Justia Labor & Employment Law Opinion Summaries

Plaintiff sued her former employer, the University of Minnesota, under the Americans with Disabilities Act (“ADA”), for discrimination based on her disability, failure to provide a reasonable accommodation for her disability, and retaliation. The district court granted summary judgment to the University.The Eighth Circuit affirmed the district court’s ruling. The court first addressed whether Plaintiff met her burden to show that the University failed to provide a reasonable accommodation; specifically, whether Plaintiff qualified for any alternative positions. The court held that Plaintiff did not meet her burden, reasoning that she did not submit the job posting, the job title, or any evidence of the duties or requirements of any position.Further, the court addressed whether the University failed to engage in the interactive process. The court concluded that there is no genuine dispute of material fact about whether the University acted in good faith to make reasonable accommodations for Plaintiff. The University offered to help Plaintiff find a new job many times and considered adopting technologies to help Plaintiff perform her job duties. Once the University realized Plaintiff could not be accommodated in her current position, an employee from the job center reached out to Plaintiff to schedule a meeting about vacant positions. But Plaintiff cancelled it, and the rescheduled meeting could not take place because Plaintiff went on full-time medical leave. Moreover, even if the University did not use good-faith efforts, Plaintiff needed to show that she “could have been reasonably accommodated but for the employer’s lack of good faith.” View "Jessica Ehlers v. University of Minnesota" on Justia Law

The Court of Appeals held that when an employer pays premiums to a mutual insurance company to obtain a policy for its employee and the insurance company demutualizes, the employee is entitled to the proceeds from demutualization.Medical Liability Mutual Insurance Company (MLMIC) issued professional liability insurance policies to eight medical professionals who were litigants in the cases before the Court of Appeals on appeal. The premiums for the policies were paid by the professionals' employers. After MLMIC demutualized and was acquired by National Indemnity Company, MLMIC sought to distribute $2.502 billion in cash consideration to eligible policyholders pursuant to its plan of conversion. At issue was the employers' claim of legal entitlement to receive the demutualization proceeds. The Supreme Court held that, absent contrary terms in the contract of employment, insurance policy, or separate agreement, the employee, who is the policyholder, is entitled to the proceeds. View "Columbia Memorial Hospital v. Hinds" on Justia Law

O’Connell began working for the County in 1999 and became a participant in the Benefit Fund, with the County transferring a portion of his salary to the Fund as his employee contribution (40 ILCS 5/9-108). In 2001, O’Connell was diagnosed with multiple sclerosis. In 2017, after exhausting his paid leave, O’Connell obtained an ordinary disability benefit (50% of his salary). The Board stated that based on his years of service, the benefit would expire in August 2021. The County separated him from the position effective July 1, 2019. The Board ceased paying the ordinary disability benefit to O’Connell; the County ceased making contributions to the Fund on O’Connell’s behalf.O’Connell filed suit, alleging that the Illinois Pension Code and the pension protection clause of the Illinois Constitution (Ill. Const. 1970, art. XIII, 5) entitled him to continued ordinary disability benefit payments even though the County had terminated his employment. The appellate court reversed the dismissal of his complaint. The Illinois Supreme Court affirmed. O’Connell maintained standing to seek relief for reinstatement of his ordinary disability benefit by the Board and of contributions by the County and stated a sufficient cause of action for declaratory judgment and for mandamus. Once the Board grants the employee the ordinary disability benefit, Pension Code section 9-157 then enumerates triggering events, which do not include termination of employment, that halt the benefit. View "O'Connell v. County of Cook" on Justia Law

The Federal Employees’ Retirement System Act provides early retirement benefits to law enforcement officers (LEOs), 5 U.S.C. 8412(d) after obtaining sufficient "LEO credit," which may be awarded for time served in either a primary law enforcement position or secondary (supervisory or administrative) law enforcement position if an employee is “transferred directly” to a secondary position after serving in a primary position. Klipp worked for the TSA, 1991-2009. In a parallel case, Klipp was determined to be entitled to LEO credit for 1991–98, but not for 1998–2008; his 2004–2009 position was not eligible for LEO credit, although it was a secondary position, because there was a break in service between his primary position and his secondary position.Klipp then sought primary LEO credit for his post-2004 position. In 2004, TSA hired Klipp as a Supervisory Criminal Investigator-Assistant Federal Security Director-Law Enforcement (AFSD-LE) for the New Orleans International Airport. The government never hired subordinate officers or investigators for him to supervise. In 2005, Klipp’s position title changed to “nonsupervisory” criminal investigator. Klipp argued that LEO credit can be awarded if the applicant’s actual duties were primarily LEO duties, even if the position description denotes a secondary position. The Merit Systems Protection Board denied Klipp's request for retroactive LEO retirement coverage for 2005-2009. The Federal Circuit vacated. The Board did not properly analyze whether 50 percent or more of Klipp’s actual duties were LEO duties under circuit precedent. View "Klipp v. Department of Homeland Security" on Justia Law

The Supreme Court reversed the judgment of the circuit court refusing to implement the decision of the grievance panel to reinstate Petitioner to her position as an employee for the City of Norfolk, holding that the circuit court erred in refusing to implement the grievance panel's decision.After holding a hearing regarding Petitioner's termination the grievance panel decided to reinstate Petitioner and award her backpay. When the City Manager declined to implement the panel's decision Petitioner brought this action. The circuit court ruled that it would not enforce the panel's decision because it was against public policy. The Supreme Court reversed, holding that the circuit court erred when it failed to implement the panel's binding decision and reinstate Petitioner. View "LaRock v. City of Norfolk" on Justia Law

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