Justia Labor & Employment Law Opinion Summaries

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The case involves two American Airlines pilots, James P. Scanlan and Carla Riner, who sued their employer for failing to pay them and provide certain benefits while they were on short-term military leave. They claimed that the airline violated the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA), which provides employees on military leave the right to receive the same employment benefits as other similarly situated employees. They also claimed that the airline breached their profit-sharing plan by failing to account for imputed earnings during periods of military leave.The District Court granted summary judgment for the airline on all claims. It held that the pilots could not prevail on their USERRA claims because short-term military leave is not comparable to jury-duty or bereavement leave when comparing duration, frequency, control, and purpose. It also concluded that, under Texas law, the profit-sharing plan unambiguously excludes imputed income from periods of military leave.The United States Court of Appeals for the Third Circuit affirmed the judgment for the airline on the breach of contract claim. However, it reversed the judgment for the airline on the USERRA claims, stating that a reasonable jury could find that short-term military leave is comparable to jury-duty leave or bereavement leave based on the three factors mentioned in the implementing regulation, and any other factors it may consider. The case was remanded for further proceedings on the USERRA claims. View "Scanlan v. American Airlines Group Inc." on Justia Law

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The Trustees of the New York State Nurses Association Pension Plan (the Trustees) and White Oak Global Advisors, LLC (White Oak) entered into an investment management agreement, which included an arbitration clause. The Trustees later brought several fiduciary duty claims against White Oak under the Employee Retirement Income Security Act (ERISA), which were resolved through arbitration. The arbitrator issued an award in favor of the Trustees, which the Trustees sought to confirm in the United States District Court for the Southern District of New York.White Oak appealed the confirmation, arguing that the district court lacked jurisdiction and that the court erroneously interpreted the award. The United States Court of Appeals for the Second Circuit affirmed the district court's jurisdiction, finding that the Trustees' petition to confirm the award was cognizable under ERISA § 502(a)(3). The court also affirmed the district court's interpretation of the award regarding the disgorgement of pre-award interest and the "Day One" fees. However, the court vacated and remanded the district court's confirmation of the disgorgement of White Oak's "profits," finding the award too ambiguous to enforce. The court also vacated and remanded the district court's order for White Oak to pay the Trustees' attorneys' fees and costs, finding the district court's findings insufficiently specific. View "Trustees of the NYSNAPP v. White Oak Glob. Adv." on Justia Law

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The case revolves around an incident that occurred on June 30, 2017, when Henry Bello, a former employee of Bronx-Lebanon Hospital (BLH), entered the hospital armed with a rifle and opened fire, killing one doctor and wounding five members of the medical staff, including Justin Timperio, a first-year resident. Bello and Timperio were strangers prior to the shooting; they never worked at BLH at the same time and had no other prior contact. Following the incident, BLH notified the Workers' Compensation Board (WCB) of Timperio's injuries. Timperio also filed a negligence action in federal court against BLH and the store that sold Bello the rifle.The Workers' Compensation Law Judge (WCLJ) determined that Timperio's injuries were compensable under the Workers' Compensation Law (WCL). Timperio appealed to the WCB, which affirmed the decision. However, the Appellate Division reversed the decision, holding that the lack of record evidence establishing any employment-related animus was sufficient to rebut the presumption in WCL § 21 (1) and concluded that the claim was therefore not compensable.The New York Court of Appeals reversed the decision of the Appellate Division. The court clarified the operation of the rebuttable presumption set forth in Workers' Compensation Law § 21 (1), which provides that when an injury arises in the course of a worker's employment, it is presumed to arise out of that worker's employment and therefore is compensable, absent substantial evidence to the contrary. The court held that in cases involving assaults that occur at work, a lack of evidence as to the motivation for the assault does not rebut that presumption. The court concluded that the presumption applied and was unrebutted in this case, and the Appellate Division's contrary conclusion was error. Therefore, the order of the Appellate Division was reversed, and the decision of the Workers' Compensation Board was reinstated. View "In re Timperio v Bronx-Lebanon Hospital" on Justia Law

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Isabel Garcia, an employee of RAC Acceptance East, LLC (RAC), filed a lawsuit against RAC, Stoneledge Furniture LLC (Stoneledge), and Inderjit Singh, alleging ten claims related to sexual harassment. RAC, Stoneledge, and Singh sought to compel arbitration based on an arbitration agreement they claimed Garcia electronically signed during her employment onboarding process. Garcia denied signing the agreement and argued that RAC failed to prove she executed the agreement.The trial court denied the petitions to compel arbitration. It found that while RAC had initially shown an agreement to arbitrate by providing the agreement, Garcia's denial of signing the agreement shifted the burden back to RAC to prove by a preponderance of the evidence that her electronic signature was authentic. The court found that RAC failed to meet this burden as the declaration provided by RAC did not present sufficient details of the onboarding process to establish how Garcia must have signed the agreement. The court also found that the agreement did not have the appearance of an electronically signed document created in Taleo, the third-party electronic workforce management platform used by RAC.On appeal, the Court of Appeal of the State of California First Appellate District Division Three affirmed the trial court's decision. The appellate court found that the trial court did not err in deciding whether any agreement to arbitrate existed in the first place, rather than delegating that decision to an arbitrator. The appellate court also found that RAC failed to prove the existence of the arbitration agreement. The court concluded that RAC's evidence did not show that only Garcia could have placed the electronic signature on the arbitration agreement. The court also found that the trial court did not abuse its discretion in denying RAC’s request for an evidentiary hearing. View "Garcia v. Stoneledge Furniture LLC" on Justia Law

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The plaintiff, Ronald Hittle, was the Fire Chief for the City of Stockton, California. He alleged that he was terminated from his position due to his religion, specifically his attendance at a religious leadership event. The City of Stockton, former City Manager Robert Deis, and former Deputy City Manager Laurie Montes were named as defendants. The City had hired an independent investigator, Trudy Largent, to investigate various allegations of misconduct against Hittle. Largent's report sustained almost all of the allegations, including Hittle's use of city time and a city vehicle to attend a religious event, his failure to properly report his time off, potential favoritism of certain Fire Department employees based on a financial conflict of interest not disclosed to the City, and endorsement of a private consultant's business in violation of City policy.The United States District Court for the Eastern District of California granted summary judgment in favor of the defendants. The court found that Hittle failed to present sufficient direct evidence of discriminatory animus in the defendants' statements and the City's notice of intent to remove him from City service. The court also found that Hittle failed to present sufficient specific and substantial circumstantial evidence of religious animus by the defendants.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court held that employment discrimination claims under Title VII and the California Fair Employment and Housing Act are analyzed under the McDonnell Douglas burden-shifting framework. The court concluded that Hittle failed to present sufficient direct evidence of discriminatory animus in the defendants' statements and the City's notice of intent to remove him from City service. Hittle also failed to present sufficient specific and substantial circumstantial evidence of religious animus by the defendants. The court found that the district court's grant of summary judgment in the defendants' favor was appropriate where the defendants' legitimate, non-discriminatory reasons for firing Hittle were sufficient to rebut his evidence of discrimination, and he failed to persuasively argue that these non-discriminatory reasons were pretextual. View "HITTLE V. CITY OF STOCKTON" on Justia Law

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The case involves plaintiffs Nancy Mator and Robert Mator, who are participants in the Wesco Distribution, Inc. Retirement Savings Plan. They sued Wesco Distribution, Inc., its fiduciaries, and the Plan, alleging that they violated fiduciary duties imposed by the Employee Retirement Income Security Act of 1974 (ERISA) by paying excessive recordkeeping fees and failing to monitor the Plan. The District Court dismissed the complaint with prejudice.The plaintiffs appealed to the United States Court of Appeals for the Third Circuit. They argued that the District Court erred in dismissing their complaint, which alleged that Wesco breached its fiduciary duties under ERISA by causing the Plan to pay excessive recordkeeping fees, offering retail-class shares of mutual funds, and failing to monitor those responsible for the Plan.The Court of Appeals agreed with the plaintiffs. It found that the plaintiffs' allegations were sufficient to state a claim for breach of fiduciary duty. The Court noted that the plaintiffs provided specific plan comparators and plausibly alleged that the services purchased were sufficiently similar to render the comparisons valid. The Court also found that the plaintiffs adequately alleged a fiduciary breach based on the Plan’s offerings of retail-class mutual fund shares.The Court of Appeals vacated the District Court's dismissal of the complaint and remanded the case for further proceedings. View "Mator v. Wesco Distribution Inc" on Justia Law

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The case involves the interpretation of Section 3 of the Federal Arbitration Act (FAA), which outlines procedures for enforcing arbitration agreements in federal court. The petitioners, current and former delivery drivers for an on-demand delivery service operated by the respondents, filed a lawsuit alleging violations of federal and state employment laws. The respondents moved to compel arbitration and dismiss the suit. The petitioners agreed that their claims were arbitrable but argued that Section 3 of the FAA required the District Court to stay the action pending arbitration rather than dismissing it entirely. The District Court issued an order compelling arbitration and dismissed the case without prejudice. The Ninth Circuit affirmed the decision.The Supreme Court of the United States reversed the Ninth Circuit's decision. The Supreme Court held that when a district court finds that a lawsuit involves an arbitrable dispute and a party has requested a stay of the court proceeding pending arbitration, Section 3 of the FAA compels the court to issue a stay, and the court lacks discretion to dismiss the suit. The Court reasoned that the statutory text, structure, and purpose all point to this conclusion. The Court further explained that the FAA's structure and purpose confirm that a stay is required. The Court concluded that staying rather than dismissing a suit comports with the supervisory role that the FAA envisions for the courts. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Smith v. Spizzirri" on Justia Law

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Matthew Meinen, a white male, filed a lawsuit against his former employer, Bi-State Development Agency, alleging racial and gender discrimination, hostile work environment, and retaliation. Meinen claimed that he was harassed by an unidentified female African American co-worker, who made inappropriate comments and physical contact. He reported these incidents to his and her supervisors. In March 2021, during an unrelated investigation, Meinen informed a Bi-State human resources employee about his concerns. He was advised to write a disciplinary warning, which he did and delivered to the female co-worker. Meinen was terminated in May 2021 and subsequently filed a claim with the Equal Employment Opportunity Commission (EEOC). He then commenced an action in Missouri state court, which Bi-State removed to federal court.The United States District Court for the Eastern District of Missouri dismissed Meinen's claims for failure to state a claim. The court applied the McDonnell Douglas framework to evaluate Meinen’s allegations of discrimination. It found that Meinen failed to show that he was a member of a protected class, was qualified to perform the job, experienced an adverse employment action, and that similarly situated employees outside of the protected class were treated differently. The court also found that the allegations of harassment were not sufficiently severe or pervasive to create an abusive working environment.Upon appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that Meinen failed to plead sufficient facts to give rise to an inference of causation beyond mere speculation for his retaliation claim. It also concurred with the lower court's application of the McDonnell Douglas framework and its conclusion that Meinen's allegations were insufficient to give rise to an inference of discrimination. Finally, the court agreed that the alleged harassment was not severe or pervasive enough to create a hostile work environment. View "Meinen v. Bi-State Development Agency" on Justia Law

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The case involves plaintiffs Christopher Maia and Sean Howarth, who were employed as laborers for defendant IEW Construction Group. The company required them to perform “pre-shift” and “post-shift” work, for which they were not paid. Both Maia and Howarth were laid off in November 2021. In April 2022, they filed a class action complaint alleging that IEW violated the Wage Payment Law (WPL) and the Wage and Hour Law (WHL).The trial judge held that Chapter 212, which amended the WPL and WHL, does not apply retroactively and thus dismissed plaintiffs’ claims for conduct that arose prior to Chapter 212’s effective date of August 6, 2019. The Appellate Division reversed this decision.The Supreme Court of New Jersey granted leave to appeal. The court held that Chapter 212 is to be applied prospectively to conduct that occurred on or after August 6, 2019, not retroactively to conduct that occurred before that date. The trial judge properly dismissed the portions of the complaint relying on Chapter 212 but arising from conduct prior to its effective date. The court reversed the Appellate Division’s judgment, reinstated the trial judge’s order partially dismissing plaintiffs’ complaint, and remanded for further proceedings. View "Maia v. IEW Construction Group" on Justia Law

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The case involves Nancy Anaya-Smith, the next of kin of Michael Brian Smith, who was killed in a single-car accident while he was a passenger in a company vehicle owned by Fixtures & Drywall Company of Oklahoma (FADCO). The vehicle was being driven by Smith's coworker, Duane Clark. Anaya-Smith alleges that Clark's negligence caused the fatal accident. At the time of the accident, FADCO maintained an insurance policy with Federated Mutual Insurance Company (Federated). The policy provided up to $1,000,000 of liability coverage per accident and an additional $6,000,000 of liability coverage per accident under an umbrella policy. However, FADCO had rejected uninsured motorist (UM) coverage for all employees, except for its directors, officers, partners, owners, and their family members.The United States District Court for the Western District of Oklahoma granted summary judgment in favor of Federated, concluding that the vehicle was an uninsured vehicle at the time of the accident because Clark is immune from tort liability under the workers' compensation exclusive remedy provision, and that FADCO's policy providing UM coverage for some individuals who qualify as insureds but rejecting UM coverage for other insureds does not violate Oklahoma law. Anaya-Smith appealed from the summary judgment order.The Supreme Court of the State of Oklahoma answered the first certified question in the affirmative, holding that the vehicle qualifies as an uninsured motor vehicle within the meaning of Oklahoma law. The court answered the second certified question in the negative, concluding that the plain language of Oklahoma law requires a named insured to either elect or reject uninsured/underinsured motorist coverage for all insureds under the policy, treating every insured in the same manner. The court declined to answer the third certified question as the record was undeveloped and the parties did not submit legal arguments pertaining to it. View "Anaya-Smith v. Federated Mutual Insurance Co." on Justia Law