Justia Labor & Employment Law Opinion Summaries

The Supreme Court affirmed the order of the circuit court that denied Appellant's request for injunctive relief preventing the University of Arkansas for Medical Sciences (UAMS) from terminating his employment and dismissing Appellant's complaint, holding that the relief sought in this complaint was moot.After Appellant, a former tenured professor at UAMS, was terminated he sought an injunction. UAMS moved to dismiss the complaint, arguing that Appellant's claim was moot and that UAMS was immune from suit. The circuit court denied Appellant's request for injunctive relief and dismissed the case with prejudice. The Supreme Court affirmed, holding that Appellant's claims were moot, and therefore, dismissal was appropriate. View "Mahadevan v. Board of Trustees of University of Arkansas System" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Plaintiff's employment discrimination complaint against Mercy Hospital Rogers, holding that the circuit court erred in dismissing Plaintiff's claim under the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-101 to -108.Specifically, the Supreme Court held (1) Plaintiff failed to plead that Mercy made any false representations of material fact sufficient to sustain a fraud action; (2) because Plaintiff failed to state an exception to the at-will doctrine, the circuit court properly dismissed Plaintiff's wrongful termination claim; and (3) given the circuit court's lack of factual development on the issue, the Supreme Court cannot determine whether Mercy is a religious organization entitled to the ACRA religious-organization exemption, and therefore, remand was required. View "Jenkins v. Mercy Hospital Rogers" on Justia Law

The Supreme Court overruled Savage v. St. Aeden’s Church, 189 A. 599 (Conn. 1937), insofar as it concluded that an employee is entitled to compensation as a matter of law when, during the course of the employee's employment, he or she is injured due to an idiopathic fall onto a level floor.The Appellate Court reversed the decision of the Compensation Review Board (Board) affirming the decision of the Workers' Compensation Commissioner for the Second District (Commissioner) denying Plaintiff's application for benefits filed after she suffered a syncopal episode at her workplace, which caused her to fall backward and strike her head on the ground, concluding that, under Savage, Plaintiff's injury was compensable as a matter of law. The Supreme Court reversed after overruling the portion of Savage at issue, holding that the risk or condition must be "peculiar to the employment" for the injury to be compensable. View "Clements v. Aramark Corp." on Justia Law

The Eleventh Circuit held that relocation benefits provided by a railroad to its employees are exempt under the Railroad Retirement Tax Act as bona fide and necessary expenses incurred by the employee in the business of the employer, 26 U.S.C. 3231(e)(1)(iii). The court also held that, because no regulatory substantiation requirements apply, CSX is entitled to a refund. Accordingly, the court affirmed in part the district court's grant of summary judgment in favor of the United States in regard to whether relocation benefits are exempt under section 3231(e)(1)(iii); reversed in part the district court's grant of summary judgment in regard to CSX's need and failure to satisfy the Accountable Plan Regulation; and remanded for the district court to calculate the amount of CSX's refund and administer the notification process. View "CSX Corp. v. United States" on Justia Law

The Supreme Court affirmed the orders of the district court (1) resolving the parties' summary judgment motions, ruling in favor of Defendant, Plaintiff's former employer, in Plaintiff's wrongful discharge lawsuit; and (2) denying Plaintiff leave to amend his complaint in that case to add an age discrimination claim, holding that there was no error.Specifically, the Supreme Court held that the district court (1) did not err in holding that Defendant's failure to exhaust internal grievance procedures precluded his wrongful discharge case as a matter of law; and (2) did not abuse its discretion in finding Defendant's age discrimination claim futile and therefore denying his motion for leave to amend the complaint. View "Hathaway v. Zoot Enterprises, Inc." on Justia Law

Plaintiffs-appellees Darrell Reeves and James King worked as welding inspectors for Enterprise Products Partners through third party staffing companies, Cypress Environmental Management and Kestrel Field Services. Reeves brought a collective action claim to recover unpaid overtime wages under the Fair Labor Standards Act. King later consented to join the putative collective action and was added as a named plaintiff. Enterprise argued that both Reeves and King signed employment contracts with their respective staffing companies that contained arbitration clauses for disputes. The Tenth Circuit found that indeed both plaintiffs’ respective contracts contained arbitration clauses, and that under the doctrine of equitable estoppel, these agreements require the claims to be resolved in arbitration. “Because Reeves and James’s claims allege substantially interdependent and concerted misconduct by Enterprise and non-defendant signatories, Cypress and Kestrel, arbitration should be compelled for these claims.” The Court reversed the district court’s denial of Enterprise’s motions to compel. View "Reeves, et al. v. Enterprise Products Partners" on Justia Law

In 2008, FTS technicians filed suit alleging that they were unlawfully deprived of overtime compensation for the prior three years. The district court authorized a collective action; 293 technicians opted in to the collective action. In 2011, a jury returned verdicts of liability and determined the average number of unrecorded hours worked per week by each testifying technician. Based on those findings, the court applied a 1.5 multiplier for calculating uncompensated overtime, calculated damages for all technicians in the collective action, and entered a judgment. The Sixth Circuit upheld the certification of the case as a collective action and the jury’s verdicts but held that the district court erred in applying a 1.5 multiplier, and in failing to calculate the hourly rates to reflect the actual hours Plaintiffs worked.After a remand from the Supreme Court, FTS sought to raise new issues that were unrelated to the recalculation of the hourly rate and correcting the multiplier. The district court barred FTS from raising most of those arguments, recalculated damages, and entered judgment. The court also substantially granted Plaintiffs’ counsel’s petition for attorney’s fees. The Sixth Circuit affirmed. The district court was constrained on remand to the specific issues; its mandate rule barred FTS and from raising arguments on judicial estoppel, aggregate judgment, and sufficiency of the evidence. View "Monroe v. FTS USA, LLC" on Justia Law

The First Circuit reversed the order of the district court denying Lyft Inc.'s request to compel arbitration in this purported class action but affirmed the denials of preliminary injunctive relief, holding that the Federal Arbitration Act (FAA) applied.Plaintiffs were Massachusetts-based rideshare drivers who used the Lyft application and platform to find passengers. In their complaint, Plaintiffs claimed that Lyft misclassified them as independent contractors rather than employees. At issue on this appeal were rulings concerning Plaintiffs' requests for preliminary injunctive relief and the denial of Lyft's request to compel arbitration. The First Circuit reversed in part, holding (1) the FAA applies in this case; and (2) the district court did not err in denying Plaintiffs' requested injunction. View "Cunningham v. Lyft, Inc." on Justia Law

The Supreme Court reversed in part and affirmed in part the order of the circuit court affirming the judgment of the Board of Review affirming the decision of a Labor Dispute Tribunal that certain union members employed at a production plant (Claimants) were not disqualified for unemployment compensation benefits, holding that the lower tribunals erred.In 2012, representatives of Constellium Rolled Products Ravenswood, LLC and United Steelworkers Local 5668, the union representing the majority of Constellium's employees, met to negotiate a new collective bargaining agreement. When the parties could not come to terms Claimants went on strike. After the strike ended, Claimants applied for unemployment compensation benefits. The Tribunal decided that Claimants were not disqualified for benefits under W. Va. Code 21A-6-3(4), the labor dispute provision. The Board and circuit court affirmed. The Supreme Court reversed in part, holding that the lower tribunals erred in holding that Claimants were not disqualified for unemployment compensation benefits under the labor dispute provision. View "Constellium Rolled Products Ravenswood, LLC, v. Cooper" on Justia Law

Houston began working for TDA in 2012. Houston’s responsibilities required on-site inspections to confirm compliance with state and federal regulations. Houston suffers from lupus, anemia, and other illnesses, requiring her to be absent from work and sometimes take leave under the Family and Medical Leave Act (FMLA). In 2016, Houston returned to her position after a long-term medical leave and submitted a request for accommodations permitting her to telework and to work a compressed workweek. TDA allowed Houston to work four 10-hour days but denied the telework request because Houston’s duties could not be performed solely from home and Houston needed training to improve performance.Later in 2016, Houston received warnings for “failure to meet expectations,” excessive absenteeism and tardiness, inadequate job performance, insubordination, leaving work early, accruing overtime without approval, late arrivals to sites being audited, failure to submit accurate and timely administrative reviews, and failure to follow TDA’s travel policy. An April 2017 warning notified Houston that she was on a 90-day probation period. When the probationary period ended, TDA discharged Houston because of her failure to correct her performance deficiencies, excessive absenteeism and tardiness unrelated to protected FMLA leave, and insubordination. The Fifth Circuit affirmed summary judgment, rejecting Houston’s FMLA retaliation claim, 29 U.S.C. 2601, and her Rehabilitation Act, 29 U.S.C. 701, discrimination claim.TDA established legitimate, nondiscriminatory reasons for Houston’s termination; Houston failed to raise a disputed material fact showing that those reasons were pretextual. View "Houston v. Texas Department of Agriculture" on Justia Law