Justia Labor & Employment Law Opinion Summaries

Dan Hamilton, an employee at an Amazon warehouse in Aurora, Colorado, received both holiday pay and holiday incentive pay. Holiday pay was his regular hourly rate for company holidays, regardless of whether he worked. Holiday incentive pay was one and one-half times his regular rate for hours worked on holidays. Hamilton filed a class action complaint alleging Amazon violated the Colorado Wage Act by not including holiday incentive pay in the calculation of his overtime pay.The case was initially filed in Arapahoe County District Court but was removed to the United States District Court for the District of Colorado. Amazon moved to dismiss the complaint, arguing that holiday incentive pay could be excluded from the regular rate of pay under both Colorado law and the Federal Fair Labor Standards Act (FLSA). The federal district court agreed with Amazon, ruling that Colorado law did not require the inclusion of holiday incentive pay in the regular rate of pay calculation, and dismissed Hamilton's complaint. Hamilton appealed to the Tenth Circuit, which then certified a question of law to the Supreme Court of Colorado.The Supreme Court of Colorado reviewed the certified question and concluded that holiday incentive pay must be included in the calculation of the regular rate of pay under Colorado law. The court found that the plain language of the relevant regulations, specifically 7 Colo. Code Regs. § 1103-1:1.8 and 1.8.1, mandated the inclusion of all compensation for hours worked, including holiday incentive pay. The court rejected Amazon's arguments that holiday incentive pay could be excluded and that Colorado law should be interpreted in line with the FLSA. The court held that holiday incentive pay is a form of shift differential and must be included in the regular rate of pay calculation. View "Hamilton v. Amazon.com Services" on Justia Law

Jeremy Hitt, a Remote Control Operator for CSX Transportation, Inc., was terminated after receiving three workplace violations within a three-year period. Hitt's first violation occurred in 2017 for failing to leave unattended train cars at a specified location. In the summer of 2018, Hitt refused to work during a lightning storm, citing safety concerns, and later refused to operate the train at a speed he considered unsafe. His second violation was in November 2018 for failing to secure his train properly. The third violation occurred in January 2019 when Hitt failed a banner test by using the emergency brake to stop the train.The United States District Court for the Northern District of Alabama granted summary judgment to CSX, concluding that Hitt failed to provide sufficient evidence of causation to support his claim under the Federal Railroad Safety Act (FRSA). The court found that Hitt could not establish that his protected activity (refusing to work during the lightning storm) was a contributing factor to his termination.The United States Court of Appeals for the Eleventh Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that Hitt failed to establish causation, as there was no evidence that his protected activity contributed to his termination. The court noted that the decision-makers who terminated Hitt were unaware of his protected activity and that Hitt's supervisor, who allegedly retaliated against him, had no influence over the termination decision. The court also found that the temporal gap between the protected activity and the adverse action was too long to establish causation based on temporal proximity alone. Thus, the court concluded that Hitt could not prove the elements of his FRSA claim. View "Hitt v. CSX Transportation Inc" on Justia Law

In this case, Denise Kemp, a manager at Regeneron Pharmaceuticals, Inc., worked remotely in June 2016 to care for her child with a serious medical condition. Regeneron then restricted her remote work to one day per week and required her to use intermittent leave under the Family and Medical Leave Act (FMLA) for additional time away. Kemp sued Regeneron, alleging interference with her FMLA rights, and discrimination, retaliation, and constructive discharge under the New York State Human Rights Law (NYSHRL).The United States District Court for the Southern District of New York dismissed Kemp’s FMLA claim, reasoning that Regeneron had not denied her FMLA benefits and that the claim was time-barred. The court also dismissed her NYSHRL claims on the merits.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that an employer can violate the FMLA by interfering with an employee’s use of FMLA benefits, even if the benefits are ultimately granted. However, the court affirmed the dismissal of Kemp’s FMLA claim as time-barred, finding no evidence of a willful violation by Regeneron to extend the statute of limitations. The court also affirmed the dismissal of Kemp’s NYSHRL claims for discrimination and retaliation as time-barred, noting that Kemp was informed of the adverse actions before the relevant date. Lastly, the court upheld the dismissal of Kemp’s constructive discharge claim, concluding that her working conditions were not intolerable enough to compel resignation.The Second Circuit affirmed the District Court’s judgment, dismissing all of Kemp’s claims. View "Kemp v. Regeneron Pharm., Inc." on Justia Law

The case involves five plaintiffs who own and operate 7-Eleven convenience stores in Massachusetts. They entered into franchise agreements with 7-Eleven, Inc., which provided them with a license to use the 7-Eleven brand and associated business format. In return, the franchisees agreed to operate their stores according to 7-Eleven's standards and pay a franchise fee, which is a percentage of the store's gross profits. The plaintiffs claim they were misclassified as independent contractors rather than employees under Massachusetts law.The United States Court of Appeals for the First Circuit previously reviewed the case and certified a question to the Massachusetts Supreme Judicial Court (SJC) regarding whether the three-prong test for independent contractor status applies to franchise relationships. The SJC concluded that the test does apply but requires a case-specific examination of whether the individual performs any service for the alleged employer. The First Circuit then certified a second question to the SJC, asking whether the plaintiffs perform any service for 7-Eleven under the Massachusetts independent contractor statute, given their contractual obligations and the franchise fee structure.The Massachusetts Supreme Judicial Court held that the plaintiffs do not perform any service for 7-Eleven within the meaning of the independent contractor statute. The court reasoned that the franchisees operate their stores independently and chose to use the 7-Eleven brand for its market benefits. The court emphasized that the franchisees' compliance with 7-Eleven's standards is necessary to maintain the brand's integrity and does not indicate an employment relationship. Therefore, the court answered the certified question in the negative, concluding that the plaintiffs are not employees of 7-Eleven under the Massachusetts independent contractor statute. View "Patel v. 7-Eleven, Inc." on Justia Law

Skylar Meinhardt, a former professional soccer player for the Washington Freedom, sustained a left knee injury in 2001 or 2002. Years later, she developed a right knee disability, which she attributed to compensating for her earlier left knee injury. Meinhardt claimed that her altered gait due to the left knee injury led to the deterioration of her right knee, resulting in pain first reported in 2015 and necessitating surgeries in 2016 and 2019.An Administrative Law Judge (ALJ) denied Meinhardt's workers' compensation claim, mistakenly framing the issue as whether a right knee injury in 2002 was related to the left knee injury in 2001. The ALJ found Meinhardt non-credible, partly because of her prior right knee surgeries in 1996, 1999, and 2001, and because the evidence did not support a right knee injury in 2002. The Compensation Review Board (CRB) affirmed the ALJ's decision, also mischaracterizing the issue as whether a 2002 right knee injury was related to the 2001 left knee injury.The District of Columbia Court of Appeals vacated the CRB's order and remanded the case for further proceedings. The court clarified that the central issue was whether Meinhardt's 2015 right knee disability was causally connected to her 2001-2002 left knee injury. The court found that both the ALJ and CRB had misunderstood the claim, leading to an erroneous denial of benefits. The court also noted that the evidence used to rebut the presumption of compensability, particularly a letter from Dr. Clinton Soppe, was not specific and comprehensive enough, as it incorrectly stated that Meinhardt's right knee pain began acutely in 2016.The case was remanded to the CRB, with instructions to remand it further to the ALJ for reconsideration, focusing on whether the 2015 right knee disability was causally related to the 2001-2002 left knee injury. View "Little v. D.C. Dep't of Employment Services" on Justia Law

Caitlin Julia Weathers, a white woman, was hired by Houston Methodist Hospital as a Patient Transporter in May 2019 and later became a Patient Care Assistant in June 2021. She reported racial harassment and discrimination by her co-workers to her supervisor, Sunila Ali, and Human Resources (HR). HR investigated but found no evidence supporting her claims and instead received negative feedback about her performance. Weathers was placed on a performance improvement plan (PIP) and was eventually terminated on October 4, 2021, for allegedly failing to meet the PIP's expectations. Weathers claimed her termination was retaliatory.Weathers filed an online inquiry with the EEOC on February 11, 2022, but faced difficulties scheduling an interview due to the EEOC's unavailability. After several delays and cancellations, she finally had an interview on August 1, 2022, and filed her charge of discrimination on August 3, 2022, 303 days after her termination. The EEOC issued a Right to Sue letter on August 11, 2022. Weathers then sued Methodist and Ali for discrimination and retaliation under Title VII. The district court dismissed her claims against Ali, citing that employees are not personally liable under Title VII, and dismissed her claims against Methodist as time-barred for not filing within the 300-day deadline.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the dismissal of claims against Ali but found that the district court erred in not applying equitable tolling to Weathers's claims against Methodist. The court noted that the delays were partly due to the EEOC's actions and that Weathers had diligently pursued her claim. The court vacated the district court's judgment for Methodist and remanded the case for further proceedings, allowing Weathers's claims to proceed. View "Weathers v. Houston Methodist Hospital" on Justia Law

Employees of Smith International, Inc. filed a claim for unpaid overtime wages under the Fair Labor Standards Act (FLSA). The employees, known as reamers, supervised the use of Smith’s underreaming tool on offshore drilling rigs. They were paid an annual salary plus daily-rate job bonuses, with their total annual compensation exceeding $100,000. The employees argued that they were misclassified as exempt from overtime requirements and sought to recover unpaid overtime wages, liquidated damages, and attorney fees.The United States District Court for the Western District of Louisiana conditionally certified the action as a collective action. Later, the claims of some plaintiffs were severed into separate individual actions, while others continued as a collective action. The district court consolidated the five proceedings for all purposes except for trial. After discovery, both parties filed cross motions for summary judgment. The district court granted Smith’s motion for summary judgment, finding that the employees were exempt from the FLSA’s overtime pay guarantee as bona fide executives. The employees appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that each employee met the criteria for the bona fide executive exemption under the FLSA. Specifically, the employees satisfied the salary basis test, the salary level test, and the job duties test. The court found that the employees were paid a guaranteed annual salary, which was not subject to reduction based on the quality or quantity of work performed, and that the additional daily-rate compensation did not defeat their qualification for the exemption. The court affirmed the district court’s grant of summary judgment in favor of Smith International, Inc. View "Venable v. Smith International" on Justia Law

Tonya Anderson was terminated from her position at Diamondback Investment Group, LLC after failing two drug tests. She filed a lawsuit against Diamondback, alleging disability discrimination under the Americans with Disabilities Act (ADA) and a violation of North Carolina law that prohibits discrimination against employees for using lawful hemp-derived products containing THC during nonworking hours.The United States District Court for the Middle District of North Carolina granted summary judgment in favor of Diamondback on all claims. The court found that Anderson failed to provide sufficient evidence to establish that she was disabled under the ADA. Even if she had, the court concluded that Diamondback had a legitimate, nondiscriminatory reason for her termination—failing drug tests. The court also found that Anderson did not request a reasonable accommodation for her alleged disability. Regarding the state law claim, the court determined that Diamondback’s drug policy was a bona fide occupational requirement reasonably related to its employment activities, thus falling under an exception to the state law.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court agreed that Anderson did not provide adequate evidence to show she was disabled under the ADA or that she requested an accommodation. The court also upheld the district court’s finding that Diamondback’s drug policy was a bona fide occupational requirement reasonably related to its employment activities, which justified the restriction on Anderson’s use of hemp-derived products. Therefore, the court affirmed the summary judgment in favor of Diamondback on all claims. View "Anderson v. Diamondback Investment Group, LLC" on Justia Law

Andrew Morgan, a millwright laborer, was employed by Allison Crane & Rigging LLC until his termination on November 18, 2020. Morgan injured his lower back on September 29, 2020, and was diagnosed with a bulged or herniated disc by a chiropractor. He was placed on light duty and given restrictions on bending and lifting. Despite these accommodations, Morgan was terminated, allegedly for failing to follow company policies and not showing up for work on November 17, 2020. Morgan filed a lawsuit claiming disability-based discrimination, retaliation, and failure to accommodate under the ADA and PHRA, as well as wrongful discharge under Pennsylvania common law.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of Allison Crane. The court held that Morgan did not establish an actual or perceived disability under the ADA and PHRA, as his testimony about the chiropractor's diagnosis was inadmissible hearsay and he failed to provide necessary medical evidence. The court also found that Morgan's back pain was transitory and minor, thus not qualifying as a disability. Additionally, the court dismissed Morgan's wrongful discharge claim for lack of prima facie evidence of protected activity.The United States Court of Appeals for the Third Circuit reviewed the case and found that the District Court applied an incorrect legal standard. The Third Circuit clarified that under the ADA Amendments Act of 2008, temporary impairments can qualify as disabilities if they substantially limit major life activities. The court reversed the District Court's dismissal of Morgan's back pain-based discrimination claims, vacated the dismissal of his retaliation and failure to accommodate claims, and affirmed the dismissal of his wrongful discharge claim. The case was remanded for further proceedings consistent with the Third Circuit's opinion. View "Morgan v. Allison Crane & Rigging LLC" on Justia Law

In 2018, North American Senior Benefits, LLC (NASB) entered into employment contracts with Ryan and Alisha Wimmer, which included a restrictive covenant prohibiting them from recruiting NASB employees for two years post-termination. In 2021, after the Wimmers left NASB and allegedly started a competing business, NASB sued to enforce the covenant. The Wimmers argued that the covenant was unenforceable due to the lack of an express geographic term.The Statewide Business Court agreed with the Wimmers and granted their motion for judgment on the pleadings, finding the covenant unenforceable without an express geographic term. The Court of Appeals affirmed this decision, relying on its prior ruling in CarpetCare Multiservices v. Carle, which held that a restrictive covenant must include an express geographic term to comply with OCGA § 13-8-53 (a). One judge dissented, arguing that the GRCA does not require an express geographic term for non-recruitment provisions.The Supreme Court of Georgia reviewed the case and concluded that the Court of Appeals erred. The Supreme Court held that OCGA § 13-8-53 (a) does not mandate an express geographic term for a restrictive covenant to be enforceable. Instead, the statute requires that the restrictions be reasonable in time, geographic area, and scope of prohibited activities. The Court emphasized that the reasonableness of a covenant's geographic scope should be assessed based on the totality of the circumstances, not solely on the presence of an express geographic term.The Supreme Court reversed the judgment of the Court of Appeals and remanded the case for further proceedings to determine the reasonableness of the non-recruitment provision under the GRCA. View "NORTH AMERICAN SENIOR BENEFITS, LLC v. WIMMER" on Justia Law