Justia Labor & Employment Law Opinion Summaries

Rachel Moniz and Paola Correa filed separate lawsuits against Adecco USA, Inc. under the Private Attorney General Act of 2004 (PAGA), alleging violations of the Labor Code. Moniz and Adecco settled their case, but Correa challenged the fairness of the settlement. The trial court approved the revised settlement over Correa's objections and awarded attorney’s fees to Moniz’s counsel. Correa's request for a service award and attorney’s fees for her own work was largely denied. Correa appealed, arguing the trial court's analysis of the revised settlement was flawed and that her request for attorney’s fees and a service award should have been granted.The San Mateo County Superior Court overruled Adecco's demurrer in Moniz's case, while the San Francisco Superior Court sustained Adecco's demurrer in Correa's case. Correa's motion to intervene in Moniz's suit was denied, and her subsequent appeal was also denied. The trial court approved Moniz's settlement with Adecco, awarding Moniz a service award and attorney’s fees, but denied Correa’s requests. Correa's motions for a new trial and to vacate the judgment were denied, leading to her appeal.The California Court of Appeal, First Appellate District, Division Four, reviewed the case. While the appeal was pending, the California Supreme Court decided Turrieta v. Lyft, Inc., which disapproved of the reasoning in Moniz II regarding Correa’s standing. The Court of Appeal concluded that Correa and her counsel lacked standing to challenge the judgment based on the Supreme Court's decision in Turrieta. Consequently, the appeals were dismissed. View "Moniz v. Adecco USA, Inc." on Justia Law

The Santa Ana Police Officers Association (SAPOA) and certain anonymous City of Santa Ana police officers (Doe Officers) sued the City of Santa Ana, alleging wrongful disclosure of confidential personnel records, failure to investigate a complaint about the disclosure, and denial of a request for related communications. The first amended complaint included four causes of action: violation of Penal Code section 832.7 and Evidence Code sections 1043 and 1045, negligence, failure to investigate under Penal Code sections 832.5 and 832.7, and violation of the Meyers-Milias Brown Act (MMBA).The Superior Court of Orange County sustained the City’s demurrer to the first amended complaint without leave to amend, leading to the dismissal of the case. The court found that the Doe Officers could not proceed anonymously without statutory authority or court authorization. It also concluded that the SAPOA lacked standing and that there was no private right of action for the alleged violations of the Penal Code and Evidence Code sections cited.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court affirmed the judgment as to the Doe Officers, agreeing they lacked authorization to proceed anonymously. It also affirmed the trial court’s decision regarding the first, second, and fourth causes of action, finding no private right of action for damages under the cited statutes and that the SAPOA failed to exhaust administrative remedies for the MMBA claim. However, the appellate court reversed the judgment concerning the third cause of action, holding that the SAPOA had standing to seek mandamus relief to compel the City to investigate the complaint and notify the SAPOA of the disposition, as required by Penal Code sections 832.5 and 832.7. The case was remanded for further proceedings on this cause of action. View "Santa Ana Police Officers Assn. v. City of Santa Ana" on Justia Law

A minor, through his mother, filed a lawsuit against Best Academy after his teacher, Aaron Hjermstad, sexually assaulted him. Hjermstad had a history of sexual abuse allegations from his previous employment, which Best Academy did not uncover during their hiring process. The school did not obtain reference letters or contact references, which were part of their hiring protocol.The district court granted summary judgment in favor of Best Academy, reasoning that hiring decisions are always protected by the discretionary-function exception to municipal tort liability under Minnesota Statutes section 466.03, subdivision 6. The court of appeals affirmed this decision, applying the same reasoning.The Minnesota Supreme Court reviewed the case and concluded that a municipality’s hiring decision is not categorically a policy-level decision involving weighing competing economic, social, political, and financial considerations. The court emphasized that the discretionary-function exception should be interpreted narrowly and that municipalities bear the burden of proving that their conduct involved such considerations. The court found that Best Academy did not provide evidence that its decision not to investigate Hjermstad’s background was based on balancing policy considerations. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "Minor Doe 601 v. Best Academy" on Justia Law

Barton Hankins was hired by Crain Automotive Holdings, LLC in 2019 as Chief Operating Officer and was offered a deferred compensation plan (DCP). After four years, Hankins resigned and sought compensation under the DCP, which Crain denied. Hankins then filed a lawsuit under the Employee Income Retirement Security Act of 1974 (ERISA) to claim his benefits. The DCP stipulated that Hankins could earn a percentage of Crain’s fair market value upon his exit, with full vesting at five years. Having served four years, Hankins was entitled to 80% of the benefits.The United States District Court for the Eastern District of Arkansas granted judgment in favor of Hankins, concluding that the DCP did not require the creation of an Employment Agreement or a Confidentiality, Noncompete, and Nonsolicitation Agreement for enforceability. The court found that Crain’s claims of misconduct by Hankins were unsubstantiated and awarded Hankins attorney’s fees, determining that Crain’s conduct was sufficiently culpable.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s judgment, holding that Crain’s interpretation of the DCP was unreasonable. The court found that the DCP’s Article 4, which mentioned the Employment and Confidentiality Agreements, did not create a condition precedent but rather a condition subsequent. The court also upheld the award of attorney’s fees, noting that Crain’s actions lacked merit and were raised only after Hankins sought his vested compensation. The appellate court concluded that the district court did not abuse its discretion in its rulings. View "Hankins v. Crain Automotive Holdings, LLC" on Justia Law

Deidre Parker, a black woman, was employed as a Program Management Assistant by the Risk Management Agency (RMA) of the USDA starting in March 2011. She filed an EEOC complaint in 2013, which was settled in 2015. Parker alleged that after the settlement, she experienced race and gender discrimination, retaliation, constructive discharge, and a hostile work environment. Her duties diminished after a change in the timekeeping system, and she was tasked with cleaning out file cabinets. She requested additional work and development opportunities but did not act on them. Parker received two letters of counseling for disruptive conduct and filed EEOC complaints in 2017 and 2018, alleging discrimination and retaliation.The United States District Court for the Western District of Missouri granted summary judgment in favor of the USDA on all counts. The court limited its review to events occurring after the 2015 settlement agreement, finding that Parker had waived claims arising before that date. The court found that Parker failed to establish a prima facie case of discrimination or retaliation under the McDonnell Douglas framework, as most of the conduct did not constitute an adverse employment action, and there was no evidence supporting an inference of discrimination. Her hostile work environment claims failed due to a lack of causal link between the USDA’s conduct and her race or gender, and her constructive discharge claim failed because she did not prove that her workplace was intolerable or that the USDA intended for her to quit.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that the district court did not abuse its discretion in limiting the scope of Parker’s claims to conduct occurring after the settlement agreement. The court also found that Parker failed to demonstrate a causal nexus between the alleged adverse actions and her race or gender, and that her claims of hostile work environment, constructive discharge, and retaliation were unsupported by sufficient evidence. View "Parker v. United States" on Justia Law

Larry Smith worked for Newport Utilities for many years, primarily repairing downed powerlines during weather emergencies. He began experiencing seizures, which led to two on-the-job incidents within months. Newport Utilities placed him on leave and later forced him to retire. Smith sued under the Americans with Disabilities Act (ADA), claiming discrimination based on his disability.The United States District Court for the Eastern District of Tennessee granted summary judgment to Newport Utilities, finding that Smith posed a safety threat in his position and that the company could not reasonably accommodate him.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Smith posed a direct threat of harm to himself and others due to his seizures, which could not be eliminated by reasonable accommodation. The court found that the essential functions of Smith's job as a bucket foreman included working extended hours and being on standby, which Smith could not perform safely. The court also determined that Newport Utilities had investigated potential alternative positions for Smith, but he did not qualify for any of them. The court affirmed the district court's grant of summary judgment to Newport Utilities. View "Smith v. Newport Utilities" on Justia Law

Kurt Beathard, a football coach at Illinois State University (ISU), was terminated from his position as offensive coordinator after posting a handwritten message on his office door that read, “All Lives Matter to Our Lord & Savior Jesus Christ.” This occurred during a period of tension and unrest on the ISU campus following the death of George Floyd. Beathard alleges that his termination was due to this personal speech, which he claims is protected by the First Amendment.The United States District Court for the Central District of Illinois reviewed the case. The defendants, Larry Lyons and Brock Spack, filed a motion to dismiss the complaint under Rule 12(b)(6), arguing that they were entitled to qualified immunity. The district court denied the motion, stating that factual development was necessary before resolving the question of qualified immunity. The court found that Beathard had made a viable claim that his speech was personal and protected, but it was premature to engage in the Pickering balancing test at the pleading stage.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court concluded that it lacked jurisdiction to hear the appeal because the district court had not made a definitive ruling on the qualified immunity defense but had instead postponed the decision pending further factual development. The Seventh Circuit emphasized that interlocutory orders, such as the denial of a motion to dismiss, are generally not immediately appealable unless they conclusively determine the issue of qualified immunity, which was not the case here. Therefore, the appeal was dismissed for want of appellate jurisdiction. View "Rogers v. Byroad" on Justia Law

Brian Ranger, a maintenance worker for Alamitos Bay Yacht Club, was injured while performing his duties, which included hoisting and mooring vessels. On August 28, 2018, he slipped and fell while boarding a vessel, resulting in serious injuries. Ranger applied for state workers' compensation and subsequently sued the Club under general maritime law, alleging negligence and unseaworthiness.The Los Angeles County Superior Court sustained the Club's demurrer without leave to amend, concluding that Ranger failed to allege facts implicating federal admiralty jurisdiction. Although the court acknowledged the tort occurred on navigable waters, it found that Ranger did not demonstrate his fall posed more than a fanciful risk to maritime commerce. The Court of Appeal affirmed the decision but on different grounds, holding that the Longshore and Harbor Workers’ Compensation Act (LHWCA) displaced general maritime law, making California’s workers’ compensation scheme Ranger’s exclusive remedy.The Supreme Court of California reviewed the case and concluded that the Court of Appeal erred. The court held that the 1984 amendments to the LHWCA, which exclude certain workers from federal workers' compensation if they are covered by state laws, did not abrogate general maritime remedies for those outside the LHWCA’s scope. The court also determined that California’s workers’ compensation exclusive-remedy provision could not deprive Ranger of his substantive federal maritime rights under the supremacy clause of the federal Constitution. The judgment of the Court of Appeal was reversed, and the case was remanded for further proceedings to address unresolved issues, including whether Ranger’s claims properly invoked admiralty jurisdiction. View "Ranger v. Alamitos Bay Yacht Club" on Justia Law

Gerry Serrano, a police officer for the City of Santa Ana, took a leave of absence to serve as president of the Santa Ana Police Officers Association. The Public Employees’ Retirement System (CalPERS) determined that certain special pay additives Serrano received before and during his service as Association president could not be included in his pension. The Administrative Board of CalPERS and the Superior Court of Sacramento County affirmed the exclusion of most of these pay additives from Serrano’s pension. Serrano appealed, arguing that Government Code section 3558.8 mandates he cannot lose any compensation, including pensionable compensation, while serving as the Association president. He also challenged the specific exclusion of a confidential premium and holiday pay from his pensionable compensation.The Superior Court of Sacramento County denied Serrano’s petition for writ of administrative mandamus, which sought to vacate the Board’s decision and include all pay additives in his retirement calculation. Serrano then appealed to the California Court of Appeal, Third Appellate District.The California Court of Appeal, Third Appellate District, affirmed the lower court’s decision. The court held that section 3558.8 did not require the compensation Serrano earned as a police sergeant to be entirely pensionable while he served as Association president. The court concluded that the confidential premium was not pensionable because it constituted nonpensionable overtime and did not meet the regulatory definition for the confidentiality premium. Additionally, the court found that Serrano’s holiday pay was not pensionable because he was not required to work on holidays, as required by the relevant regulation. The court’s decision was based on the interpretation of the Retirement Law and the specific definitions and requirements for pensionable compensation under that law. View "Serrano v. Public Employees' Retirement System" on Justia Law

John Lowry, a harbor patrol officer, suffered physical and psychiatric injuries, including PTSD, from a workplace accident. His psychiatrist deemed him unfit to return to work, and the Port San Luis Harbor District (the District) indicated that his only option was retirement. Lowry applied for disability retirement, but the District denied his application, stating insufficient information to determine disability. The California Public Employees’ Retirement System (CalPERS) also denied his application, and the District terminated his employment, claiming he voluntarily resigned, which was later admitted to be untrue.The trial court granted summary judgment in favor of the District, concluding that Lowry was not eligible for relief under the California Fair Employment and Housing Act (FEHA) because he could not perform his essential job duties with or without reasonable accommodations. The court found that disability retirement does not qualify as a term, condition, or privilege of employment under FEHA.The California Court of Appeal, Second Appellate District, Division Six, affirmed the trial court's decision. The court held that the denial of disability retirement payments is not an adverse employment action under FEHA. Disability retirement payments serve as income replacement for employees who can no longer work and do not facilitate continued employment, job performance, or advancement opportunities. The court concluded that an individual who is not a qualified employee cannot bring a disability discrimination claim under FEHA for the denial of disability retirement payments. The judgment in favor of the District was affirmed. View "Lowry v. Port San Luis Harbor Dist." on Justia Law