Justia Labor & Employment Law Opinion Summaries

Univar Solutions USA Inc. entered into a collective bargaining agreement (CBA) with Teamsters Local Union No. 283 in 2016, which required Univar to make pension contributions to a multiemployer pension fund. The CBA included an evergreen clause, automatically renewing the agreement annually unless either party provided notice of termination. In 2020, the parties extended the CBA by one year. Before the new expiration date, Univar sent a notice proposing modification or termination of the agreement and later entered a successor agreement allowing it to withdraw from the Fund and cease contributions. The Fund sued, claiming Univar's notice was too ambiguous to terminate the agreement.The United States District Court for the Northern District of Illinois ruled in favor of the Fund, finding that the 2020 extension did not prevent the CBA from automatically renewing under the evergreen clause. The court also found Univar's January 2021 letter insufficient to terminate the agreement, concluding that the CBA remained in effect through March 28, 2022. Consequently, the court granted summary judgment to the Fund, ordering Univar to pay the requested contributions and the Fund's legal fees.The United States Court of Appeals for the Seventh Circuit reviewed the case and disagreed with the district court's findings. The appellate court held that the 2020 extension did not nullify the evergreen clause and that Univar's January 2021 letter provided clear notice of its desire to terminate the CBA. The court concluded that Univar properly terminated the CBA before its expiration date, allowing it to cease contributions as per the successor agreement. The appellate court reversed the district court's summary judgment in favor of the Fund, vacated the award of attorneys' fees, and remanded the case. View "Central States Southeast and Southwest Areas Pensi v Univar Solutions USA Inc." on Justia Law

Samantha Long, a former Clerk of the Town Justice Court for the Town of New Lebanon, filed a lawsuit against the Town of New Lebanon and Jessica Byrne, a former Town Justice. Long alleged that she was unlawfully terminated in retaliation for cooperating with an investigation by the New York State Commission on Judicial Conduct into Byrne’s suspected judicial misconduct. Long claimed that she provided specific case files to the Commission and refused to discuss the investigation with Byrne, which led to her termination. She argued that her termination violated her First Amendment rights and her rights under New York State Civil Service Law § 75-b.The United States District Court for the Northern District of New York dismissed Long’s claims. The court concluded that Long’s actions were not protected by the First Amendment because they were part of her official duties as Court Clerk and did not constitute protected citizen speech. Consequently, the court declined to exercise supplemental jurisdiction over Long’s Section 75-b claim.The United States Court of Appeals for the Second Circuit reviewed the case. The court vacated the district court’s judgment and remanded the case for further proceedings. The appellate court held that Long’s complaint adequately alleged that she acted as a private citizen, not pursuant to her work responsibilities, when she cooperated with the Commission’s investigation and refused to discuss it with Byrne. The court emphasized that Long’s refusal to discuss the investigation with Byrne was not within the scope of her job duties and that her cooperation with the Commission was motivated by a sense of civic duty rather than employment-related responsibilities. The court also vacated the district court’s dismissal of Long’s state-law claim under Section 75-b, as the legal premise for the dismissal was defeated by the reinstatement of her First Amendment claim. View "Long v. Byrne" on Justia Law

Sun Valley Orchards, a New Jersey farm, was accused by the U.S. Department of Labor (DOL) of breaching an employment agreement under the H-2A nonimmigrant visa program. The DOL alleged that Sun Valley failed to provide adequate housing, meal plans, transportation, and guaranteed work hours to its workers, as stipulated in the job order. The DOL imposed civil penalties and back wages totaling hundreds of thousands of dollars through administrative proceedings.The case was first reviewed by an Administrative Law Judge (ALJ), who affirmed most of the DOL's findings but slightly modified the penalties and back wages. Sun Valley then appealed to the Administrative Review Board, which upheld the ALJ's decision. Subsequently, Sun Valley challenged the DOL's decision in the United States District Court for the District of New Jersey, arguing that the administrative proceedings violated Article III of the Constitution, among other claims. The District Court dismissed Sun Valley's claims, holding that the DOL's actions fit within the public-rights doctrine and that the agency had statutory authority to impose penalties and back wages.The United States Court of Appeals for the Third Circuit reviewed the case and held that Sun Valley was entitled to have its case decided by an Article III court. The court found that the DOL's enforcement action resembled a common law breach of contract suit, which traditionally would be heard in a court of law. The court also determined that the case did not fit within the public rights exception to Article III adjudication, as the H-2A labor certification regulations primarily concern domestic employment law rather than immigration control. Consequently, the Third Circuit reversed the District Court's decision and remanded the case with instructions to enter judgment in favor of Sun Valley. View "Sun Valley Orchards LLC v. United States Department of Labor" on Justia Law

The Grand Traverse Band of Ottawa and Chippewa Indians and its employee welfare plan (the Plan) alleged that Blue Cross Blue Shield of Michigan (Blue Cross) breached fiduciary duties under ERISA and related duties under Michigan state law. The Tribe claimed that Blue Cross submitted false claims, causing the Tribe to overpay for hospital services. The Tribe also alleged violations of the Michigan Health Care False Claims Act (HCFCA) and sought to amend its complaint to include additional facts.The United States District Court for the Eastern District of Michigan dismissed the Tribe’s ERISA and common-law fiduciary duty claims as time-barred, granted summary judgment to Blue Cross on the HCFCA claim, and denied the Tribe’s motion for leave to amend its complaint a second time. The court found that the Tribe had actual knowledge in 2009 that it was not receiving Medicare-Like Rates (MLR) and thus the claims were time-barred. The court also concluded that Blue Cross was not directly governed by the MLR regulations, and therefore, the Tribe could not prove a violation of the HCFCA based on Blue Cross’s failure to apply MLR.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decisions. The appellate court agreed that the Tribe’s fiduciary duty claims were time-barred because the Tribe knew in 2009 that it was not receiving MLR. The court also upheld the summary judgment on the HCFCA claim, finding that the MLR regulations did not apply to Blue Cross. Additionally, the court found no error in the district court’s denial of the Tribe’s motion for leave to amend its complaint, as the proposed amendments would not have cured the deficiencies in the ERISA claim. View "Grand Traverse Band of Ottawa & Chippewa Indians v. Blue Cross Blue Shield of Michigan" on Justia Law

Christopher Pable, a software engineer with the Chicago Transit Authority (CTA), discovered a cybersecurity vulnerability in the BusTime system, which was developed by Clever Devices, Ltd. Pable reported the vulnerability to his supervisor, Mike Haynes, who tested it on another city's transit system. Clever Devices, which had a significant contract with the CTA, alerted the CTA about the incident, leading to the termination of Pable and Haynes. Pable then sued the CTA and Clever Devices under the National Transit Systems Security Act, alleging retaliation for whistleblowing.The United States District Court for the Northern District of Illinois dismissed Pable's complaint during the discovery phase, citing the deletion of evidence and misconduct by Pable's attorney, Timothy Duffy. The court also imposed monetary sanctions on both Pable and Duffy. The court found that Pable and Duffy had failed to preserve relevant electronically stored information (ESI) and had made misrepresentations during the discovery process.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court did not abuse its discretion in dismissing Pable's complaint under Federal Rule of Civil Procedure 37(e) due to the intentional spoliation of evidence. The court also upheld the monetary sanctions imposed under Rule 37(e), Rule 37(a)(5), and 28 U.S.C. § 1927, finding that Duffy's conduct unreasonably and vexatiously multiplied the proceedings. The appellate court declined to impose additional sanctions on appeal, concluding that the appeal was substantially justified. View "Christopher Pable v CTA" on Justia Law

An assistant prosecuting attorney, Jennifer Janetsky, filed a lawsuit against Saginaw County, the Saginaw County Prosecutor’s Office, John McColgan, and Christopher Boyd. Janetsky alleged violations of the Whistleblowers’ Protection Act (WPA), public policy violations, assault and battery, intentional infliction of emotional distress, and false imprisonment. The case stemmed from Janetsky’s handling of a criminal sexual conduct prosecution and subsequent alleged retaliatory actions by her supervisors, McColgan and Boyd, after she reported concerns about a plea agreement.The Saginaw Circuit Court granted summary disposition to the Saginaw County Prosecutor’s Office on all claims, to all defendants on the intentional infliction of emotional distress claim, and to McColgan on the intentional-tort claims, but denied the motion for the remaining claims. The Court of Appeals reversed the trial court’s judgment in part, ordering summary disposition in favor of all defendants on the remaining claims. The Michigan Supreme Court reversed in part and remanded to the Court of Appeals to consider unresolved issues. On remand, the Court of Appeals again reversed in part, ordering summary disposition on the intentional-tort and public-policy claims in favor of all defendants and on the WPA claim in favor of Saginaw County.The Michigan Supreme Court held that the Court of Appeals erred in reversing the trial court’s denial of summary disposition. The Supreme Court determined that Saginaw County was an employer under the WPA, allowing Janetsky to sue under the Act. The Court also established a test for wrongful termination in violation of public policy, remanding the case to the trial court to apply this test. Additionally, the Court found genuine issues of material fact regarding Janetsky’s intentional-tort claims, including false imprisonment and assault and battery, sufficient to defeat summary disposition. The judgment of the Court of Appeals was reversed in part, and the case was remanded for further proceedings. View "Janetsky v. County Of Saginaw" on Justia Law

Matthew Waleyko was employed as a civilian computer scientist at the Naval Undersea Warfare Center, a division of the U.S. Navy. His employment was subject to a two-year probationary period. During his tenure, he faced complaints from female coworkers, Beibhinn Gallagher and Layna Nelson, regarding his behavior and alleged misconduct. Gallagher accused him of being condescending and making her feel sexually harassed, while Nelson falsely reported that he had deleted code files. Additionally, Waleyko was investigated for being emotionally unstable after crying in his supervisor's office. Ultimately, he was asked to resign or face termination, and he chose to resign.Waleyko filed a complaint with the Department of the Navy, which was investigated by the Department of Defense's Investigations and Resolutions Directorate. After receiving an unfavorable final agency decision, he filed a lawsuit in the District of Rhode Island, alleging sex discrimination under Title VII. The district court dismissed his suit for failure to state a claim, concluding that he did not specifically describe instances of disparate treatment based on his gender.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court affirmed the district court's dismissal, holding that Waleyko's complaint lacked sufficient factual matter to state a plausible claim for relief. The court found that his allegations were speculative and did not support a reasonable inference that his termination was based on his gender. The court also noted that the alleged procedural irregularities in the Navy's investigations did not demonstrate sex-based bias and that the gender-neutral terms used to describe Waleyko did not support a gender-stereotyping claim. View "Waleyko v. Del Toro" on Justia Law

Monica Gray, a long-time employee of State Farm, assisted a colleague, Sonya Mauter, in securing an ADA accommodation. Mauter's supervisor, Joe Kyle, opposed the accommodation and later reported Gray for timecard falsification. State Farm investigated and terminated Gray. Gray sued for retaliation under the ADA and Ohio law, alleging that Kyle targeted her due to her assistance to Mauter.The United States District Court for the Southern District of Ohio granted summary judgment to State Farm, concluding that the company had an honest belief that Gray engaged in misconduct, thus negating her retaliation claim. Gray appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court found that Gray presented sufficient evidence to establish a prima facie case of retaliation, including her protected activity, State Farm's knowledge of it, and a causal connection between her activity and termination. The court also determined that Gray raised a genuine dispute over whether State Farm's stated reason for her termination was pretextual, particularly given the differential treatment between Gray and another employee, Diane Parker, who had similar timekeeping discrepancies but was not reported.The Sixth Circuit held that Gray could proceed on a theory of vicarious liability, as Kyle's alleged bias and selective reporting could have influenced State Farm's decision to terminate her. The court reversed the district court's grant of summary judgment and remanded the case for further proceedings. View "Gray v. State Farm Mutual Auto Insurance Co." on Justia Law

Jeanne Weinstein, a former server at The Ridge Great Steaks & Seafood, filed a collective action complaint alleging that the restaurant and its operator, Stephen Campbell, violated the Fair Labor Standards Act (FLSA) by not meeting the federal minimum wage requirement. The Ridge paid servers and bartenders $2.15 per hour, supplementing their income with tips to meet the $7.25 minimum wage. The Ridge also required servers and bartenders to contribute 3% of their gross food sales to a tip pool, which was used to pay support staff. Any excess tips were supposed to be distributed to bartenders, but there were inconsistencies in the record-keeping and distribution process.The United States District Court for the Northern District of Georgia granted unopposed motions to voluntarily dismiss five opt-in plaintiffs. The court also ruled partially in favor of the defendants on summary judgment, finding that the tip pool funds were not distributed to non-tipped employees. The remaining issue for trial was whether the defendants retained any portion of the tip pool funds.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court affirmed the district court's judgment, holding that Rule 41(a) permits the dismissal of a single plaintiff in a multiple-plaintiff case if all claims brought by that plaintiff are dismissed. The court also found no error in the district court's conclusion that the defendants did not retain any of the extra tips and operated a lawful tip pool within the parameters of the FLSA. Consequently, the defendants successfully asserted the tip credit defense, and the plaintiffs could not prevail on their minimum wage claim. View "Weinstein v. 440 Corp." on Justia Law

Wheeling Power Company operates the Mitchell Plant, where employees are represented by Local 492 under a collective bargaining agreement. After a fire at another plant owned by the same parent company, employees from that plant were temporarily assigned to the Mitchell Plant. These employees were not covered by Local 492’s agreement, leading the union to file a grievance. The grievance was denied, and the union took the matter to arbitration. The arbitrator found that assigning work to non-union employees violated the agreement but left the remedy to be determined by the parties, retaining jurisdiction in case of an impasse.The United States District Court for the Northern District of West Virginia upheld the arbitrator’s liability award. Wheeling Power appealed, arguing that the arbitrator exceeded his authority and that the award was not final because the remedy had not been determined.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that the complete arbitration rule applied, meaning the arbitrator’s decision was not final since he retained jurisdiction over the remedy. The court noted that the district court should have dismissed the case as premature. Despite Local 492 not raising this issue in the lower court, the appellate court chose to overlook the forfeiture to reinforce the complete arbitration rule’s importance and to avoid piecemeal litigation.The Fourth Circuit vacated the district court’s judgment and remanded the case with instructions to dismiss it without prejudice, allowing the parties to return to court once the arbitrator’s award becomes final. View "Wheeling Power Company - Mitchell Plant v. Local 492 Utility Workers Union of America" on Justia Law