Justia Labor & Employment Law Opinion Summaries

Wilbert Finley, a production manager at Kraft Heinz’s Newberry, South Carolina plant, was responsible for overseeing product quality and food safety. Finley raised concerns about food safety, particularly regarding improperly sealed bacon packages and bone fragments in the meat. He reported these issues to his supervisors and HR, but was criticized and told not to stop production. On March 24, 2020, Finley was suspended and then terminated two days later, allegedly for dishonesty during an HR investigation into the botched firing of another employee, Yolanda Gaines.The United States District Court for the District of South Carolina granted summary judgment to Kraft Heinz, adopting the magistrate judge’s report and recommendation. The magistrate judge concluded that Finley could not establish that his safety complaints were a “contributing factor” in his dismissal, citing the March 24 investigation as a legitimate intervening event that severed any causal connection. The district court agreed, also finding that Kraft Heinz had shown by clear and convincing evidence that it would have terminated Finley regardless of his complaints.The United States Court of Appeals for the Fourth Circuit vacated the district court’s judgment and remanded the case. The appellate court held that the district court and magistrate judge failed to properly consider all the evidence, including the close temporal proximity between Finley’s complaints and his termination, and the disputed facts regarding the March 24 investigation. The court found that a reasonable jury could infer that Finley’s food safety complaints contributed to his termination and that Kraft Heinz’s rationale for firing him was pretextual. Thus, the case was remanded for further proceedings. View "Finley v. Kraft Heinz Inc." on Justia Law

Timothy Upchurch, a Black man, has worked at the Indiana Department of Correction’s Correctional Industrial Facility (CIF) for over thirty years. He filed discrimination and retaliation claims under Title VII against the State of Indiana, challenging his demotion from Correctional Lieutenant to Officer, subsequent written reprimands, a suspension, and non-promotions. The district court substituted the Indiana Department of Correction for the State of Indiana as the defendant and granted summary judgment to the Department.The United States District Court for the Southern District of Indiana found insufficient evidence of race discrimination or retaliation to support Upchurch's claims. Upchurch appealed, challenging the substitution of the Department for the State as the defendant and the summary judgment decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court agreed with the district court that the Indiana Department of Correction was the proper defendant under Title VII, as it had actual hiring and firing responsibility. The court also reviewed the grant of summary judgment de novo, finding that the Department provided nondiscriminatory explanations for its actions, and Upchurch failed to show these explanations were pretextual. The court noted that Upchurch did not provide sufficient evidence to support his claims of race discrimination or retaliation, including failing to show that comparators were similarly situated or that the Department's actions were motivated by his race or complaints about discrimination.The Seventh Circuit affirmed the district court's judgment, concluding that no reasonable jury could find that race discrimination or retaliation motivated the adverse employment actions against Upchurch. View "Upchurch v. Indiana" on Justia Law

Rodney Burch, the former Public Works Director for the City of Chubbuck, Idaho, filed a lawsuit against the City and Mayor Kevin England, alleging First Amendment retaliation and violations of Idaho state law. Burch claimed that adverse employment actions were taken against him due to his protected speech, which included criticisms of England’s policies and performance, advocacy for a city administrator position, and displaying a political yard sign supporting England’s opponent during the mayoral election.The United States District Court for the District of Idaho granted summary judgment in favor of the defendants. The court found that Burch’s criticisms and advocacy were made pursuant to his official duties and thus were not protected speech under the First Amendment. However, the court recognized that Burch’s political yard sign was protected speech. Despite this, the court concluded that Burch failed to establish a First Amendment violation because the defendants had adequate justification for their actions and would have taken the same actions regardless of the yard sign.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court’s decision. The Ninth Circuit agreed that Burch’s criticisms and advocacy were unprotected as they were part of his official duties. The court also found that while Burch’s yard sign was protected speech, the defendants had legitimate reasons for their actions, including Burch’s unprotected speech and the need to maintain effective city operations. Additionally, the court held that Burch’s state law claim was time-barred as the adverse employment actions occurred outside the statute of limitations.In conclusion, the Ninth Circuit affirmed the district court’s summary judgment for the defendants, holding that Burch’s First Amendment retaliation claim and Idaho state law claim both failed as a matter of law. View "Burch v. City of Chubbuck" on Justia Law

David Meza, an employee of Union Pacific Railroad Co. for over twenty years, suffered a traumatic brain injury from a non-job-related motorcycle accident. Despite his treating physicians clearing him to return to work, Union Pacific's medical examiner recommended work restrictions due to the risk of future seizures. These restrictions prevented Meza from returning to his previous position, leading him to seek other employment within the company. Meza sued Union Pacific, alleging that the company discriminated against him by regarding him as disabled under the Americans with Disabilities Act (ADA).The United States District Court for the District of Nebraska granted summary judgment in favor of Union Pacific. The court concluded that Union Pacific did not regard Meza as currently disabled but imposed restrictions based on potential future effects of his injury. Meza appealed this decision, arguing that the company's actions constituted illegal discrimination.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo, considering the evidence in the light most favorable to Meza. The court found that there was a genuine issue of material fact regarding whether Union Pacific regarded Meza as disabled. The medical examiner's report suggested that Meza's brain injury could be perceived as an impairment, which could support Meza's claim. The court distinguished this case from Morriss v. BNSF Railway Co., noting that Meza's condition could be seen as an existing impairment rather than a future risk.The Eighth Circuit vacated the district court's judgment and remanded the case for further proceedings, allowing the lower court to consider other unresolved issues, such as whether Meza was qualified for his job post-accident and whether his condition posed a direct threat to workplace safety. View "Meza v. Union Pacific Railroad Co." on Justia Law

George Merithew, a former police officer with the City of Omaha Police Department (OPD), sued the City of Omaha under the Nebraska Fair Employment Practice Act (NFEPA) for retaliation. Merithew, who began his employment with OPD in 1996 and was promoted to lieutenant in 2009, reported a violation of the Palmer Consent Decree in May 2018 and subsequently claimed retaliation by the police chief. He filed a charge of discrimination with the Nebraska Equal Opportunity Commission (NEOC) in April 2020 after receiving a 20-day suspension. In June 2020, he received a termination letter, was suspended with pay, and later retired in February 2021 under an "Early Delayed Retirement Option."The District Court for Douglas County granted summary judgment in favor of the City, finding that any alleged discriminatory actions before June 25, 2019, were time-barred and that Merithew failed to establish a prima facie case of retaliation. The court determined that Merithew did not suffer an adverse employment action and lacked evidence of a causal connection between his protected conduct and the alleged retaliation. Additionally, the court found that the City provided legitimate, nondiscriminatory reasons for its actions, which Merithew failed to prove were pretextual.The Nebraska Supreme Court reviewed the case de novo and affirmed the district court's enforcement of the statute of limitations, barring claims for actions before June 25, 2019. However, the Supreme Court found that there were genuine issues of material fact regarding whether Merithew was subjected to an adverse employment action, whether there was a causal connection between his protected conduct and the adverse action, and whether the City's reasons were pretextual. The court reversed the summary judgment in part and remanded the case for further proceedings. View "Merithew v. City of Omaha" on Justia Law

The case involves Dr. Lisa Menninger, who was the Executive Director for Laboratory Operations at PPD Development, L.P. (PPD). Menninger claimed that PPD discriminated and retaliated against her due to her social anxiety disorder, violating the Americans with Disabilities Act (ADA) and Massachusetts antidiscrimination law. A jury found in favor of Menninger, awarding her over $24 million in damages. PPD then moved for judgment as a matter of law, a new trial, and remittitur, but the district court denied these motions.The United States District Court for the District of Massachusetts initially granted partial summary judgment for PPD, rejecting Menninger's theory that PPD could be liable solely for failing to engage in an interactive process. It also limited Menninger's disparate-treatment claims to a single adverse action. However, the court denied PPD's motion for summary judgment on other claims, allowing the case to proceed to trial. The jury found in favor of Menninger on all counts, concluding that PPD failed to provide reasonable accommodation, discriminated against her, and retaliated against her. The jury awarded substantial damages, including punitive damages.The United States Court of Appeals for the First Circuit reviewed the case. PPD argued that the evidence was insufficient to support the jury's verdict, that the jury instructions were misleading, and that the punitive damages were unsupported. The Court of Appeals found that PPD failed to properly preserve its sufficiency-of-the-evidence arguments by not specifying the grounds for its Rule 50(a) motion. The court also found no plain error in the jury instructions and concluded that the evidence supported the punitive damages award. The court affirmed the district court's judgment and its denial of PPD's posttrial motions. View "Menninger v. PPD Development, L.P." on Justia Law

Jody Pham injured her neck and right shoulder while working at Smithfield Foods, a self-insured employer. Smithfield accepted the injury as a compensable workers’ compensation claim and paid benefits for over two years. In 2018, Smithfield stopped paying medical benefits, believing Pham’s employment was no longer a major contributing cause of her need for additional treatment. Pham filed a petition for a hearing with the Department of Labor and Regulation, and an administrative law judge (ALJ) determined that Pham failed to establish causation. Pham appealed to the circuit court, which reversed the ALJ’s decision, reasoning that Smithfield had the burden to show a change in circumstances to justify suspending benefits. Smithfield appealed.The South Dakota Supreme Court reviewed the case. The court concluded that SDCL 62-7-33, which the circuit court relied on, did not apply because Smithfield’s pre-petition payments were voluntary and not based on a final order or settlement agreement. The court also found that Pham’s argument that Smithfield had the burden to prove non-compensability was incorrect. The court emphasized that Pham bore the burden to establish compensability since the issue had not been previously litigated or adjudicated.Regarding the expert testimony, the court noted that the ALJ found Dr. Jensen’s testimony more persuasive than Dr. Ripperda’s. The court held that the ALJ’s findings were not clearly erroneous and that the circuit court erred in reweighing the evidence. The South Dakota Supreme Court reversed the circuit court’s decision and reinstated the ALJ’s decision, concluding that Pham failed to meet her burden of proving that her work-related injury was a major contributing cause of her need for additional treatment. View "Pham v. Smithfield Foods" on Justia Law

Employees of Veolia Water Contract Operations USA, Inc. filed a lawsuit in Massachusetts state court, claiming they were entitled to prevailing wages under the Massachusetts Prevailing Wage Act (PWA) for work performed. They argued that their work fell within the scope of the PWA. Veolia removed the case to federal court based on diversity jurisdiction.The United States District Court for the District of Massachusetts granted summary judgment in favor of Veolia. The court concluded that the Special Act of 1997, which pertains to the Springfield Water and Sewer Commission, exempted Veolia from the obligation to pay prevailing wages under the PWA. The employees appealed this decision.The United States Court of Appeals for the First Circuit reviewed the case. The central issue was whether the Special Act required Veolia to pay prevailing wages. The court noted that the outcome depended on unresolved questions of Massachusetts law and significant policy concerns. Consequently, the First Circuit decided to certify the dispositive state law questions to the Massachusetts Supreme Judicial Court for clarification.The First Circuit certified two questions: the meaning of "construction and design of improvements" in the Special Act and whether the Special Act is incompatible with the PWA under the Massachusetts Supreme Judicial Court's decision in Metcalf v. BSC Group, Inc. The First Circuit retained jurisdiction over the appeal pending the resolution of these certified questions. View "Nicholls v. Veolia Water Contract Operations USA, Inc." on Justia Law

Katrina Robertson, an independent contractor working as a polygraph examiner for the Defense Intelligence Agency (DIA), was involved in an automobile accident while exiting the DIA campus. She sued the United States under the Federal Tort Claims Act (FTCA), alleging that a DIA employee's negligence caused the accident. The government moved to dismiss the case for lack of subject matter jurisdiction, arguing that it had not waived its sovereign immunity under the FTCA because a private employer in similar circumstances would be immune from suit under Virginia law.The United States District Court for the Eastern District of Virginia granted the government's motion to dismiss. The court found that the DIA was a "statutory employer" under the Virginia Workers' Compensation Act (VWCA) and that Robertson's injury occurred during the course of her work. Therefore, the VWCA provided the exclusive remedy, and the government was immune from the suit. The district court also denied Robertson's motion to certify a question to the Supreme Court of Virginia as moot.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court's decision. The Fourth Circuit held that under the FTCA, the United States is liable only to the extent that a private party would be liable in similar circumstances. Since a private employer in Virginia would be immune from a negligence suit under the VWCA if it were a statutory employer, the United States had not waived its sovereign immunity. The court concluded that the district court properly dismissed the case for lack of subject matter jurisdiction. View "Robertson v. United States" on Justia Law

Ada Martinez-Medina, a Hispanic female of Puerto Rican descent, worked for the United States Department of Agriculture (USDA) and alleged that her supervisor assigned her work above her pay grade and took credit for her work. She filed two Equal Employment Opportunity (EEO) complaints alleging discrimination, retaliation, and a hostile work environment, which were settled in August 2018. After the settlement, she experienced further issues, including a delayed performance review and derogatory comments from her acting supervisor. She filed another EEO complaint in March 2019, which was denied, leading her to file a lawsuit in federal district court.The United States District Court for the Western District of Missouri granted summary judgment in favor of the defendant, the Secretary of the USDA, finding that Martinez-Medina had not presented sufficient evidence to support her claims of disparate treatment, hostile work environment, and retaliation.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that Martinez-Medina did not establish a prima facie case of disparate treatment because the alleged adverse employment actions did not affect an identifiable term or condition of her employment. Additionally, the court found that she did not present evidence that the employer's legitimate, nondiscriminatory reason for not granting her reassignment request was pretextual.Regarding the hostile work environment claim, the court concluded that the incidents Martinez-Medina cited were not severe or pervasive enough to alter the conditions of her employment. For the retaliation claim, the court determined that there was no causal link between her protected EEO activity and the alleged retaliatory acts.The Eighth Circuit affirmed the district court's judgment, granting summary judgment to the defendant on all claims. View "Martinez-Medina v. Rollins" on Justia Law