Justia Labor & Employment Law Opinion Summaries

A participant in two ERISA-qualified retirement plans at a university sought to change the beneficiary designation shortly before his death, naming trust accounts for his grandchildren as primary beneficiaries and removing his wife as a primary beneficiary. The plan documents required spousal consent for such changes. The participant’s wife, who was still living at the time, had previously executed a Wisconsin statutory power of attorney appointing her son-in-law as her agent. The agent signed the spousal consent form on her behalf, but the power of attorney did not expressly grant authority to waive her spousal survivor annuity rights. The plan recordkeeper rejected the beneficiary change form as deficient, and the participant died soon thereafter. The wife died about a year later. The plaintiffs, including family members and trustees, sought to enforce the beneficiary change, arguing that the power of attorney provided sufficient authority.After the recordkeeper’s rejection, the plaintiffs made a claim for benefits with the university as plan administrator. The university denied the claim, determining that Wisconsin law required a specific grant of authority in the power of attorney to waive spousal survivor benefits, which was absent in this case. The plaintiffs appealed the denial, but the university upheld its decision. Plaintiffs then filed suit in the United States District Court for the Northern District of Illinois, asserting claims under ERISA for benefits, breach of fiduciary duty, and negligence. The district court granted summary judgment for the defendants, concluding the waiver was invalid and finding no merit in the other claims.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The Seventh Circuit held that under Wisconsin law, specifically Wis. Stat. § 244.41(1)(f), a power of attorney must expressly grant authority to an agent to waive spousal rights to a joint and survivor annuity. Because the power of attorney did not contain such an express grant, the attempted waiver was invalid, and the plaintiffs’ ERISA claim failed. The court also affirmed dismissal of the fiduciary duty and negligence claims and denied the plaintiffs’ motion to certify a question to the Wisconsin Supreme Court. View "Havlik v. University of Chicago" on Justia Law

Cheryl Hileman worked as a CAT scan technologist at Forbes Hospital, operated by West Penn Allegheny Health System. After about a year of employment, she was reprimanded for frequent absences and informed of the process to request a disability accommodation or medical leave. She did not make such a request. Several months later, a coworker reported concerns that Hileman was sleeping during her shift. When confronted, Hileman denied sleeping but mentioned, for the first time, that she had diabetes and was experiencing fatigue and dry eyes due to a medication change. She did not request an accommodation or leave. Shortly thereafter, Hileman was terminated for misconduct related to sleeping on the job.Hileman filed suit in the U.S. District Court for the Western District of Pennsylvania, asserting claims under the Americans with Disabilities Act, the Pennsylvania Human Relations Act, and the Family and Medical Leave Act, including disability discrimination, failure to accommodate, retaliation, wrongful termination, and interference with medical leave. The District Court granted summary judgment in favor of West Penn, finding that Hileman was discharged for misconduct and had not requested an accommodation or leave prior to the investigation.On appeal, the United States Court of Appeals for the Third Circuit reviewed the case de novo. The court rejected Hileman’s attempt to supplement the record on appeal and sanctioned her attorney for submitting a motion containing misquotations. On the merits, the court held that an employee must notify the employer of a disability and request an accommodation or leave before the employer is obligated to act. Because Hileman did not request an accommodation or leave, and there was no clear indication that she needed one, her claims failed. The Third Circuit affirmed the District Court’s decision. View "Hileman v. West Penn Allegheny Health System Inc" on Justia Law

Gertrude Crisp, an emergency medical technician, alleged that a co-worker, Joshua Gullett, sexually harassed her at their workplace, the Scioto Ambulance District. Crisp claimed that Gullett made inappropriate comments, touched her without consent, and engaged in other sexually charged behavior. After reporting one incident to a supervisor and showing him Gullett’s Fetlife profile, the employer separated Crisp and Gullett on future shifts but did not otherwise discipline Gullett. Years later, Crisp showed nude images, allegedly of Gullett and his wife, to several co-workers at work, purporting to warn them about Gullett’s behavior. Following an investigation, Scioto Ambulance District terminated Crisp for sharing the images while on duty.In the United States District Court for the Southern District of Ohio, Crisp sued Scioto, arguing that her termination was unlawful retaliation under federal and Ohio antidiscrimination laws. The district court granted summary judgment for the employer, finding that Crisp’s conduct in showing the images was not protected activity under the relevant statutes. Crisp appealed this decision.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The Sixth Circuit held that Title VII and the Ohio Civil Rights Act do not protect an employee who, in the course of opposing workplace discrimination, gratuitously shares nude or sexually explicit images of co-workers while on the job. The court reasoned that while some complaints of sexual harassment are protected, Crisp’s sharing of such images was not necessary to her complaint and extended beyond protected conduct. Therefore, Crisp’s firing did not constitute unlawful retaliation, and the district court’s decision was affirmed. View "Crisp v. Scioto Ambulance Dist." on Justia Law

Several related companies, along with an individual, operated the Inn of Chicago. After purchasing the property, they assumed an existing collective bargaining agreement (CBA) with a labor union. When the City of Chicago approached them to use the Inn to house displaced migrants, the operation resumed, but the employers did not use union members for typical hotel functions. Instead, these tasks were handled by an outside staffing agency and later by another company managed by the same people. The labor union learned of this arrangement, filed grievances alleging violations of the CBA, and submitted the dispute to arbitration. The union also filed an unfair labor practice charge with the National Labor Relations Board, which was consolidated with the arbitration.The United States District Court for the Northern District of Illinois, Eastern Division, reviewed the arbitration award. The arbitrator had found that the Inn was operating as a “hotel” within the meaning of the CBA while housing migrants, that the related companies and individual were a “single employer” under the CBA, and that they violated both the CBA and the National Labor Relations Act by failing to use union employees and failing to provide notice or bargain with the union. The district court confirmed the arbitration award, rejecting the employers’ arguments regarding arbitrability, notice, and authority.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s confirmation of the arbitration award. The court held that the employers were bound by the arbitration because they participated without reserving objections, and the arbitrator’s findings drew from the CBA and issues submitted by the parties. The court found no due process or public policy violation and affirmed the district court’s confirmation of the award. View "Elmar Hotel Management, LLC v Unite Here Local 1" on Justia Law

Segerdahl Corporation, a direct-mail printing company wholly owned by an employee stock ownership plan (ESOP), was sold to a private equity firm in 2016. Bruce Rush, a senior manager and ESOP shareholder, alleged that the sale was improperly organized and approved for less than the company’s fair market value. He claimed that the Defendants—the ESOP trustee GreatBanc and several Segerdahl Board members—breached their fiduciary duties under ERISA by favoring financial buyers, inadequately marketing the company, and failing to secure a higher sale price. The sale process involved negotiations led by JP Morgan, with only financial buyers considered, culminating in an agreement with ICV Partners for $265 million.The United States District Court for the Northern District of Illinois, Eastern Division, certified a class of ESOP shareholders and denied summary judgment for most claims. After a three-week bench trial, the district court issued a comprehensive opinion finding in favor of Defendants on all counts. The court determined that the Defendants did not intentionally depress the sale price, had obtained the best possible price given Segerdahl’s declining performance, and had fulfilled their fiduciary obligations. The district court also found no prohibited transactions under ERISA and concluded that Rush failed to prove damages, rejecting expert testimony that relied on hypothetical buyers and unsupported valuations.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the district court’s legal conclusions de novo and factual findings for clear error. The appellate court affirmed the district court’s judgment, holding that there was no clear error in the findings that Defendants did not breach their fiduciary duties, did not engage in prohibited transactions, and that the sale price reflected fair market value. The district court’s decision was affirmed in full. View "Rush v GreatBanc Trust Co." on Justia Law

A public policy research institute requested records from the City of Phoenix related to ongoing collective bargaining negotiations between the city and its police union. The request sought drafts and proposals for a new labor agreement, as well as communications about the union’s failure to submit a timely proposal. The city declined to provide bargaining documents during ongoing negotiations, arguing that disclosure could harm the negotiation process by creating political pressure, encouraging collusion, and impeding frank discussions.The Maricopa County Superior Court held an evidentiary hearing and found that the city’s concerns about potential harm to the negotiation process outweighed the public interest in disclosure, allowing temporary nondisclosure of bargaining materials until the next agreement was finalized. The Arizona Court of Appeals affirmed the trial court’s approach, noting that the judge applied the correct legal standard and deferred to the trial court’s weighing of evidence. However, the appellate court remanded for in camera inspection of the records, to assess specifically which portions could be withheld, particularly since some content might be unchanged from prior, publicly available agreements.The Supreme Court of the State of Arizona reviewed the case to clarify the proper standard for withholding public records under the “best interests of the state” exception and the appellate review process. The court held that a public entity is not required to prove it is more likely than not that disclosure would cause specific, material harm, but must demonstrate some degree of likelihood of such harm that is not vague or speculative. The court also held that appellate courts defer to factual findings but review the legal balancing of interests de novo. The Supreme Court reversed the appellate decision and remanded for in camera review of the documents and further proceedings. View "GOLDWATER v PHOENIX" on Justia Law

A longtime educator and administrator, the plaintiff began working as a teacher in 1996 and advanced to principal roles in Cherry Creek School District. In 2018, she became principal at High Plains Elementary. After receiving positive evaluations initially, complaints from staff and parents intensified during her second year. The teachers’ union conducted a “Listening Tour,” reporting negative staff feedback, including concerns about division, lack of trust, micromanagement, and fear of retaliation. Subsequent meetings between the plaintiff and her supervisors discussed these concerns and potential remedies. Ultimately, the district’s superintendent decided to demote her to assistant principal, citing loss of staff confidence but no disciplinary or misconduct issues. She took leave and then retired the following year.The plaintiff sued the school district, several administrators, and board members in the United States District Court for the District of Colorado, asserting federal claims under the Fourteenth Amendment (due process and equal protection), the First Amendment, the Equal Pay Act (EPA), and Title IX. The district court granted summary judgment to all defendants on the due process, First Amendment, and EPA claims, and partially on the equal protection and Title IX claims. Only the equal protection claim against three individual administrators (based on disparate treatment) and the Title IX claim against the district (based on disparate treatment and sex stereotyping) proceeded to trial.The United States Court of Appeals for the Tenth Circuit reviewed the district court’s rulings and the subsequent judgment as a matter of law. The appellate court affirmed all decisions. The main holdings are: the plaintiff lacked a due process property interest in continued employment as principal; Cherry Creek’s salary determination based on relevant experience was a legitimate, non-discriminatory factor under the EPA; and, after trial, no reasonable jury could find sex or gender was a motivating factor in the plaintiff’s demotion for either equal protection or Title IX claims. View "Maccagnan v. Cherry Creek School District No. 5" on Justia Law

The plaintiff, an African American clinical pharmacist, worked at a Department of Veterans Affairs facility in Illinois. He was the only African American pharmacist at his workplace and was employed on a yearlong probationary period. After receiving a “fully successful” performance review, his new supervisor criticized his productivity, which later improved. The plaintiff filed an internal Equal Employment Opportunity (EEO) complaint alleging race-based disparate treatment and retaliation by his supervisor, referencing racially charged remarks and disparate scrutiny. Weeks after the complaint, the department received anonymous reports of several medication errors allegedly committed by the plaintiff. He admitted to most of these errors in a subsequent investigatory meeting. Days after mediation regarding his EEO complaint, which he voluntarily withdrew, the plaintiff was terminated just before his probationary period ended.The United States District Court for the Northern District of Illinois granted summary judgment for the Department, dismissing both the race discrimination and retaliation claims. The district court found that the plaintiff failed to establish a prima facie case of race discrimination, as there was no evidence he was treated less favorably than similarly situated employees outside his protected class. The court also concluded that the Department’s stated reasons for termination—medication errors—were legitimate and not shown to be pretextual. The retaliation claim was rejected for lack of evidence showing a causal connection between the EEO complaint and his termination.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s judgment. The appellate court held that the plaintiff failed to provide evidence that the Department’s stated nondiscriminatory reason for his termination was pretextual or that his protected activity was the but-for cause of his termination. The judgment for the Department was affirmed. View "Abayomi v Collins" on Justia Law

A firefighter with sixteen years of service in the Chicago Fire Department (“CFD”) was terminated after an investigation revealed that he had posted racially offensive and derogatory content on his public Facebook account. He openly identified himself as a CFD firefighter on his page, which included photos in uniform, and his posts targeted Black and Asian Americans, groups served by the CFD. The posts prompted complaints from members of the public, leading to an Office of Inspector General investigation. The investigation concluded that the firefighter’s posts undermined public trust and recommended his dismissal, which the Fire Commissioner approved. The firefighter unsuccessfully challenged his termination through arbitration.He then sued the City of Chicago and two CFD officials in the United States District Court for the Northern District of Illinois, Eastern Division, alleging his termination violated his First Amendment rights and challenging the City’s social media policy as unconstitutionally vague and overbroad. The district court granted summary judgment for the City, holding that the firefighter’s posts were not protected by the First Amendment because they did not address matters of public concern. Alternatively, the court found that, even if the posts did touch on public concern, the City’s interest in departmental efficiency and maintaining public trust outweighed his free speech interests.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court found that the district court erred in its analysis of public concern, concluding that the posts could be seen as addressing matters of public concern. However, applying the Pickering balancing test, the appellate court held that the City’s interests in preserving public trust, especially given the firefighter’s public identification with the CFD and the nature of his posts, outweighed his speech interests. The court affirmed summary judgment in favor of the City. View "Inendino v Nance-Holt" on Justia Law

An employee was terminated from her position as a court officer after failing to comply with her employer’s COVID-19 vaccination mandate. She had requested a religious exemption, submitting several documents in support, but her application was denied by the employer’s review committee. After resubmitting forms and additional statements, the employer maintained its denial and ultimately terminated her for noncompliance. Several months later, the vaccination requirement was rescinded, and terminated employees, including the plaintiff, were allowed to seek reinstatement.Following her termination, the plaintiff brought suit in the United States District Court for the Eastern District of New York, alleging a violation of Title VII due to the employer’s failure to accommodate her religious beliefs. The district court granted partial summary judgment in her favor, finding that she had established a prima facie case of religious discrimination based on the employer’s statements during discovery. The court also concluded that the employer had not shown that granting the accommodation would have been an undue hardship. The district court’s decisions rested in part on treating certain statements by the employer as judicial admissions regarding the adequacy of her exemption request.The United States Court of Appeals for the Second Circuit reviewed the district court’s judgment. The Second Circuit held that the standard for a prima facie case for failure to accommodate religion under Title VII was changed by EEOC v. Abercrombie & Fitch Stores, Inc., requiring proof that the employee actually needed an accommodation and that the employer’s motive to avoid that accommodation was a factor in an adverse employment decision. The court found that the district court did not apply the correct standard and improperly treated discovery statements as judicial admissions. The Second Circuit vacated the judgment and remanded the case for further proceedings. View "Bergin v. N.Y. State Unified Court System" on Justia Law