Justia Labor & Employment Law Opinion Summaries

Courtney Galloway, a used car sales manager at Husker Auto Group, LLC, was terminated from her position in January 2019. Galloway claimed her termination was in retaliation for investigating and reporting a fraudulent sales scheme involving a fellow employee, Ryan Mathis. She alleged that the scheme involved selling vehicles to straw purchasers to evade state sales tax and Mercedes-Benz export policies, and that upper management was aware of and benefited from the scheme.Galloway filed a claim with the Nebraska Equal Opportunity Commission (NEOC), alleging whistleblower retaliation under the Nebraska Fair Employment Practice Act (NFEPA). The NEOC dismissed her claim, concluding that she had not engaged in protected activity because she reported a coworker’s actions, not those of her employer. The NEOC also found no evidence that the individual who terminated her employment was aware of her protected activity.Galloway then filed a lawsuit in the district court for Lancaster County, Nebraska, asserting claims of retaliation under the NFEPA and wrongful discharge under Nebraska’s public policy exception to the at-will employment rule. The district court granted summary judgment in favor of Husker Auto, agreeing with the NEOC’s findings.The Nebraska Supreme Court reviewed the case de novo. The court found that there were genuine issues of material fact regarding whether Husker Auto was involved in or knew of the fraudulent scheme and whether the company knew of Galloway’s role in investigating the scheme. The court noted conflicting testimony and evidence about Husker Auto’s knowledge and involvement, as well as Galloway’s performance and the reasons for her termination. Consequently, the court reversed the district court’s summary judgment and remanded the case for further proceedings. View "Galloway v. Husker Auto Group" on Justia Law

Hemphill Construction Company, Inc. (Hemphill) entered into a contract with the City of Jackson and subsequently subcontracted Interstate Carbonic Enterprises (ICE) for a project. Gay Lynn Harris, Jr., an owner and officer of ICE, was severely injured while working on the project in September 2020. Harris sought workers’ compensation benefits from Hemphill, but an Administrative Judge (AJ) ruled that Harris was not entitled to these benefits because he had voluntarily opted out of ICE’s workers’ compensation insurance coverage. Neither party appealed the AJ’s decision.In March 2022, Harris filed a negligence complaint against Hemphill in the Circuit Court of the First Judicial District of Hinds County. Hemphill moved to dismiss the complaint, claiming tort immunity under the exclusive remedy provision of the Mississippi Workers’ Compensation Act (MWCA). The trial court agreed and granted Hemphill’s motion to dismiss. Harris appealed, arguing that tort immunity did not apply and that judicial estoppel should apply. Hemphill contended that Harris had not exhausted his administrative remedies.The Supreme Court of Mississippi reviewed the case and found that Harris was not required to exhaust his administrative remedies before filing his negligence suit. The court held that Hemphill was entitled to tort immunity because it had contractually required ICE to obtain workers’ compensation insurance for its employees, thus satisfying the statutory requirement to secure payment under the MWCA. The court affirmed the trial court’s decision to dismiss Harris’s negligence claim against Hemphill. View "Harris v. Hemphill Construction Company, Inc." on Justia Law

The National Collegiate Athletic Association (NCAA) conducted an investigation into the University of Mississippi's football program, which included allegations against Barney Farrar, an assistant athletics director. The NCAA found Farrar guilty of multiple recruiting violations and issued a five-year show-cause order, restricting his employment in recruiting roles at NCAA member institutions. Farrar appealed the decision, but the NCAA's Infractions Appeals Committee upheld the findings and penalties.Farrar then filed a lawsuit in the Circuit Court of Lafayette County, alleging negligence, denial of a fair hearing, malicious interference with employment, denial of due process under the Mississippi Constitution, and usurpation of judicial function. The trial court granted summary judgment in favor of the NCAA on all claims except for malicious interference with employment and denial of due process. The NCAA petitioned for an interlocutory appeal on these two issues.The Supreme Court of Mississippi reviewed the case and applied a de novo standard of review. The court held that the NCAA is not a state actor and thus not subject to due process requirements under the Mississippi Constitution. The court also found that Farrar failed to provide evidence of malice necessary to support his claim of malicious interference with employment. Consequently, the court reversed the trial court's denial of summary judgment and rendered judgment in favor of the NCAA. View "National Collegiate Athletic Association v. Farrar" on Justia Law

Capitol Street Surgery Center, an outpatient surgical clinic, hired Marty Lauster, a licensed interventional radiology technologist (IR tech), in 2019. In November 2020, during a staff meeting, Lauster objected to a nurse moving an imaging device called a C-arm, stating that nurses are not permitted to operate it. Two weeks later, Lauster was fired by Brandon Ehret, the clinic’s top administrator. Lauster filed a charge of unfair labor practices with the National Labor Relations Board (NLRB), claiming he was terminated due to his objection at the meeting.An administrative law judge (ALJ) heard the case and found that Capitol fired Lauster because of his protected labor activity, issuing a make-whole award. The NLRB affirmed the ALJ’s decision. Capitol petitioned for review, arguing that Lauster was fired due to performance issues, not because of his comment about the C-arm.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court noted that to prove a prima facie section 8(a)(1) violation, the NLRB must establish that the employee engaged in protected activity, the employer’s decisionmaker was aware of this activity, and the decisionmaker took adverse action because of animus toward the protected activity. The court found that the ALJ’s determination that Ehret knew about Lauster’s comment was not supported by substantial evidence. Ehret testified that he was unaware of the comment when he decided to fire Lauster, and this was corroborated by other witnesses.The Seventh Circuit granted Capitol’s petition for review, vacated the NLRB’s decision and order, and denied the petition for enforcement, concluding that the NLRB failed to prove that Ehret knew of Lauster’s protected activity when he made the termination decision. View "National Labor Relations Board v. Capitol Street Surgery Center, LLC" on Justia Law

Jorge Baez sued BayMark Detoxification Services, Inc., alleging disability discrimination under Massachusetts law, claiming BayMark Detox was his former employer. Baez was repeatedly informed that he had sued the wrong party but did not amend his complaint in time. BayMark Detox moved for summary judgment, asserting it was never Baez's employer. Baez then requested to amend his complaint to name the correct employer, but the district court granted summary judgment to BayMark Detox, denied Baez's Rule 60(b) motion for relief, and ordered Baez to pay costs.Baez initially worked for Community Health Care, Inc. (CHC), which was acquired by BayMark Health Services, Inc. (BHS). During the COVID-19 pandemic, Baez worked from home but was later terminated after an audit revealed billing errors. Baez filed a discrimination complaint against BayMark Detox, which was removed to federal court. BayMark Detox, a separate entity from CHC, stated it never employed Baez. The district court set a deadline for amending pleadings, which Baez missed.The United States District Court for the District of Massachusetts granted summary judgment to BayMark Detox, finding no evidence that BayMark Detox was Baez's employer. The court denied Baez's request to amend his complaint, citing his failure to show good cause for the delay. The court also denied Baez's Rule 60(b) motion, rejecting the argument that Massachusetts procedural rules should apply. The court awarded costs to BayMark Detox.The United States Court of Appeals for the First Circuit affirmed the district court's rulings, agreeing that Baez failed to name the correct employer and did not demonstrate good cause for amending his complaint late. The court also upheld the award of costs to BayMark Detox. View "Baez v. BayMark Detoxification Services, Inc." on Justia Law

Derek Hall, a Senior Account Executive at UiPath Incorporated, alleged retaliation under the Age Discrimination in Employment Act (ADEA) after being placed on a Performance Improvement Plan (PIP) and subsequently terminated. Hall, who was 62 years old, filed an internal complaint against his supervisor for age discrimination on the same day he was placed on the PIP. UiPath and Hall later entered into a Separation and Release of Claims agreement, terminating Hall's employment. Hall then joined Accelirate, Inc., but was terminated shortly after his former supervisor at UiPath informed Accelirate of complaints about Hall.The United States District Court for the Western District of Texas granted summary judgment in favor of UiPath. The court found that Hall failed to establish a causal link between his protected activity (the age discrimination complaint) and the adverse employment action (his termination). Additionally, Hall did not successfully rebut UiPath’s legitimate, non-discriminatory reason for the adverse action, which was based on Hall's performance issues.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court affirmed the district court’s grant of summary judgment, noting that Hall did not challenge the district court’s determination that UiPath had provided a legitimate, non-discriminatory reason for the adverse action. Hall's failure to address this aspect of the district court’s analysis in his appeal effectively forfeited his argument. Consequently, the appellate court did not need to address the issue of causation and upheld the summary judgment in favor of UiPath. View "Hall v. UiPath" on Justia Law

Angel Matta was hired by Dakota Provisions in February 2020 as a production worker. Matta had attendance issues documented by his employer and was injured at work on March 23, 2020, leading to several weeks of missed work. He filed a workers' compensation claim and was terminated by Dakota Provisions one month later. Matta then filed a lawsuit alleging wrongful termination and violation of public policy. Dakota Provisions moved for summary judgment, which the circuit court granted. Matta appealed the decision.The Circuit Court of the Third Judicial Circuit in Beadle County, South Dakota, reviewed the case. The court granted summary judgment in favor of Dakota Provisions, concluding that Matta was an at-will employee and could be terminated for any lawful reason. The court also found that Matta failed to exhaust administrative remedies for his disability discrimination claim and did not recognize a common law tort for retaliatory discharge based on a disability.The Supreme Court of the State of South Dakota reviewed the case. The court affirmed the circuit court's decision in part, agreeing that Matta was an at-will employee and that his termination did not violate public policy based on disability discrimination. However, the court reversed the summary judgment regarding Matta's claim of retaliatory discharge for filing a workers' compensation claim. The court found that there were genuine issues of material fact regarding whether Matta's termination was pretextual and retaliatory, given the proximity of his termination to his workers' compensation claim and the inconsistent reasons provided by Dakota Provisions for his termination. The case was remanded for further proceedings on this claim. View "Matta v. Dakota Provisions" on Justia Law

Stephnie Trujillo filed a complaint against her former employer, J-M Manufacturing Company (JMM), and four former coworkers, alleging unlawful sexual/gender discrimination, harassment, failure to prevent such actions, retaliation, and seeking injunctive relief. The parties negotiated and entered into a post-dispute stipulation for arbitration, which was approved by the trial court. Arbitration commenced, and JMM paid the arbitrator’s invoices for over a year. However, JMM failed to pay an invoice by the due date of September 12, 2022, but paid it immediately upon being reminded on October 18, 2022. Trujillo then sought to withdraw from arbitration under California Code of Civil Procedure section 1281.98, which the trial court granted.The Superior Court of Los Angeles County granted Trujillo’s motion to withdraw from arbitration, finding that JMM’s late payment constituted a material breach under section 1281.98, which does not allow exceptions for inadvertent delays or lack of prejudice. The court lifted the stay on trial court proceedings, allowing the case to proceed in court.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that section 1281.98 did not apply because the parties entered into a post-dispute stipulation to arbitrate, not a pre-dispute arbitration agreement. Additionally, JMM was not considered the “drafting party” as defined by section 1280, subdivision (e), which refers to the company that included a pre-dispute arbitration provision in a contract. The appellate court reversed the trial court’s order and remanded with instructions to deny Trujillo’s motion to withdraw from arbitration and to reinstate the stay of trial court proceedings pending completion of arbitration. View "Trujillo v. J-M Manufacturing Co., Inc." on Justia Law

Edgar Gonzalez worked for Nowhere Santa Monica, one of ten related LLCs operating Erewhon markets in Los Angeles. As a condition of his employment, he signed an arbitration agreement with Nowhere Santa Monica. Gonzalez later filed a class action lawsuit against all ten Nowhere entities, alleging various Labor Code violations. He claimed that all entities were his joint employers, sharing control over his employment conditions.The Superior Court of Los Angeles County granted the motion to compel arbitration for Nowhere Santa Monica but denied it for the other entities, finding no evidence that Gonzalez's claims against the non-signatory entities were intertwined with his claims against Nowhere Santa Monica. Gonzalez then dismissed his complaint against Nowhere Santa Monica, and the other entities appealed.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that Gonzalez was equitably estopped from avoiding arbitration with the non-Santa Monica entities because his claims against them were intimately founded in and intertwined with his employment agreement with Nowhere Santa Monica. The court reasoned that Gonzalez's joint employer theory inherently linked his claims to the obligations under the employment agreement, which contained an arbitration clause. Therefore, it would be unfair for Gonzalez to claim joint employment for liability purposes while denying the arbitration agreement's applicability.The appellate court reversed the lower court's order denying the motion to compel arbitration for the non-Santa Monica entities, concluding that all of Gonzalez's claims should be arbitrated. View "Gonzalez v. Nowhere Beverly Hills LLC" on Justia Law

Ashley Howell, a temporary pre-licensed psychiatric technician, was employed by the Department of State Hospitals (DSH) from January 2, 2020, to January 24, 2020. Howell was terminated after DSH discovered she was on medical leave from her previous job due to a 2017 sexual assault, which she did not disclose during her pre-employment health screening. Howell filed a lawsuit against DSH, claiming mental and physical disability discrimination under the Fair Employment and Housing Act (FEHA).The Napa County Superior Court granted summary judgment in favor of DSH on Howell’s claims for failure to accommodate and failure to engage in the interactive process. Howell dismissed her claim for failure to prevent discrimination. The jury found in favor of Howell on her mental disability discrimination claim, awarding her $36,751.25 in lost earnings and health insurance benefits but nothing for pain and suffering. The court denied Howell’s motion for a new trial on non-economic damages and granted DSH’s motion for judgment notwithstanding the verdict, striking the award for lost health insurance benefits. Howell was awarded $135,102 in attorney fees and costs but did not receive a ruling on her request for prejudgment interest.The California Court of Appeal, First Appellate District, Division Two, reviewed the case. The court affirmed the trial court’s decisions to deny Howell’s motion for a new trial and to grant DSH’s motion for judgment notwithstanding the verdict. The appellate court found that Howell did not provide evidence of out-of-pocket expenses for lost health insurance benefits. The court also upheld the trial court’s award of $135,102 in attorney fees and costs, finding Howell’s request for $1.75 million to be unreasonable. However, the appellate court remanded the case for the trial court to address Howell’s request for prejudgment interest. View "Howell v. State Dept. of State Hospitals" on Justia Law