Justia Labor & Employment Law Opinion Summaries

Dr. Placzek, a physician, entered into an employment agreement with MCHS In 2015, Placzek had a miscarriage, which required time off. MCHS provides Short-Term Disability (STD) benefits but Placzek did not submit an STD claim. MCHS later gave her five days of STD benefits. In 2016, Dr. Placzek took 12 weeks of maternity leave; she used STD benefits for the first six weeks. For the last six weeks of maternity leave, Placzek wanted to use vacation time. Placzek was eligible for an educational-loan reimbursement of $15,000 per year; if the physician terminates the agreement “except for a breach by the Medical Center,” the physician must repay two reimbursements. In 2017, Placzek resigned; her appointment at Mayo Clinic had been terminated unilaterally by Mayo in 2016. Placzek brought a Minnesota Whistleblower Act (MWA) claim against Mayo, alleging retaliation for reporting a violation of law and a breach-of-contract claim against MCHS for failing to provide additional STD benefits for her miscarriage, improperly paying her STD benefits for her maternity leave, and not allowing her to use paid vacation for her maternity leave. She sought a declaratory judgment that she need not repay her educational-loan reimbursement. The Eighth Circuit affirmed the rejection of all of her claims. Although she worked some of her full-time hours at a Mayo Clinic site, Placzek was an independent contractor, not a Mayo employee for MWA purposes. MCHS did not breach the employment agreement in calculating her benefits or in denying her paid vacation time. View "Placzek v. Mayo Clinic" on Justia Law

Avenoso, a maintenance supervisor, had long-term disability insurance under a Reliance policy, governed by the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1132(a)(1)(B). The policy provided two years of benefits if the claimant showed that he was unable to perform the material duties of his current occupation and provided continued benefits if the claimant showed that he was unable to perform the material duties of any occupation. Avenoso left his job due to lower-back pain and underwent back surgery. Reliance approved two years of benefits. At the end of the two years, Reliance informed Avenoso that it would discontinue benefits because Avenoso had not shown that he was unable to perform the material duties of any occupation.Avenoso had an MRI; the results appeared relatively mild. Avenoso sent Reliance a note from his physician, recommending that Avenoso “avoid lifting, bending and prolonged sitting” due to his lower back condition. He was receiving Social Security disability benefits. Following a “functional-capacity evaluation,” a physical therapist concluded Avenoso did not demonstrate an ability to tolerate an 8-hour workday. An independent medical evaluation concluded that Avenoso retained sedentary-work capacity and was “able to work 8 hours a day but was engaging in “symptom magnification.” A vocational-rehabilitation specialist identified five “viable sedentary occupational alternatives” consistent with Avenoso’s physical capacities. The Eighth Circuit affirmed summary judgment in favor of Avenoso. The district court’s finding that Avenoso lacks sedentary-work capacity was not clearly erroneous. View "Avenoso v. Reliance Standard Life Insurance Co" on Justia Law

The Fifth Circuit affirmed the district court's grant of summary judgment in favor of defendants in an action brought by plaintiff, an oil-platform worker, after he injured his back while building scaffolding. Plaintiff filed suit against the companies managing both the day-to-day construction and the overall construction project. The court concluded, however, that a reasonable jury could not find that either company was liable for the worker's injury because neither was his direct employer. In this case, the Hickman factors weigh in favor of holding that plaintiff was Grand Isle and BP's independent contractor. Furthermore, the court agreed with the district court that the operational-control exception did not apply as to either BP or Grand Isle. View "Coleman v. BP Exploration & Production, Inc." on Justia Law

The Union represents employees at Constellium’s plant. In 2013, after Constellium attempted to change retirees’ health benefits, the Union sued. In 2017, the Fourth Circuit held, in "Barton," that, because the collective bargaining agreement (CBA) stated that retiree health benefits would endure only for the CBA's term, they did not vest. Constellium and the Union subsequently negotiated another CBA, effective through September 2022, which outlines retiree healthcare benefits. Constellium sent a letter to its Medicare-eligible retirees, announcing changes to their healthcare coverage.The Union initiated a grievance, citing the CBA’s guarantee of retiree health benefits for the CBA’s term. Constellium claimed that the change did not violate the CBA and that Barton permitted the change with respect to retirees who retired under previous CBAs. Constellium unsuccessfully sought a declaratory judgment that it prevailed on preclusion grounds; the district court reasoned that whether Barton precluded arbitration was a question for the arbitrator.An arbitrator ruled in favor of the Union, reasoning that “the question of whether retiree health benefits were vested or durational”—which was “central” in Barton—was "a red herring” because the Union’s new claims did not depend on whether the benefits were vested or durational, but focused on the terms of the 2017 CBA, under which Constellium was obligated to maintain the same health benefits for the relevant retirees throughout the CBA's full term. The Fourth Circuit affirmed the denial of Constellium’s motion to vacate the arbitrator’s award. View "Constellium Rolled Products Ravenswood, LLC v. United Steel, Paper & Forestry, Rubber, Manufacturing, Energy, Allied Industrial & Service Workers International Union" on Justia Law

Plaintiffs, formerly employed as deputy sheriffs, filed a 42 U.S.C. 1983 action alleging that defendants violated their First Amendment rights based on Defendant Cole's retaliatory employment actions taken after plaintiffs supported his political opponent. The district court granted defendants' motion for summary judgment and dismissed the complaints.The Eighth Circuit affirmed, concluding that the district court did not err in interpreting Curtis v. Christian County, 963 F.3d 777 (8th Cir. 2020), by concluding that even if plaintiff is a first responder and other provisions of Missouri law protect against discharge for engaging in political activity, because he was a Missouri deputy sheriff, plaintiff was legally terminated and Cole did not violate plaintiff's constitutional rights. The court explained that whether Cole violated plaintiffs' state statutory political activity rights is an inquiry separate from whether he violated their First Amendment rights. The court's conclusion that Cole committed no unconstitutional act necessarily resolves the municipal liability issue involving Christian County and the Christian County Commissioners, sued in their official capacities. Because Cole is entitled to qualified immunity under Curtis, the court did not address plaintiffs' second argument about affirmative defenses. View "Burns v. Cole" on Justia Law

AT&T employed Fowler, 1986-2016. She was diagnosed in 2006 with epilepsy that caused cognitive impairments. In 2015, she was diagnosed with breast cancer and informed AT&T of her diagnosis. In December 2015, AT&T planned to reduce Fowler’s unit by consolidating roles. Fowler began a new position in March 2016. After two months, Fowler sought reassignment, acknowledging she did not have the skills for the job. AT&T, through an outsourced service center, negotiated with Fowler’s doctors on her accommodation requests but the representatives found that Fowler “could not describe a specific accommodation that would help her on the job.” Fowler, age 60, was laid off and could not find any replacement positions within AT&T. She was terminated and sued under the Americans with Disabilities Act, 42 U.S.C. 12101, and the Age Discrimination in Employment Act, 29 U.S.C. 621.The Third Circuit affirmed summary judgment in favor of AT&T. Based on the original downsizing, Fowler established an adverse employment action that could support a discrimination claim, although she eventually found another job within AT&T. However, AT&T provided powerful evidence that Fowler’s selection for downsizing was simply a neutral reduction in force; she has not provided sufficient evidence to suggest that the explanation was a pretext. As for Fowler’s termination, she may not maintain discrimination or failure-to-accommodate claims connected to a job for which she was not qualified by her own admission. View "Fowler v. AT&T Inc." on Justia Law

The Court of Appeals held in these consolidated appeals that liability for the death benefits claims at issue could not be transferred to the Special Fund for Reopened Cases (the Special Fund).At issue in these appeals was whether New York Workers' Compensation Law 25-a(1-a), under which no liability for claims submitted on or after January 1, 2014 may be transferred to the Special Fund, forecloses the transfer of liability for a death benefits claim submitted on or after the cut-off date, regardless of the prior transfer of liability for a worker's disability claim arising out of the same injury. The Court of Appeals held that, based on the plain statutory language and this Court's established precedent, liability for the death benefits claims at issue in these cases could not be transferred to the Special Fund. View "Verneau v. Consolidated Edison Co. of N.Y." on Justia Law

After the Board concluded that NYPS committed an unfair labor practice and ordered NYPS to reinstate an employee and make him whole, NYPS appealed the Board’s liability finding but failed to file an opening brief. The Fifth Circuit entered a default judgment and the Board held a compliance proceeding to determine damages. At the proceeding, an ALJ awarded some $91,000 in backpay to the employee.The Fifth Circuit concluded that the district court's findings support the Board's conclusion that petitioners constitute a single employer. In this case, substantial evidence supports the Board's finding that there is common ownership and financial control among petitioners; substantial evidence supports the Board's finding of an interrelation of operations between all five petitioners; the record supports the Board's finding that a common cast of characters, who operate on a "readily fungible" team, manage the companies; and substantial evidence once supports the Board's findings that there is centralized control over critical policy matters.The court rejected petitioners' contention that the underlying 2013 merits order is void ab initio because of the Supreme Court's holding in NLRB v. Noel Canning, 573 U.S. 513, 519 (2014). The court affirmed the Board's order to pay the employee backpay except for the portion of that order awarding backpay for the period of October 2014 to 2018. As to that part of the order, the court reversed and remanded. Finally, the court rejected petitioners' evidentiary arguments. View "New York Party Shuttle, LLC v. National Labor Relations Board" on Justia Law

Elation sued Fenn and Shi for breach of a nondisclosure agreement (NDA) (against Shi only) entered during the course of Shi’s prior employment with Elation and breach of a confidential settlement agreement and mutual release (Settlement Agreement) (against both defendants) entered to resolve a prior action between the parties. The defendants filed a cross-complaint, alleging Elation’s breach of the Settlement Agreement. Elation admitted to liability and stipulated to $10,000 in liquidated damages on the cross-claim for breach of the Settlement Agreement. A jury found that Shi had breached the NDA and harmed Elation, and awarded Elation $10,000 in damages. The court entered judgment notwithstanding the verdict (JNOV), denied Elation’s motion for injunctive relief, and awarded defendants $700,000 in attorney fees.The court of appeal reversed in part. The trial court should have awarded Elation nominal damages on its NDA claim, as defendants’ JNOV motion did not challenge the jury’s finding that Shi breached the NDA. Substantial evidence did not support the jury’s finding in Elation’s favor on its Settlement Agreement claim. The court affirmed the order granting JNOV as to Elation’s Settlement Agreement claim and vacated the award of attorney fees. View "Elation Systems, Inc. v. Fenn Bridge LLC" on Justia Law

The Supreme Court reversed the order of the circuit court preliminarily enjoining the West Virginia Paycheck Protection Act, passed by the Legislature in 2021, from taking effect, holding that the circuit court abused its discretion when it granted Respondents injunctive relief.Respondents - labor unions, employee associations, and individual members of such groups - sought to enjoin the enforcement of the Act, which prohibits state employers from continuing to deduct union dues and employee association membership fees from public employees' wages. The circuit court concluded that the law violated certain of Respondents' constitutional rights and that its enforcement would irreparably harm them. The Supreme Court reversed, holding that the circuit court abused its discretion when it did not deny injunctive relief to Respondents. View "Justice v. W. Va. AFL-CIO" on Justia Law