Justia Labor & Employment Law Opinion Summaries

John Sigley applied for a Material Handler position with ND Fairmont LLC (NDF) and was offered the job contingent on passing a physical exam. During the physical, conducted by Industrial Therapy Solutions (ITS), Sigley denied having any back issues or seeing a chiropractor, despite having undergone three back surgeries and having a metal rod in his back. He passed the physical and began working on September 13, 2021. On October 28, 2021, Sigley called out of work due to back spasms and later disclosed his back condition to NDF's HR Manager, Joyce Hardway, and Environmental Health & Safety Manager, Justin Darrah. NDF confirmed Sigley's omission of his back condition during the physical and terminated him for dishonesty on November 2, 2021.Sigley filed a lawsuit against NDF, alleging disability discrimination under the Americans with Disabilities Act (ADA). The United States District Court for the Northern District of West Virginia granted summary judgment in favor of NDF, finding that Sigley was terminated for dishonesty, not because of his disability. The court also dismissed Sigley's claims of breach of confidentiality and failure to accommodate, as they were not properly pled in his complaint.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 Sigley failed to establish a prima facie case of discriminatory discharge, as he could not demonstrate that his termination raised a reasonable inference of unlawful discrimination. The court found that NDF had a legitimate, non-discriminatory reason for terminating Sigley—his dishonesty during the physical exam. The court also noted that Sigley's claims of breach of confidentiality and failure to accommodate were untimely and meritless, as he did not properly plead them and admitted he did not require an accommodation. View "Sigley v. ND Fairmont LLC" on Justia Law

Attorney Jon Rhyan Fritz was admitted to practice law in Kentucky in 1998. He was retained by client Vera Williams to pursue a wrongful termination claim against her employer, House of Bread and Peace (HBP). Williams paid Fritz a $3,500 flat fee, which he deposited into his general business account without a written advance fee agreement. Fritz failed to provide billing statements or memoranda explaining how he was earning the fee. The Equal Employment Opportunity Commission (EEOC) investigated Williams's case but ultimately declined to pursue it further. Fritz did not respond to Williams's subsequent emails or requests for meetings, and no lawsuit was filed against HBP within the statute of limitations.Williams filed a Bar Complaint against Fritz, leading the Office of Bar Counsel (OBC) to open the matter for informal resolution. Fritz responded to initial inquiries but failed to provide Williams's client file as requested. The Inquiry Commission charged Fritz with multiple violations of the Supreme Court Rules (SCR), including lack of diligence, communication, and safekeeping of property. Fritz did not respond to the formal Charge, and attempts to serve him were unsuccessful, leading to constructive service via the Kentucky Bar Association (KBA) Executive Director.The Supreme Court of Kentucky reviewed the case and found that Fritz failed to answer the Charge or participate in the disciplinary process. The court granted the OBC's motion to indefinitely suspend Fritz from practicing law in Kentucky. Fritz is required to notify all courts and clients of his suspension, cancel pending advertisements, and take steps to protect his clients' interests. The suspension order takes effect twenty days after its entry. View "In re Fritz" on Justia Law

The University of Vermont appealed a Vermont Labor Relations Board decision that predoctoral fellows and trainees are employees under the State Employees Labor Relations Act (SELRA). United Auto Workers, Local 2322, filed a petition to represent a bargaining unit of select graduate students, including predoctoral fellows and trainees. The University objected, arguing that these individuals were not employees under SELRA. The Board held a three-day hearing and concluded that predoctoral fellows and trainees were employees, as they provided services for compensation and were supervised or monitored by the University.The Board found that approximately 1700 graduate students were enrolled at the University, with 57 being predoctoral fellows and trainees. These fellows and trainees received stipends, tuition reimbursement, and health insurance, and were required to adhere to specific program requirements, such as internships and professional development. However, they did not receive W-2s, and the University did not withhold taxes from their stipends. The Board concluded that all individuals in the proposed bargaining unit, including predoctoral fellows and trainees, were employees because they worked for the University in return for compensation.The Vermont Supreme Court reviewed the case and found that the Board's findings did not support its conclusion that predoctoral fellows and trainees were employees. The Court noted that the Board made no findings that these individuals worked for the University or that their tasks benefited the University. The Court also highlighted the lack of findings regarding the University's control over the fellows and trainees' work. Consequently, the Court reversed the Board's decision and remanded the case for further consideration of the issue. View "In re United Auto Workers, Local 2322" on Justia Law

The plaintiffs, peace officers employed by the Iowa Department of Corrections, alleged that they were disciplined following administrative investigations and subsequently requested copies of witness statements and investigation reports related to their cases. They claimed that the Department refused to provide these documents as required by Iowa Code chapter 80F. The officers filed a lawsuit seeking money damages and injunctive relief, asserting that the Department violated their rights under chapter 80F.The Iowa District Court for Polk County granted summary judgment in favor of the Iowa Department of Corrections, dismissing the officers' lawsuit. The district court concluded that chapter 80F did not grant the officers a right to bring a cause of action against their employing agency.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that Iowa Code § 80F.1(13) does not provide a private right of action for officers against their employing agency. The court reasoned that the term "person" in § 80F.1(13) does not include government agencies, and the statute does not explicitly exempt the officers' claims from the exclusive remedies provided under the Iowa Administrative Procedure Act (chapter 17A). Therefore, the officers must follow the procedures outlined in chapter 17A to challenge the Department's actions. The court concluded that the officers' claims did not have a direct path to the courthouse through § 80F.1(13) and affirmed the summary judgment in favor of the Department. View "Chandler v. Iowa Department of Corrections" on Justia Law

Michael Ayala, a correctional officer for California’s Department of Corrections and Rehabilitation (CDCR), was injured in a planned attack by inmates. He filed a workers’ compensation claim, asserting that his injuries were due to CDCR’s serious and willful misconduct in failing to address a credible threat of inmate violence. A workers’ compensation administrative law judge (WCJ) initially rejected this claim, but the Workers’ Compensation Appeals Board (Board) found in favor of Ayala, concluding that he was entitled to a 50 percent increase in compensation under Labor Code section 4553 due to CDCR’s serious and willful misconduct.The CDCR did not dispute the finding of serious and willful misconduct but argued that the 50 percent increase should be calculated based on the temporary disability (TD) benefits Ayala would have received under the workers’ compensation law, not the more generous industrial disability leave (IDL) and enhanced industrial disability leave (EIDL) benefits he received under the Government Code. The WCJ agreed with CDCR, but the Board reversed, including IDL and EIDL benefits in the calculation of the increased compensation.The California Supreme Court reviewed the case and agreed with the Court of Appeal, which had reversed the Board’s decision. The Supreme Court held that the term “compensation” under Labor Code section 4553, as defined in section 3207, is limited to benefits provided under the workers’ compensation law. Therefore, the 50 percent increase in compensation for serious and willful misconduct should be calculated based on the TD benefits Ayala was entitled to under the workers’ compensation law, not the IDL and EIDL benefits provided under the Government Code. The judgment of the Court of Appeal was affirmed. View "Dept. of Corrections & Rehabilitation v. Workers' Comp. Appeals Bd." on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

In this wage-and-hour class action, the plaintiffs, employees of ACE American Insurance Company (ACE), alleged that ACE misclassified them as exempt employees and failed to provide benefits required for nonexempt employees under state law. The plaintiffs also added claims under the Private Attorneys General Act of 2004 (PAGA) for the same alleged violations. The plaintiffs had signed arbitration agreements as a condition of their employment, which required them to submit employment-related legal claims to arbitration.The Superior Court of Los Angeles County initially granted ACE's motion to compel arbitration and stayed the case pending arbitration. However, neither party initiated arbitration. The plaintiffs then moved to lift the stay, arguing that ACE was required to initiate arbitration and had waived its right to arbitrate by failing to do so. The trial court agreed with the plaintiffs, finding that ACE's inaction was inconsistent with its right to arbitrate and lifted the stay.The Court of Appeal of the State of California, Second Appellate District, reviewed the case. The court held that the plaintiffs, not ACE, were required to initiate arbitration under the terms of the arbitration agreements. The agreements specified that the party wanting to start the arbitration procedure should submit a demand, and in this context, it referred to the plaintiffs who had employment-related legal claims. The court concluded that ACE did not breach the arbitration agreements or waive its right to arbitration by failing to initiate the process. Consequently, the trial court's order lifting the stay was reversed, and ACE was awarded its costs on appeal. View "Arzate v. ACE American Insurance Company" on Justia Law

Jones Lang LaSalle Americas, Inc. (JLL) provides building management services. In 2023, the International Union of Operating Engineers, Stationary Engineers, Local 39, AFL-CIO (Union) sought certification as the bargaining representative for JLL's Maintenance II and III technicians at an Amazon facility in Napa, California. The Union and JLL agreed to a stipulated election, which was approved by the NLRB's Regional Director. The election was held on May 17, 2023, and all four eligible employees voted in favor of Union representation. JLL refused to bargain with the Union and filed an objection to the election, claiming misconduct by the Board Agent overseeing the election.The Regional Director dismissed JLL's objections, finding them meritless, and certified the election. JLL appealed to the NLRB, which denied the appeal. JLL continued to refuse to bargain, leading the Board's General Counsel to file a complaint. In March 2024, the NLRB issued a summary judgment against JLL, finding that the company violated sections 8(a)(5) and (1) of the National Labor Relations Act by refusing to recognize and bargain with the Union. The Board ordered JLL to bargain with the Union.JLL then filed a petition for review with the United States Court of Appeals for the District of Columbia Circuit, reiterating its claim that the election should be set aside. The Board cross-petitioned for enforcement of its order. The Court of Appeals reviewed the case and found that the Regional Director's decision to certify the election without a hearing was reasonable and supported by substantial evidence. The court held that JLL's objections did not raise substantial and material factual issues that would justify setting aside the election. Consequently, the court denied JLL's petition for review and granted the Board's cross-application for enforcement of its order requiring JLL to recognize and bargain with the Union. View "Jones Lang LaSalle Americas, Inc v. NLRB" on Justia Law

The case involves Tarlochan Sandhu, who worked for various public agencies as a finance and accounting professional and was a member of CalPERS, receiving retirement benefits upon his retirement in 2011. After retiring, Sandhu was hired by Regional Government Services (RGS) in 2015, which assigned him to work for several cities. RGS considered Sandhu its employee, providing him with benefits and paying him, while the cities paid RGS for his services. CalPERS determined Sandhu was a common law employee of the cities, violating postretirement employment rules, and the trial court upheld this determination.The Superior Court of Sacramento County reviewed the case, where Sandhu challenged CalPERS’s decision, arguing he was not a common law employee and that the decision was based on underground regulations. The trial court applied its independent judgment, finding the evidence supported CalPERS’s determination that Sandhu was a common law employee of the cities. The court found the cities had the right to control Sandhu’s work, which is the principal test for an employment relationship, and that several secondary factors also supported this conclusion.The California Court of Appeal, Third Appellate District, reviewed the case. The court affirmed the trial court’s judgment, holding that the common law test for employment applies and that substantial evidence supported the trial court’s finding that Sandhu was a common law employee of the cities. The court also found that Sandhu forfeited his argument regarding underground regulations by not properly raising it in the trial court. The judgment was affirmed, and the parties were ordered to bear their own costs on appeal. View "Sandhu v. Bd. of Admin. of CalPERS" on Justia Law

Black Hills Adventure Lodging (BHAL) manages rental cabins in the Black Hills and hired Stephanie Hammer to clean these cabins. After her relationship with BHAL ended, Hammer applied for reemployment assistance benefits, which BHAL contested, claiming she was an independent contractor. An administrative law judge (ALJ) determined Hammer was an employee and ordered BHAL to pay into the unemployment compensation fund based on her wages and those of others similarly situated. The circuit court affirmed this decision, and BHAL appealed.The ALJ found that Hammer was free to accept or decline cleaning jobs, was not trained or supervised by BHAL, and provided her own cleaning supplies and transportation. Despite these findings, the ALJ concluded that Hammer was not free from BHAL's control and was not customarily engaged in an independently established trade. The circuit court affirmed the ALJ's decision.The Supreme Court of South Dakota reviewed the case and determined that BHAL did not exercise control over Hammer's work, as she had the freedom to accept or decline jobs, set her own hours, and provide her own supplies. However, the court found that Hammer was not customarily engaged in an independently established trade, as she did not provide cleaning services to others, did not advertise her services, and was wholly dependent on BHAL for work.The Supreme Court affirmed the circuit court's decision that Hammer was an employee of BHAL and that BHAL must contribute to the unemployment compensation fund for her wages. However, the court reversed the decision that BHAL was liable for wages paid to "others similarly situated" to Hammer, as each individual's employment status must be determined based on their unique relationship with BHAL. The case was remanded for the circuit court to vacate that portion of the Department's decision. View "Black Hills Adventure Lodging, LLC v. South Dakota Department of Labor and Regulation" on Justia Law