Justia Labor & Employment Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals concluding that neither party had established proper venue in this workers' compensation case, holding that the record adequately demonstrated that venue was mandatory in Dallas County.Tex. Labor Code 410.252(b), a mandatory venue provision governing suits for judicial review of administrative decisions regarding workers' compensation benefits, requires that suit be brought in "the county where the employee resided at the time of the injury." At issue in this case was whether judicial review of the denial of the workers' compensation claim brought by a Texas Tech University offensive lineman who signed a contract to play for the Dallas Cowboys and was injured while attending the team's training camp in California was proper in Travis County, the county to which the insurer sought transfer, or Dallas County. A Dallas County jury found in favor of the plaintiff on his appeal of the denial of his workers' compensation claim. The court of appeals reversed, concluding that neither party had established proper venue. The Supreme Court reversed, holding that the plaintiff "resided" in Dallas County at the time of his injury, as required by section 410.252(b), and therefore, venue was mandatory in Dallas County. View "Fortenberry v. Great Divide Insurance Co." on Justia Law

The Supreme Court remanded this case stemming from a labor dispute between a union and city, holding that remand was required to establish whether the city complied with Local Government Code Chapter 174's compensation standards.When the City of Houston and the Houston Professional Fire Fighters' Association, Local 341 could not agree to an employment contract the Fire Fighters sued the City for compensation under the Fire and Police Employee Relations Act, codified in Chapter 174, claiming that the City failed to meet Chapter 174's compensation standards. Thereafter, the City's voters approved the "pay-parity amendment" amending the City's charter. The Houston Police Officers' Union sued the Fire Fighters seeking a declaration that Chapter 174 preempted the pay-parity amendment, rendering it unenforceable. In the first action, the trial court rejected the constitutional and immunity challenges brought by the City, and the court of appeals affirmed. In the second action, the court of appeals reversed, concluding that state law did not preempt the amendment. The Supreme Court affirmed as to the initial suit and reversed as to the second suit, holding (1) Chapter 174 does not violate constitutional separation of powers principles; (2) the Fire Fighters met the prerequisites for seeking Chapter 174 enforcement; and (3) Chapter 174 preempts the pay-parity amendment. View "City of Houston v. Houston Professional Fire Fighters' Ass'n, Local 341" on Justia Law

The Supreme Court reversed the decisions of the district court and employment appeal board affirming the decision of the department of workforce development denying Appellant's claim for unemployment benefits, holding that Appellant's claims on appeal were unavailing.Appellant, an apprentice electrician, attended a week-long training as part of his apprenticeship curriculum, and his employer didn't pay him for that week. Appellant filed a claim for unemployment benefits under Iowa Code 96.4(3), arguing that he met the statute's criteria that he be able to work, available for work, and actively seeking work. The department of workforce development denied the claim, and the employment appeal board and district court affirmed. The Supreme Court affirmed, holding that the board's decision that Appellant had not established his eligibility for benefits was not an erroneous interpretation of the law, unsupported by substantial evidence in the record, or an abuse of the board's discretion. View "Dornath v. Employment Appeal Bd." on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff's claims against Defendants for wrongful termination, workplace harassment, and age discrimination, holding that the district court properly granted summary judgment on all claims.Plaintiff, an at-will employee, was promptly fired after he texted his plant manager "FUCK You!" and "Believe who and what you want" following the manager's criticism of his job performance. In response to Plaintiff's complaint, Defendants moved for summary judgment on the grounds that Plaintiff was lawfully fired for insubordination. The district court granted summary judgment in favor of Defendants. The Supreme Court modified the McDonnell-Douglas burden-shifting framework for summary judgment on discrimination claims under the Iowa Civil Rights Act to align with the causation standard at trial and adopted and applied the good-faith "honest believe rule" to affirm Defendant's decision to terminate Plaintiff's employment for insubordination. View "Feeback v. Swift Pork Co." on Justia Law

The Supreme Court affirmed the judgment of the district court determining that social media posts directed toward local public figures from a public account of an officer of a local bank did not constitute misconduct in connection with work disqualifying the employee from unemployment benefits, holding that the district court did not err.The posts at issue were not sent from the employee's work, during work hours, or using the employer's equipment and did not contain information obtained in the capacity as an employee, mention the employee's position at the bank, or refer to coworkers or customers. The Department of Labor determined that the employee was disqualified for benefits for the week in which the discharge occurred plus fourteen weeks because he had been discharged for misconduct. The Appeal Tribunal reversed, holding that the employer's social media policy was insufficient to transform the employee's personal social media postings into misconduct connected with his work. The district court affirmed. The Supreme Court affirmed, holding that Defendant did not commit misconduct connected with his work, and therefore, the district court properly found that he was not disqualified for unemployment benefits. View "Pinnacle Bancorp v. Moritz" on Justia Law

The Supreme Court reversed the order of the single justice of the appeals court reversing the denial of Plaintiffs' motion for a preliminary injunction and vacated the injunction, holding that the single justice abused her discretion in enjoining Defendants from enforcing their December 2021 amended COVID-19 vaccination policy.Plaintiffs - the Boston Firefighters Union, the Boston Police Superior Officers Federation, and others - filed a complaint challenging Defendants' unilateral amendment of the COVID-19 vaccination policy for all city of Boston employees, seeking declaratory and injunctive relief. The superior court denied Plaintiffs' motion for injunctive relief, but a single justice of the appeals court reversed and ordered the entry of a preliminary injunction. The Supreme Court reversed, holding that the single justice abused her discretion in issuing the preliminary injunction because the potential harm to the city resulting from the spread of COVID-19 clearly outweighed the economic harm to employees. View "Boston Firefighters Union, Local 718, Internat'l Ass'n of Fire Fighters, AFL-CIO v. City of Boston" on Justia Law

The Supreme Court reversed the decision of the appellate court affirming the order of the superior court granting Defendant's motion for summary judgment as to the first count of Plaintiff's complaint in this action to recover damages for the allegedly wrongful discharge of Plaintiff, holding that summary judgment was improper.Defendant, a helicopter flight training school, hired Plaintiff as a flight instructor. When Plaintiff refused to share fees that he expected to receive as a Federal Aviation Administration certified pilot examiner Defendant terminated his employment. Plaintiff brought this action alleging wrongful discharge in violation of the public policy embodied in Conn. Gen. Stat. 31-73(b). The Supreme Court held that the appellate court improperly upheld the trial court's summary judgment for Defendant because genuine material questions of fact remained. View "Dunn v. Northeast Helicopters Flight Services, LLC" on Justia Law

After the EEOC closed its investigation into Plaintiff’s charge of discrimination, the agency issued Plaintiff a right-to-sue notice. This notice, however, only reached Plaintiff’s attorney and not Plaintiff himself. The EEOC then sent a subsequent notice acknowledging that the first had not reached Plaintiff and advising him that his 90-day window in which to file suit began to run upon its—the second notice’s—receipt. Plaintiff filed his complaint 141 days after his attorney is presumed to have received the first notice and 89 days after Plaintiff and his attorney received the second. The district court dismissed Plaintiff’s suit as untimely and held that equitable tolling was unavailable.   The Fifth Circuit vacated the district court’s order dismissing Plaintiff’s complaint. The court explained that Plaintiff’s case did not present the kind of exceptional circumstances that may warrant equitable tolling; the district court failed to consider controlling precedent from this court that tolling may be available when the EEOC affirmatively misleads a claimant about the time in which he must file his federal complaint. The court wrote that this was an abuse of discretion. Further, the court found that the district court did not proceed beyond this first prong of the tolling analysis the record at this motion to dismiss stage does not disclose whether Plaintiff diligently pursued his rights. View "Bernstein v. Maximus Federal Services" on Justia Law

Plaintiff, a former driver for Defendant Lyft, Inc., filed suit against Lyft under the Private Attorneys General Act of 2004 (PAGA). He alleged that Lyft misclassified him and other drivers as independent contractors rather than employees, thereby violating multiple provisions of the Labor Code. Lyft moved to compel arbitration based on the arbitration provision in the “Terms of Service” (TOS) that it required its drivers to accept. The trial court denied the motion, finding the PAGA waiver in the arbitration provision unenforceable under then-controlling California law. Lyft appealed, and the Second Appellate District affirmed the denial of Lyft’s motion to compel arbitration. Lyft petitioned the United States Supreme Court for a writ of certiorari. The Court granted Lyft’s petition and remanded the case for further consideration in light of Viking River Cruises, Inc. v. Moriana (2022).   The Second Appellate District reversed in part and affirmed in part the trial court’s order. The court remanded the matter to the trial court with directions to (1) enter an order compelling Plaintiff to arbitrate his individual PAGA claim and (2) conduct further proceedings regarding Plaintiff’s non-individual claims. The court explained that it is not bound by the analysis of PAGA standing set forth in Viking River. PAGA standing is a matter of state law that must be decided by California courts. The court explained that until it has guidance from the California Supreme Court, its review of PAGA and relevant state decisional authority leads the court to conclude that a plaintiff is not stripped of standing to pursue non-individual PAGA claims simply because their individual PAGA claim is compelled to arbitration. View "Seifu v. Lyft, Inc." on Justia Law

The First Circuit affirmed the order of the district court granting Defendant's motion for summary judgment and dismissing Plaintiff's action alleging gender discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. and other claims under Puerto Rico law, holding that Defendant was not entitled to relief on her assignments of error.Plaintiff sued Defendant after she was not selected for promotion and her employment was terminated. The district court dismissed Plaintiff's claims on summary judgment, finding that Plaintiff failed to show that Defendant's decisions relating to Plaintiff's employment were motivated by discriminatory animus. The First Circuit affirmed, holding that summary judgment was proper as to all of Plaintiff's claims. View "Lopez-Hernandez v. Terumo Puerto Rico LLC" on Justia Law