Justia Labor & Employment Law Opinion Summaries

The San Diego City Attorney brought an enforcement action under the California Unfair Competition Law, Business and Professions Code sections 17200, et seq. (UCL), on behalf of the People of California against Maplebear Inc. DBA Instacart (Instacart). In their complaint, the State alleged Instacart unlawfully misclassified its employees as independent contractors in order to deny workers employee protections, harming its alleged employees and the public at large through a loss of significant payroll tax revenue, and giving Instacart an unfair advantage against its competitors. In response to the complaint, Instacart brought a motion to compel arbitration of a portion of the City’s action based on its agreements with the individuals it hired (called "Shoppers"). The trial court denied the motion, concluding Instacart failed to meet its burden to show a valid agreement to arbitrate between it and the State. Instacart appealed, arguing that even though the State was not a party to its Shopper agreements, it was bound by its arbitration provision to the extent the State sought injunctive relief and restitution because these remedies were “primarily for the benefit of” the Shoppers. The Court of Appeal rejected this argument and affirmed the trial court’s order. View "California v. Maplebear Inc." on Justia Law

Daniel Sharp suffered an injury to his lower back from an accident at work in 2015. After surgery, he was repeatedly advised to lose weight by the medical providers treating his injury. However, Sharp gained considerable weight instead. The Industrial Commission found that Sharp’s functional ability had diminished between 2016, when he reached maximal medical improvement (MMI) after surgery, and 2019, when his permanent disability hearing was held. The Commission attributed the worsening of Sharp’s condition to his weight gain, which it held to be a superseding cause of any increase in Sharp’s disability post-MMI. Accordingly, the Commission evaluated Sharp’s disability based on his condition at MMI, despite the Idaho Supreme Court's opinion in Brown v. Home Depot, 272 P.3d 577 (2012), requiring that a claimant’s disability be evaluated based on circumstances at time of the hearing. After review in this case, the Supreme Court held that the Commission erred by departing from "Brown," by applying an incorrect standard to determine that Sharp was not entitled to compensation due to the aggravation of his injury, and by reaching certain factual conclusions not supported by substantial and competent evidence. Therefore, the Commission’s decision was vacated and the matter remanded for further proceedings. View "Sharp v. Thomas Bros Plumbing" on Justia Law

The First Circuit affirmed the entry of final judgment entered in favor of Defendant on Plaintiff's wage and employment misclassification claims, holding that the Massachusetts Wage Act, Mass. Gen. Laws ch. 149, 148 (MWA), did not apply to the undisputed facts in this case.Plaintiff, a Florida-based financial planner with a Massachusetts-based financial services company and office, sued his former broker-dealer in a Massachusetts federal district court alleging that Defendant had misclassified him as an independent contractor instead of an employee in violation of Massachusetts law. The district court concluded that Defendants were entitled to judgment as a matter of law and granted Defendants' motion in its entirety. The First Circuit affirmed, holding that the district court correctly concluded that the MWA did not apply to Plaintiff's employment relationship with Defendant. View "Viscito v. National Planning Corp." on Justia Law

The four truckers who initiated this action regularly drove more than forty hours per week for their employer, JP Trucking, Inc., a Colorado transport company. The question they presented for the Colorado Supreme Courts review concerned whether they were entitled to overtime pay for hours exceeding forty hours per week or twelve hours per day. The Court surmised the answer depended on the meaning of a state regulation that exempted “interstate drivers” from overtime compensation. The truck drivers and JP Trucking both urged the Supreme Court to declare that the term “interstate drivers” was unambiguous: the truck drivers argued the term referred to drivers whose work predominantly took them across state lines; JP Trucking argued that “interstate drivers” were drivers involved in the transportation of goods in interstate commerce, even if their work never took them across state lines. A division of the Colorado court of appeals determined that “interstate drivers” was unambiguous from JP Trucking’s understanding of the term. The Supreme Court concluded the term was ambiguous, and consistent with a different appellate court division, held that “interstate drivers” refers to drivers whose work takes them across state lines, regardless of how often. Hence, the state exemption from overtime compensation was triggered the first time a driver crosses state lines during a work trip. The case was remanded for further proceedings, namely to allow the appeals court to consider JP Trucking’s remaining contentions regarding the calculation of damages. View "Gomez v. JP Trucking" on Justia Law

Plaintiff alleged that her former employer, Circassia Pharmaceuticals (“Circassia”), fired her for discriminatory and retaliatory reasons. The district court granted summary judgment for Circassia, holding that Owens had failed to create a genuine dispute of material fact as to pretext.The Fifth Circuit affirmed the district court’s grant of summary judgment for Defendant in Plaintiff’s employment discrimination lawsuit. The court held even when an employee presents evidence that would allow a jury to conclude that an employer’s proffered justification for an adverse action is false, that does not necessarily permit a rational inference that the real reason was discrimination Plaintiff provided enough evidence to permit a finding that Circassia’s proffered justification for her termination is false. But she has presented a mere scintilla of evidence that the true reason for her termination was discriminatory animus, and “the burden of proof [is hers] throughout.” The court held that summary judgment for Circassia is therefore appropriate because Plaintiff's evidence is of insufficient “nature, extent, and quality” to permit a reasonable factfinder to resolve “[t]he ultimate determination” of discrimination in her favor. Finally, the court reasoned that Plaintiff failed to raise additional arguments regarding pretext to support her retaliation claim, thus falling short of creating a genuine dispute of material fact. View "Owens v. Circassia Pharmaceuticals" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decision of the Workers' Compensation Court of Appeals (WCCA) affirming the decision of the compensation judge finding that Respondent sustained an occupational disease of hearing loss and ordering Relator to pay medical benefits under Minn. Stat. 176.135, subd. 5, holding that further proceedings were required.Respondent developed hearing loss after a career of handling occupational safety and health compliance and monitoring workplace noise levels. Respondent filed a claim for workers' compensation benefits against Relator, his most recent employer. The compensation judge ruled in favor of Respondent and denied his claim for permanent partial disability (PPD) benefits. The WCCA affirmed and clarified that the PPD issue was moot because of a Pierringer settlement between Respondent and one of his former employers. The Supreme Court remanded the case, holding (1) the occupational disease finding was supported by the evidence; (2) the award of medical benefits was appropriate under Minn. Stat. 176.135, subd. 5; and (3) the compensation judge did not properly apply the Pierringer settlement precedent, potentially prejudicing Relator's interests. View "Sershen v. Metropolitan Council" on Justia Law

Plaintiff Angela Gates appealed a trial court’s decision granting summary judgment to defendant, her former employer, on plaintiff’s claims for disability discrimination under the Vermont Fair Employment Practices Act (FEPA) and retaliation under both the Vermont Parental Family Leave Act (PFLA) and Vermont’s workers’ compensation law. Defendant hired plaintiff as a “molder” in 1996. In May 2015, plaintiff reported to defendant that she injured her left knee outside of work. She subsequently took approximately twelve weeks of leave under the federal Family and Medical Leave Act (FMLA) and the PFLA, which ran concurrently. Plaintiff returned to work full-time as a "molder" in August 2015 after exhausting her FMLA/PFLA leave. She returned to molder work, but it caused pain in her knee. Plaintiff was reassigned to work as a "finisher," which again aggravated her knee. After a third period of recovery and return to work, plaintiff testified that when she returned, she was told there was no work she could do that was a light-duty task. "Ultimately, plaintiff had the burden to present some admissible material by which a reasonable jury could infer that defendant’s stated legitimate, nondiscriminatory reason for terminating her - that she was indefinitely incapable of performing the essential functions of her job - was a lie. She failed to do so." The trial court correctly granted summary judgment to defendant on plaintiff’s retaliation claims. View "Gates v. Mack Molding Company, Inc." on Justia Law

Vicki Hebert filed a putative class action against Barnes & Noble, Inc. (Barnes & Noble), alleging it willfully violated the Fair Credit Reporting Act (FCRA). According to Hebert, Barnes & Noble willfully violated the FCRA by providing job applicants with a disclosure that included extraneous language unrelated to the topic of consumer reports. The Act required employers like Barnes & Noble provide a job applicant like Herbert a standalone disclosure stating that the employer may obtain the applicant’s consumer report when making a hiring decision. Barnes & Noble moved for summary judgment, arguing that no reasonable jury could find its alleged FCRA violation was willful. The company asserted it included the extraneous information in its disclosure due to an inadvertent drafting error. The trial court agreed with Barnes & Noble, granted the company’s motion, and entered judgment in the company’s favor. The Court of Appeal disagreed with the trial court, determining a reasonable jury could have found that Barnes & Noble acted willfully because it violated an unambiguous provision of the FCRA, at least one of the company’s employees was aware of the extraneous information in the disclosure before the disclosure was displayed to job applicants, the company may not have adequately trained its employees on FCRA compliance, and/or the company may not have had a monitoring system in place to ensure its disclosure complied with the FCRA. Judgment was reversed and the matter remanded for further proceedings. View "Hebert v. Barnes & Noble, Inc." on Justia Law

Workforce Safety and Insurance (“WSI”) sued law firm Boechler, P.C., and Jeanette Boechler, individually, to collect unpaid workers’ compensation premiums and penalties, and to enjoin them from employing others until they complied with the North Dakota Workers Compensation Act, including paying the premiums and penalties. The firm appealed the district court’s ultimate judgment holding the firm liable for the premiums and penalties, and Boechler appealed the order dismissing the personal liability claim against her without prejudice. Finding no reversible error in the district court’s judgments, the North Dakota Supreme Court affirmed. View "WSI v. Boechler, PC, et al." on Justia Law

Petitioner State Employees’ Association of New Hampshire, Inc. SEIU, Local 1984 (SEA), and intervenors New Hampshire Troopers Association, New Hampshire Troopers Association-Command Staff, New Hampshire Probation and Parole Officers Association, and New Hampshire Probation and Parole-Command Staff Association, appealed a Public Employee Labor Relations Board (PELRB) order denying petitioner’s request for declaratory relief. They argued the PELRB erred by ruling that the state legislature’s vote accepting a fact-finder’s report and recommendations pursuant to RSA 273-A:12, III (2010) was not binding upon respondent State of New Hampshire. In 2018, the unions and the State began negotiating the terms of a multi-year collective bargaining agreement. After the negotiations reached an impasse, the parties proceeded to impasse resolution procedures and engaged a neutral fact finder to assist them with resolving their disputes. The unions accepted the fact-finder’s report, but the Governor did not. In addition, the Governor declined to submit the report to the Executive Council for its consideration. The parties treated the Governor’s actions as a rejection of the report pursuant to RSA 273-A:12, II; from there the matter was submitted to the legislature. The legislature voted to adopt the fact-finder’s report. The unions took the position that the legislature’s vote was binding upon the State with respect to the cost items set forth in the report. The State took the opposite position, asserting that the legislature’s vote was merely advisory and did not result in a binding agreement between the parties. The New Hampshire Supreme Court concluded that the legislature’s vote was advisory and did not bind the State. View "Appeal of New Hampshire Troopers Association et al." on Justia Law