Justia Labor & Employment Law Opinion Summaries

An employee of the Department of Veterans Affairs began experiencing respiratory issues at work, which she attributed to the building environment. Over several years, she requested various accommodations, including changes to her work schedule, relocation of her workstation, and the use of air purifiers. The Department provided some accommodations, but the employee found them ineffective. In 2012, she was diagnosed with breast cancer and submitted a Family and Medical Leave Act (FMLA) form to request leave for treatment. Later, she learned that a union steward had been informed of her cancer diagnosis by a human resources manager, which she had not expected. After returning to work, she continued to request further accommodations, eventually being allowed to work from home full-time.The United States District Court for the Middle District of Florida granted summary judgment in favor of the Department on all claims, including disability discrimination, failure to accommodate, unlawful disclosure of medical information, and retaliation or hostile work environment. The court found that the Department had provided reasonable accommodations, that there was no evidence of discrimination or retaliation, and that the employee had not shown a tangible injury from the alleged disclosure of her medical information.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s summary judgment on the claims of disability discrimination, failure to accommodate, retaliation, and hostile work environment. The appellate court agreed that the Department had made reasonable efforts to accommodate the employee and that her dissatisfaction with the accommodations did not amount to a legal violation. However, the Eleventh Circuit reversed the summary judgment on the unlawful disclosure claim, holding that requiring medical information for FMLA leave constituted an employer inquiry under the Rehabilitation Act, and that there were genuine issues of fact as to whether confidential medical information was improperly disclosed and whether the employee suffered a tangible injury as a result. The case was remanded for further proceedings on the unlawful disclosure claim. View "Mullin v. Secretary, Department of Veterans Affairs" on Justia Law

An employee of a multinational information technology company alleged that his employer engaged in fraudulent practices by obtaining less expensive L-1 and B-1 visas for foreign workers who, according to him, should have been sponsored under the more costly H-1B visa program. He claimed this allowed the company to avoid paying higher application fees and payroll taxes owed to the U.S. government. The employee also asserted that after he reported these alleged practices internally, the company retaliated against him by imposing unrealistic performance goals, removing him from a key client account, and ultimately terminating his employment.After the employee filed a qui tam action under the False Claims Act (FCA) in the United States District Court for the District of Columbia, the government declined to intervene. The district court dismissed the employee’s first amended complaint, holding that he failed to state a claim for a reverse false claim under the FCA because the company was not obligated to pay higher payroll taxes or application fees for visas it never sought. The court also dismissed the retaliation claim, finding that the employee’s reports concerned only potential statutory and regulatory violations, not FCA-protected activity.On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the dismissal of the reverse false claim, concluding that the employer had no established obligation under the FCA to pay higher payroll taxes or H-1B visa fees for visas it did not apply for. However, the appellate court reversed the dismissal of the retaliation claim, holding that the employee sufficiently alleged he engaged in protected activity under the FCA and that the employer retaliated against him for this conduct. The case was remanded for further proceedings on the retaliation claim. View "United States v. Tata Consultancy Services, LTD" on Justia Law

An employee who worked as a packaging operator began experiencing left shoulder pain, which she attributed to her work activities. After seeking medical treatment, including surgery, her employer and its workers’ compensation insurer initially accepted her claim as work-related but later denied it based on an independent medical examination. While the workers’ compensation claim was pending, the employee’s health insurer paid for her medical expenses as required by Minnesota law when compensability is disputed. The employee then filed a workers’ compensation claim seeking a determination that her injury was compensable and that her employer should cover her medical expenses. The health insurer was notified of its right to intervene in the proceedings but did not do so within the statutory deadline.A compensation judge found the employee’s injury was work-related and compensable, but concluded that the employee could not bring a direct claim for medical expenses already paid by her health insurer, reasoning that only medical providers, not insurers, could be the subject of such claims. The judge also ruled that the health insurer’s failure to intervene extinguished its right to reimbursement. The Workers’ Compensation Court of Appeals (WCCA) reversed, holding that the employee could bring a direct claim for the medical expenses paid by the health insurer and that the employer and its insurer must reimburse the health insurer, despite its failure to intervene.The Minnesota Supreme Court reviewed the case. It held that, consistent with its recent decision in Johnson v. Concrete Treatments, Inc., an employee may bring a direct claim under the Workers’ Compensation Act for medical expenses related to a compensable work injury, even if those expenses were paid by a health insurer before compensability was determined. However, the Court also held that the WCCA erred in reviving the health insurer’s independent intervenor interest, which was extinguished by its failure to timely intervene. The Court affirmed in part and reversed in part. View "Brunner vs. Post Consumer Brands" on Justia Law

Two fiduciaries, who managed retirement and welfare funds for a New York City law enforcement union, were found to have improperly withdrawn over $500,000 from the union’s annuity fund. The withdrawals, which occurred over several years, were facilitated by one defendant preparing false authorization forms and the other signing and submitting them to the fund’s custodian. The funds were then transferred to the union’s operating account and used for unauthorized purposes, including personal enrichment and unrelated union expenses. The defendants misrepresented the nature of these withdrawals to both the fund’s custodian and union members, and they continued the scheme even after being warned by auditors that their actions were improper.The United States District Court for the Southern District of New York presided over a joint jury trial, where both defendants were convicted of wire fraud and conspiracy to commit wire fraud. One defendant was also convicted of conspiracy to defraud the United States and multiple counts of tax evasion. The district court denied motions to sever the trials, found the evidence sufficient to support the convictions, and imposed restitution and forfeiture orders. The court also addressed government discovery errors by granting a continuance and requiring early disclosure of materials, but declined to impose harsher sanctions.On appeal, the United States Court of Appeals for the Second Circuit reviewed claims of improper joinder, insufficient evidence, prosecutorial misconduct, ineffective assistance of counsel, and errors in restitution calculation. The court held that joinder was proper because the indictment sufficiently linked the fraud and tax offenses, the evidence was sufficient to support the convictions, and the attorney’s illness did not constitute per se ineffective assistance. The court also found no abuse of discretion in the district court’s handling of discovery issues or restitution calculation, and no reversible prosecutorial misconduct. The Second Circuit affirmed the district court’s judgment. View "United States v. Wynder" on Justia Law

A multiemployer pension fund managed by the Operating Engineers Local 324 Pension Fund assessed withdrawal liability against Ace-Saginaw Paving Company after Ace partially withdrew from the fund in December 2018. The dispute centered on the interest rate assumption used to calculate the withdrawal liability. Ace argued that the rate should match the fund’s minimum funding interest rate of 7.75%, resulting in a lower liability, while the fund’s actuary used a much lower rate of 2.27% (the PBGC rate), resulting in a significantly higher liability. The actuary’s choice of rate was based on policy considerations and a desire to protect the fund’s remaining employers, rather than his best estimate of the fund’s anticipated investment experience.The parties proceeded to arbitration, as required by ERISA. The arbitrator found that the actuary’s use of the 2.27% rate violated 29 U.S.C. § 1393(a)(1) because it was not the actuary’s best estimate of anticipated experience under the plan. The arbitrator ordered the fund to recalculate Ace’s withdrawal liability using a rate that complied with the statutory requirements. The United States District Court for the Eastern District of Michigan affirmed the arbitrator’s findings and granted summary judgment to Ace on the statutory violation, but declined Ace’s request to require use of the minimum funding rate as the remedy, instead allowing the fund’s actuary another opportunity to select a compliant rate.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the actuary’s use of the PBGC rate was not his best estimate and thus violated ERISA. The court also held that, on remand, the actuary may use a different rate from the minimum funding rate only if it is justified by factors that improve the accuracy of the withdrawal liability calculation, not by policy considerations. The court denied both parties’ requests for attorney’s fees. View "Ace-Saginaw Paving Co. v. Operating Engineers Local 324" on Justia Law

Donald Wright was employed by Honeywell International for fourteen years as a Dock B Operator. In 2021, Honeywell instituted a mandatory COVID-19 vaccination policy in response to a federal executive order affecting federal contractors. Wright, a Baptist Christian, requested a religious exemption from the policy, citing his belief in God-given bodily autonomy and referencing certain scriptural passages. He also submitted a third-party attestation from his daughter, who explained their shared religious beliefs. Honeywell denied his exemption request, stating that Wright had not adequately identified a sincerely held religious belief prohibiting vaccination. Wright was subsequently suspended and then terminated for failing to comply with the vaccination requirement.Wright filed a charge of discrimination with the Equal Employment Opportunity Commission and, after receiving a right-to-sue letter, brought suit in the United States District Court for the Middle District of Louisiana. He alleged religious discrimination and disparate treatment under Title VII. The district court granted summary judgment in favor of Honeywell on all claims, finding that Wright had not provided sufficient evidence to raise a genuine issue of material fact regarding the existence of a bona fide religious belief or that he had informed Honeywell of such a belief. Wright’s motion for reconsideration was denied, and he appealed, but only as to the religious discrimination claim.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s summary judgment decision de novo. The Fifth Circuit held that Wright had presented sufficient evidence to create a genuine dispute of material fact as to whether he held a bona fide religious belief and whether he informed Honeywell of that belief. The court reversed the district court’s grant of summary judgment on the Title VII religious discrimination claim and remanded the case for further proceedings. The court did not address the disparate treatment claim or the motion for reconsideration, as those issues were either not appealed or rendered moot. View "Wright v. Honeywell International" on Justia Law

Two students challenged the University of California’s policy that prohibits the employment of undocumented students who lack federal work authorization. The University’s longstanding practice allowed employment of undocumented students with Deferred Action for Childhood Arrivals (DACA) status, as they have federal work authorization, but excluded those without such authorization. After the federal government stopped accepting new DACA applications, the number of undocumented students without work authorization increased. The University considered changing its policy but ultimately decided against it, citing significant risks of federal enforcement under the Immigration Reform and Control Act (IRCA) and related regulations, and dissolved a working group tasked with exploring alternatives.The students filed a petition for a writ of mandate in the California Court of Appeal, First Appellate District, Division Four, arguing that the University’s policy was an abuse of discretion and violated the Fair Employment and Housing Act (FEHA) by discriminating based on immigration status. The court initially denied the petition, but the California Supreme Court granted review and transferred the case back, instructing the appellate court to reconsider. The University argued that its policy was based on risk assessment rather than a definitive interpretation of IRCA, and that even if the policy was discriminatory, the risk of federal enforcement justified its continuation.The California Court of Appeal, First Appellate District, Division Four, held that the University’s policy facially discriminates based on immigration status and that, under state law, such discrimination is only permissible if required by federal law, which the University did not establish. The court concluded that the University abused its discretion by relying solely on litigation risk as a justification for its policy. The court issued a writ of mandate directing the University to reconsider its policy using proper legal criteria. View "Munoz v. The Regents of the University of Cal." on Justia Law

A customer service analyst at a large corporation alleged that her supervisors created a hostile work environment characterized by inappropriate behavior and a culture of “machismo.” She reported these concerns to human resources, including claims of increased workload without overtime approval and specific instances of inappropriate conduct. The company investigated, found low morale but no evidence of discrimination or harassment, and paid her owed overtime. After her complaints, the analyst received escalating warnings about her work performance, culminating in the lowest possible rating on her annual review. She was then given the choice between a performance improvement plan or resignation. Following an emotional reaction to this meeting, the company withdrew the improvement plan option and terminated her employment.She filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging gender discrimination and retaliation under Title VII, and age discrimination and retaliation under the Age Discrimination in Employment Act. The district court granted summary judgment in favor of the employer, finding insufficient evidence to support her claims.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case de novo, considering whether a reasonable factfinder could conclude that her gender, age, or protected activity caused her termination. The court held that the plaintiff failed to identify similarly situated comparators who were treated more favorably, did not present evidence that her age was the “but for” cause of her termination, and could not establish a causal link between her complaints and adverse employment actions. The court found no evidence of pretext or retaliation and concluded that the record did not support her allegations. The Seventh Circuit affirmed the district court’s grant of summary judgment to the employer. View "Ontiveros v. Exxon Mobil Corporation" on Justia Law

Monica Richards, a long-time employee in her early fifties, applied for a promotion at Eli Lilly & Company after serving as an interim District Sales Manager. The promotion was instead awarded to a younger, less experienced candidate. Richards filed suit in federal court, alleging age discrimination under the Age Discrimination in Employment Act (ADEA) and Massachusetts law. She sought to proceed collectively on behalf of all Eli Lilly employees aged 40 or older who were denied promotions since February 2022, claiming a companywide bias favoring “Early Career Professionals” over older employees.In the United States District Court for the Southern District of Indiana, Richards moved for conditional certification of a collective action and requested that notice be sent to potential opt-in plaintiffs. The parties disputed the appropriate standard for issuing such notice. The district court applied the Lusardi “modest factual showing” standard, declined to consider the employer’s opposing evidence, and granted conditional certification, agreeing to send notice. Recognizing uncertainty in the law, the district court certified the question for interlocutory appeal under 28 U.S.C. § 1292(b).The United States Court of Appeals for the Seventh Circuit reviewed the case to clarify the standard for issuing notice in Fair Labor Standards Act (FLSA) and ADEA collective actions. The court held that, before notice may issue, plaintiffs must present evidence raising a material factual dispute as to whether the proposed collective is similarly situated. Both parties’ evidence must be considered, and the district court retains discretion to manage the process, including authorizing limited discovery or narrowing the scope of notice. The court rejected both the lenient Lusardi standard and heightened standards requiring proof by a preponderance of the evidence or a strong likelihood of similarity. The Seventh Circuit vacated the district court’s order and remanded for further proceedings under the clarified standard. View "Richards v. Eli Lilly & Company" on Justia Law

A high school in Indiana implemented a policy requiring teachers to address students by the first names listed in the school’s database, which, for transgender students, reflected their chosen names. A teacher objected to this policy on religious grounds, believing that using names inconsistent with students’ biological sex would violate his faith. The school initially accommodated him by allowing him to address all students by their last names only. After a year, complaints from students, parents, and staff led the school to rescind this accommodation, requiring the teacher to use students’ first names or face termination. The teacher resigned and later attempted to rescind his resignation, but the school treated it as final.The teacher sued the school corporation in the United States District Court for the Southern District of Indiana, alleging violations of Title VII for failure to accommodate his religion and for retaliation. The district court denied the teacher’s motion for summary judgment on the accommodation claim, finding a factual dispute about the sincerity of his religious beliefs. The court granted summary judgment to the school on both claims, concluding that accommodating the teacher imposed more than a de minimis cost due to student and staff complaints and potential Title IX liability. The court also found no evidence of pretext in the school’s stated reasons for its actions.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the case in light of the Supreme Court’s decision in Groff v. DeJoy, which clarified that an employer must show a “substantial” burden to deny a religious accommodation under Title VII. The Seventh Circuit held that material factual disputes remained regarding whether the accommodation caused an undue hardship on the school’s mission or exposed it to legal liability. The court affirmed the denial of summary judgment on the sincerity issue, affirmed the decision not to revisit the retaliation claim, reversed the grant of summary judgment to the school on the accommodation claim, and remanded for further proceedings. View "Kluge v. Brownsburg Community School Corporation" on Justia Law