Justia Labor & Employment Law Opinion Summaries

The Supreme Court affirmed the decision of the Labor and Industrial Relations Commission reversing the administrative law judge's (ALJ) award of permanent and total disability (PTD) benefits against the Second Injury Fund, holding that the Commission's findings were supported by substantial and competent evidence.Christopher Klecka suffered a compensable work-related injury to his left shoulder. After settling the primary claim with his employer Klecka brought a claim against the Fund, alleging that his primary injury combined with his prior injuries rendered him permanently and totally disabled (PTD). An ALJ issued an award against the fund for PTD benefits. The Commission reversed. The Supreme Court affirmed, holding that Klecka failed to establish that his primary injury and sole qualifying preexisting disability entitled him to PTD benefits from the Fund under Mo. Rev. Stat. 287.220.3. View "Klecka v. Treasurer of Missouri" on Justia Law

The Supreme Court reversed the circuit court's grant of summary judgment in favor of Respondent and dismissing Petitioner's civil action alleging that Respondent violated the terms of the West Virginia Wage Payment and Collection Act, the terms of her employee agreement, and the employee handbook by failing, upon her resignation, to provide her severance pay and compensation for accrued paid time off, holding that the circuit court erred.Following her resignation, Petitioner initiated a lawsuit alleging that Respondent failed timely to pay her wages on several occasions, thereby breaching the employee agreement that triggered Respondent's duty to pay her a severance package. Petitioner additionally asserted that the failure to pay her the severance package constituted violations of the employee handbook and the Act. The circuit court granted judgment in favor of Respondent. The Supreme Court reversed, holding that the circuit court erred in dismissing Petitioner's claims. View "Miller v. St. Joseph Recovery Center, LLC" on Justia Law

The Supreme Court held that, by and large, Hawai'i's public information law - the Uniform Information Practices Act (UIPA) - required the state Attorney General (AG) to release a report it issued in 2016 documenting deceptive practices, incompetence, and workplace bullying in the Office of the Auditor.After the state AG compiled a record of its investigation a reporter with the Honolulu Civil Beat, an investigative news organization, asked for the investigative reports pursuant to UIPA. The circuit court granted summary judgment in favor of the state AG, concluding that the report was exempt from the UIPA. The Supreme Court vacated the circuit court's final judgment, holding that, regarding the vast majority of the report, the UIPA's presumption favoring disclosure was not overcome. View "Honolulu Civil Beat Inc. v. Department of the Attorney General" on Justia Law

Boshaw, an openly gay man, began working as a server at Midland in May 2018. In discussing a possible promotion, Boshaw’s supervisor suggested he “needed to change [his] appearance and kind of just act a little more masculine” and to remove his Facebook relationship status. Boshaw changed his hairstyle and deleted his Facebook relationship status but did not otherwise hide his sexual orientation. Boshaw was rapidly promoted three times, becoming front-of-house operations manager. Meanwhile, Boshaw reposted his relationship status and used hashtags referencing his sexual orientation. Boshaw had a cordial relationship with his supervisor, who persuaded Boshaw not to accept an offer from another restaurant. Boshaw’s employment record was not spotless.” After other incidents, Boshaw missed a mandatory meeting and did not show up to work that evening. Midland fired Boshaw due to his “absence and failure to notify management” and “other issues.”Boshaw filed an EEOC complaint, then sued, alleging sex discrimination and retaliation under Title VII and Michigan’s Elliott-Larsen Civil Rights Act (ELCRA), and civil rights conspiracy under the ELCRA. The Sixth Circuit affirmed summary judgment in favor of the defendants. Boshaw’s rapid rise shows that Midland did not delay or deny his promotions because of sex discrimination. Even if Boshaw had made a prima facie showing of retaliatory termination, he cannot show that Midland’s reasons for his termination were pretextual. Boshaw alleged only “isolated incidents,” which are not enough to state a hostile work environment claim. View "Boshaw v. Midland Brewing Co." on Justia Law

Plaintiff, a former Federal Public Defender, was subject to sexual harassment by a supervisor. After attempting to pursue her administrative remedies, Plaintiff claimed she was constructively discharged and resigned. Plaintiff then filed claims under the Due Process and Equal Protection clauses, as well as under 42 U.S.C. Sections 1985(3) and 1986, against various executive and judicial officers. The district court dismissed all of Plaintiff's claims based on her failure to state a claim and Defendant's sovereign immunity.The panel held that Plaintiff's Due Process claim sufficiently plead a deprivation of her property interests, but failed to plead a deprivation of her liberty interest. The panel also held Plaintiff's Equal Protection claim adequately plead sex discrimination; however, her claims under 42 U.S.C. Sections 1985(3) and 1986 failed to state a claim upon which relief could be granted. Finally, the court determined that Plaintiff could only pursue back-pay benefits from all Defendant's named in their official capacity and that all Defendant's named in their individual capacity were entitled to dismissal under Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971). Thus, the court affirmed in part, reversed in part, and remanded the case to the district court for further proceedings. View "Caryn Strickland v. US" on Justia Law

Plaintiff appeared in ten photoshoots organized by Walmart for a total of fifteen days, in non-consecutive periods of one or two days. Plaintiff sued Walmart for its failure to pay her immediately after each photoshoot ended, seeking more than $540,000 in penalties. The district court denied summary judgment on Walmart’s defense that Plaintiff was an independent contractor outside the protection of the relevant Labor Code provisions due to disputes of material fact. However, it granted summary judgment on Walmart’s good-faith defense. The district court concluded that there was a good faith dispute about whether Plaintiff was an independent contractor that made it objectively reasonable for Walmart to believe Plaintiff was not an employee.   The Ninth Circuit affirmed the district court’s summary judgment in favor of Walmart. The court rejected Plaintiff’s contention that Walmart was foreclosed from raising a good faith defense based on mistakenly classifying an employee as an independent contractor. The court held that Walmart’s argument that Plaintiff was an independent contractor was a good-faith dispute that any wages are due. The court further held that nothing in the record indicated bad faith on Walmart’s part and that there were some reasonable grounds for Walmart to believe that Plaintiff was an independent contractor. View "BIJON HILL V. WALMART INC." on Justia Law

Plaintiffs, civil detainees in the Minnesota Sex Offender Program (“MSOP”), sued the state defendants arguing that they failed to pay Plaintiffs minimum wage under the Fair Labor Standards Act, 29 U.S.C. Sec. 201. The district court granted summary judgment to Defendants.The Eighth Circuit affirmed the ruling finding that sexually dangerous civil detainees are not state employees. The court reasoned that “there is no bargained-for exchange of labor for mutual economic gain” like that which “occurs in a true employer-employee relationship.” Further detainees are under the control and supervision of the detention facility, which is not comparable to the free labor situation of true employment. Moreover, the detainees have their basic needs met by the state, which means that the FLSA’s purpose to maintain a “standard of living necessary for health, efficiency, and general well-being of workers” does not apply. View "David Gamble v. Minnesota State-Operated Svcs" on Justia Law

The Supreme Court affirmed the final judgment of the superior court in favor of Defendants due to Plaintiff's having failed to comply with her discovery obligations, which had earlier been the subject of a conditional order of dismissal, holding that there was no error.Plaintiff brought this complaint alleging that Defendants had discriminated against her in retaliation for her whistleblowing activities and that she was entitled to relief under the Rhode Island Whistleblowers' Protection Act. Ultimately, the hearing justice granted Defendants' motion for final judgment on the grounds that Plaintiff had, over a five-year period, repeatedly failed to comply with her discovery obligations. The Supreme Court affirmed, holding that the hearing justice acted within her discretion in ordering the entry of final judgment. View "Boss v. Chamberland" on Justia Law

Plaintiff sued her employer, the Institute of International Education, for discrimination in violation of federal, state, and local, employment law. The district court referred the matter to New York’s mediation program and the parties reached an agreement to settle the case. The parties committed that agreement to writing, signed it, had their counsel sign it, and had the mediator sign it. The week after the mediation, Plaintiff contacted the district court seeking to revoke her acceptance of the mediation agreement and to continue the litigation. The Institute then moved to enforce the mediation agreement. The district court enforced the mediation agreement and entered judgment in favor of the Institute.   The Second Circuit affirmed the district court judgment. The court concluded that the mediation agreement bound the parties to its terms. The court reasoned that the case is not one in which the language of the agreement merely committed the parties to “work together in accordance with the terms and conditions outlined in” the agreement, which would be an agreement to continue negotiating. And while this language was pre-printed, the parties could have crossed it out if they did not intend to acknowledge that agreement on all issues had been reached or they could have added language in the handwritten portion of the mediation agreement reserving the right not to be bound by the mediation agreement’s terms until the final agreement was drafted. Further, the court found that Plaintiff was not under duress when she signed the mediation agreement. View "Murphy v. Inst. of Int'l Educ." on Justia Law

Former employees of Nationwide Motor Sales Corporation sued the company and its owners (collectively, Nationwide) in district court, alleging fraudulent payment practices that reduced employees’ sales commissions and final paychecks. Nationwide produced its Employee Handbook’s provision requiring arbitration. The employees contended that the arbitration agreement is invalid because Nationwide retains the right to change, delete, or modify the policies. The district court denied Nationwide’s motion to compel arbitration, finding the Arbitration Agreement illusory due to the Modification Clause   Applying Maryland law, the Fourth Circuit affirmed the district court’s decision, reasoning that the promise to arbitrate was illusory because, on the agreement’s signature page, the employer retained the right to amend or abolish the agreement without notice to the employees. Further, in reviewing the plain meaning of the Acknowledgement Receipt “as a whole,” it is clear that the Modification Clause applies to the Arbitration Agreement. View "Michael Coady v. Nationwide Motor Sales Corp." on Justia Law