiction because the legal standards and issues between the FLSA collective and the Rule 23 class were not sufficiently intertwined. Turning to class certification, the Fifth Circuit found no abuse of discretion by the district court. It held that the Rule 23 requirements of numerosity, commonality, typicality, adequacy, predominance, and superiority were satisfied based on the plaintiffs’ “on-call” theory, which presented common questions suitable for classwide adjudication. The court therefore affirmed the district court’s certification of the Rule 23 class, dismissed the appeal regarding the collective action, and remanded for further proceedings. View "Hamm v. Ochsner-Acadia" on Justia Law

A former Chief Financial Officer of a clinical drug development company was terminated shortly after experiencing a domestic violence incident and requesting limited accommodations at work. She alleged that her supervisor sidelined her, assigned her diminished responsibilities, and ultimately terminated her for reasons related to her gender and experience as a domestic violence victim. After her termination, she initially filed an arbitration demand asserting discrimination and harassment based on national origin and her status as a domestic violence victim. During discovery in the arbitration process, she uncovered evidence suggesting her mistreatment was motivated by sex. She then withdrew from arbitration and filed suit in state court, asserting sex discrimination and hostile work environment claims.The employer removed the case to the United States District Court for the Northern District of California and moved to compel arbitration, arguing that the Federal Arbitration Act and related federal law preempted any state procedural rules allowing withdrawal from arbitration. The district court ruled that, although state procedural rules were preempted, the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA) gave the plaintiff the right to invalidate the arbitration agreement and proceed in court based on plausible allegations of sexual harassment. The district court found that the plaintiff did not know of her sexual harassment claim when she initiated arbitration and had not waived her rights under the EFAA.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s order denying the motion to compel arbitration. The court held that the EFAA allows plaintiffs to elect to proceed in court once they discover a sexual harassment claim, even if they initially pursued other claims in arbitration, so long as they did not intentionally relinquish a known right. The court further found the plaintiff plausibly alleged a sex-based hostile work environment claim under California law and thus under the EFAA. View "DING V. STRUCTURE THERAPEUTICS, INC." on Justia Law

In August 2021, a teacher was indefinitely suspended from his position within the District of Columbia Public Schools, allegedly without prior notice or an opportunity to be heard. The teacher subsequently filed a pro se lawsuit in federal court against the Mayor of the District of Columbia and two public school officials. He claimed a violation of his procedural due process rights under 42 U.S.C. § 1983 and asserted separate claims under District of Columbia law.The United States District Court for the District of Columbia dismissed the teacher’s section 1983 claim, reasoning that he failed to exhaust administrative remedies available under the District’s Comprehensive Merit Personnel Act (CMPA). Since the federal claim was dismissed, the district court declined to exercise supplemental jurisdiction over the local law claims and dismissed them as well.On appeal, the United States Court of Appeals for the District of Columbia Circuit reviewed the case de novo. The appellate court held that, under Supreme Court precedent—especially Patsy v. Board of Regents of Florida—and its own prior decisions, exhaustion of state or District of Columbia administrative remedies is not a prerequisite to bringing a section 1983 claim in federal court, unless Congress expressly imposes such a requirement. The court found that neither the CMPA nor any federal statute required exhaustion in this context. Thus, the court reversed the district court’s dismissal of the section 1983 claim and vacated the dismissal of the local law claims, remanding the case for further proceedings. The appellate court emphasized that only Congress, not local law or judicial interpretation, may impose exhaustion requirements for section 1983 actions in federal court. View "Mpoy v. Burst" on Justia Law

An employee of Royal Caribbean participated in the company’s retirement plan and invested in a series of target date funds managed by Russell. She, on behalf of a class, alleged that Royal Caribbean, as plan sponsor and fiduciary under ERISA, breached its duty of prudence by selecting and retaining the Russell Target Date Funds (TDFs) instead of alternatives like those from Vanguard or American Funds. The complaint highlighted that the Russell TDFs underperformed their peers and benchmarks, charged higher fees, and had features—such as a particular glidepath and asset allocation—that allegedly made them a poor fit for plan participants. Internal communications from Russell and Royal Caribbean raised concerns about the performance and cost of the Russell TDFs.The United States District Court for the Southern District of Florida granted summary judgment to Royal Caribbean. It reasoned that, in order to prove the investment was objectively imprudent, the plaintiff was required to present “apples-to-apples” comparator evidence—showing the Russell TDFs were worse than another fund with the same investment strategy and risk profile. The district court found that the plaintiff’s comparators, such as the Vanguard and American Funds TDFs, were not proper because they differed in strategy and structure from the Russell funds.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that an ERISA plaintiff is not always required to provide an “apples-to-apples” comparator to establish that an investment was objectively imprudent. The court explained that evidence of objective imprudence can be qualitative or quantitative, and the inquiry is context-specific, depending on all relevant facts and circumstances. The Eleventh Circuit reversed the district court’s grant of summary judgment and remanded the case for further proceedings. View "Johnson v. Russell Investments Trust Company" on Justia Law

An aluminum company had, through various collective bargaining agreements (CBAs), promised certain healthcare benefits to retirees, their spouses, and dependents. The agreements did not specify the duration of these benefits, but the company had been providing lifetime healthcare coverage to individuals who retired before June 1, 1993. In August 2020, the company announced it would transition these pre-1993 retirees to a new health reimbursement arrangement starting January 1, 2021, under which the company reserved the right to terminate benefits at any time. Over 3,000 affected individuals, including the widow of a former employee, challenged this change, alleging that it breached the CBAs and violated federal labor and benefits laws.The United States District Court for the Southern District of Indiana certified a class of affected retirees and their eligible spouses and dependents. After discovery, the court granted summary judgment as to liability in favor of the plaintiffs, relying on judicial estoppel. The court found that the company was barred from arguing that benefits were not vested for life because it had previously taken the opposite position in earlier litigation. As a result, the district court declared that class members were entitled to lifetime healthcare benefits and issued a permanent injunction requiring reinstatement of the prior plan and allowing claims for expenses incurred since January 1, 2021.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s certification of the class under Rule 23(b)(2), finding no abuse of discretion. However, it reversed the grant of summary judgment as to liability. The appellate court concluded that judicial estoppel did not apply because the company’s prior statements in earlier litigation were not clearly inconsistent with its current position. The case was remanded for further proceedings on the merits. View "Kaiser v Alcoa USA Corp." on Justia Law

The case centers on a group of plaintiffs who brought a lawsuit claiming that their employer's timekeeping system, which rounded employees’ clock-in and clock-out times to the nearest quarter-hour, resulted in underpayment of wages. The plaintiffs argued that this rounding practice systematically favored the employer and thus violated the Fair Labor Standards Act (FLSA). The employer maintained that its rounding policy was neutral and consistent with federal regulations, and that over time, the rounding did not systematically disadvantage employees.In the United States District Court for the Northern District of Illinois, the employer moved for summary judgment, contending that the evidence showed the rounding practice was neutral both on its face and in practice. The district court agreed, finding that the employer’s rounding system complied with the FLSA’s regulations, which permit rounding as long as it does not consistently favor the employer. The court concluded there was no genuine dispute of material fact and granted summary judgment in favor of the employer.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case. The appellate court affirmed the district court’s decision, holding that the employer’s rounding policy was permissible under the FLSA, provided it was facially neutral and did not systematically undercompensate employees over time. The Seventh Circuit clarified that, although individual pay periods might see some employees gain or lose time, the system as a whole did not violate federal law when considered in the aggregate. The court’s holding confirms that time-rounding practices consistent with federal guidance, and that do not result in systematic underpayment, are lawful under the FLSA. View "Kim v Jump Trading, LLC" on Justia Law

An African American employee worked as a driver for a metal recycling company in South Carolina for several months in 2017. During his employment, he experienced repeated racial harassment from white coworkers and supervisors, including the frequent use of racial slurs, exposure to racist cartoons, and derogatory comments both in person and on social media. The employee also believed he was denied training and promotional opportunities due to his race. He refrained from making complaints initially out of fear of retaliation, as a manager had previously warned him against associating with African American coworkers who had complained about discrimination. On June 13, 2017, after a racially offensive incident involving his manager, the employee complained directly to the manager about racial harassment and discrimination. He was immediately suspended and, after providing a written statement, was terminated a week later.After his termination, the employee filed suit in the United States District Court for the District of South Carolina, alleging a racially hostile work environment, race discrimination in training and promotion, and retaliatory discharge under 42 U.S.C. § 1981. The district court, adopting the magistrate judge’s recommendation in part, held that the hostile work environment and race discrimination claims were time-barred. The court also granted summary judgment to the employer on the retaliatory discharge claim, concluding that the employee’s termination was due to “belligerent and insubordinate conduct” rather than retaliation and that no reasonable jury could find otherwise.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit held that genuine disputes of material fact existed as to whether the employer’s stated reason for termination was pretext for retaliation and whether retaliation was a but-for cause of the discharge. The appellate court therefore vacated the summary judgment on the retaliatory discharge claim and remanded the case for further proceedings. View "Stewart v. GES Recycling South Carolina LLC" on Justia Law

Aisha Putnam was employed by CaramelCrisp, LLC, working in research and development and also managing quality assurance for the company’s food products. During her time there, she observed several food safety and quality control violations, which she repeatedly reported to company management. In early 2019, Putnam sent anonymous emails to the FDA regarding these concerns. Two weeks after her communication with the FDA, CaramelCrisp terminated her employment. Subsequent to her termination, CaramelCrisp discovered that Putnam had taken company documents and initiated a trade secrets lawsuit against her.While the trade secrets case was pending, Putnam filed suit in the United States District Court for the Northern District of Illinois, alleging she was discharged in retaliation for her food safety complaints, bringing claims under the Food Safety Modernization Act (FSMA) and Illinois common law. The district court dismissed her common law claim, holding that the existence of a statutory remedy under the FSMA precluded a separate common law action. The court granted summary judgment to CaramelCrisp on Putnam’s FSMA claim to the extent it was based on her FDA emails because there was no evidence CaramelCrisp knew about them. Her claim based on complaints to management proceeded to trial, where a jury found that her complaints were not a contributing factor in her termination.On appeal, the United States Court of Appeals for the Seventh Circuit dismissed Putnam’s trial-related challenges due to her failure to provide trial transcripts. The court affirmed the district court’s dismissal of the common law claim and its summary judgment ruling, holding that Putnam failed to show CaramelCrisp knew of her FDA emails and that the jury’s finding precluded success on any theory requiring proof that her complaints contributed to her termination. View "Putnam v Caramelcrisp, LLC" on Justia Law

A former Fire Chief of the Cincinnati Fire Department, who had worked for the department since 1993 and was promoted to Fire Chief in 2021, was terminated by the City Manager in 2023 without being given a pre-termination hearing. The City Charter provided that, after serving six months as Fire Chief, the individual could only be removed for cause. When promoted, the Fire Chief signed a memorandum stating the position was “unclassified” and subject to dismissal without cause, but the Charter’s language provided for-cause protection after the first six months. The City Manager provided the Fire Chief with a termination letter listing reasons for the firing and publicized the termination, including to the media, citing the reasons as “for cause.” The Fire Chief did not receive a pre-termination or post-termination hearing before a neutral decisionmaker.The United States District Court for the Southern District of Ohio denied summary judgment to the City Manager and the City, holding that the City Manager was not entitled to qualified immunity regarding pre-termination due process violations. The court found that, under the Charter, the Fire Chief had a property interest in continued employment after six months and that there were unresolved factual disputes regarding waiver of those rights. The district court also denied statutory immunity to the City Manager on the Fire Chief’s state law defamation claim, finding triable issues regarding whether her statements were knowingly false or made with malice.On interlocutory appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The Sixth Circuit held that the City Charter unambiguously gave the Fire Chief for-cause removal protection after six months, creating a property interest protected by procedural due process. It found that no “clear and unmistakable” waiver of those rights was effected by the memorandum. The court also held that sufficient evidence existed for a jury to decide whether the City Manager acted with malice or bad faith in making allegedly defamatory statements. The matter was remanded for further proceedings. View "Washington v. City of Cincinnati" on Justia Law

A black factory manager worked for a biomedical company that had been placed on a corporate safety watchlist due to recurring safety issues. He became responsible for the factory’s operations and safety. The company conducted several safety audits, including a special unannounced audit after two safety incidents were reported late. The manager believed that the head of the safety department, a white executive, targeted him with excessive scrutiny and was rude, later attributing these actions to racial bias based on his own experiences and discussions with other black employees. The company investigated possible bias after concerns were raised, finding the executive had been rude and had engaged in some microaggressions or unconscious bias, but no blatant racial discrimination.After the factory manager filed a discrimination charge with the EEOC, a dispute with the interim president led him to send group messages that a recipient interpreted as threatening. The company suspended the manager with pay pending investigation. He then left the company and filed suit under Title VII, alleging racial discrimination and retaliation.The United States District Court for the Eastern District of Pennsylvania granted summary judgment to the employer. It found no evidence that the alleged actions harmed any identifiable term or condition of the manager’s employment, nor that any actions were racially motivated. The court also concluded there was no evidence of retaliation, as the suspension was due to the perceived threatening messages.The United States Court of Appeals for the Third Circuit reviewed the case de novo and affirmed the District Court’s judgment. The Third Circuit held that the manager failed to establish a prima facie case of racial discrimination or retaliation under Title VII. The court found that neither the alleged conduct nor the suspension constituted unlawful discrimination or retaliation. View "Gabriel v. DSM Biomedical Inc" on Justia Law