Justia Labor & Employment Law Opinion Summaries

The Supreme Court affirmed the ruling of the district court ruling that Plaintiff's employer had complied with Iowa Code 35C.6 when it terminated the employment of Plaintiff, a military veteran, from his job as a police officer at the University of Iowa's (UI) Department of Public Safety (DPS), holding that the district court did not err.Plaintiff was charged with misconduct after he violated DPS policies. Following arbitration, Plaintiff was terminated and was later reinstated without back pay. Plaintiff filed a petition for writ of certiorari alleging that DPS violated section 35C.6 in his initial termination. The district court ruled that DPS had complied with section 35C.6 as interpreted in Kern v. Saydel Community School District, 637 N.W.2d 157 (Iowa 2001). The Supreme Court affirmed, holding (1) this Court declines to overrule Kern; and (2) the district court correctly determined that the State complied with Iowa Code 35C.6 in terminating Plaintiff. View "Williams v. Bullock" on Justia Law

The Supreme Court reversed the judgment of the district court denying Hamilton County Public Hospital's motion for summary judgment concerning Plaintiff's defamation claim and Iowa Wage Payment Collection Law (IWPCL) claim, holding that Plaintiff's defamation and statutory wage claims failed.Plaintiff, a general surgeon, was employed by the hospital. After an investigation, Plaintiff's employment through a for-cause provision in his contract was terminated. The hospital subsequently made two reports to the Iowa Board of Medicine and the National Practitioner Data Bank. Plaintiff then brought this action. The hospital moved for summary judgment on the defamation and IWPCL claims, but the district court denied the motion. The Supreme Court reversed on interlocutory appeal, holding (1) Plaintiff's defamation claim failed because the challenged portions of the reports were nonactionable opinions; and (2) Plaintiff's statutory wage claim failed because he did not perform work for which he was not paid. View "Andrew v. Hamilton County Public Hospital" on Justia Law

WSI appealed a judgment ordering payment of death benefits to Gloria Felan. In 2017, Fred Felan was injured when driving a loaded truck that tipped on its side. Julie Schulz of KBO Farms, Fred’s employer, arrived at the scene a short time later. Fred declined an ambulance but agreed to allow Schulz to drive him to the hospital. At the hospital Fred complained of left chest and rib pain. X-rays taken at the hospital did not reveal any fractures. The next morning, Schulz picked Fred up from the hotel. She noted Fred was falling asleep during the meal and expressed concern he should return to the hospital to get checked again. Fred declined. Fred was discovered dead in his hotel room two days after the accident. WSI accepted Fred’s claim for injuries relating to his truck accident for contusion of thorax. WSI also did not believe Fred died from his work-related injury because Fred had multiple health problems including some related to his heart and diabetes. An autopsy confirmed Fred died of congestive cardiomyopathy and arteriosclerotic heart disease. Gloria thereafter filed a claim for death benefits. WSI would deny this claim, but an ALJ reversed the agency’s denial. WSI argued the ALJ and the district court misapplied the law by failing to properly apply N.D.C.C. 65-01-02(11)(a)(3). The North Dakota Supreme Court reversed the ALJ and district court, finding the ALJ was not provided objective evidence of the claimed injury: Fred died of a cardiac arrhythmia caused by blunt force trauma to his chest cavity. However, a medical expert admitted there was no objective medical evidence that an arrhythmia occurred. Rather, the conclusion the expert reached was a result of deductive reasoning. “As our precedent indicates, objective medical evidence may be established by a physician’s medical opinion based on an examination, a patient’s medical history, and the physician’s education and experience. However, objective medical evidence may not be established solely by deductive reasoning. On this record, the ALJ erred in concluding there was objective medical evidence of a cardiac arrhythmia.” View "WSI v. Felan, et al." on Justia Law

The Court of Appeals held that, under NY City Civ Ct Act 1808, small claims judgments do not have collateral estoppel or issue preclusive effect but that such judgments may have the traditional res judicator or claim preclusive effect in a subsequent action involving a claim between the same parties arising out of the same transaction at issue in a prior small claims court action.Plaintiff brought an action against her former employer in a small claims part of Civil Court seeking damages arising out of the alleged nonpayment of wages. After Defendant satisfied the small claims judgment, Plaintiff commenced this action in the federal district court seeking additional damages based on Defendant's failure to pay her overtime wages. Defendant moved to dismiss the complaint, asserting that the federal litigation was barred under the doctrine of claim preclusion. In response, Plaintiff argued that NY City Civ Ct Act 1808 rendered small claim preclusion inapplicable to small claims judgments unless the subsequent action raised precisely the same claim or theory as the earlier action. The district court rejected Plaintiff's argument but certified a question to the Court of Appeals asking for an interpretation of section 1808. The Court of Appeals answered the question as set forth above. View "Simmons v. Trans Express Inc." on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Defendant in this case alleging a violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., holding that genuine issues of material fact precluded summary judgment.Plaintiff, who was Black, sued Bridgewater State university's Board of Trustees and Office of Equal Opportunity and a University administrator (collectively, Defendants) alleging that she was not hired for a University position because of her race. The district court granted summary judgment in favor of Defendants. The First Circuit reversed, holding that Plaintiff's aggregate package of proof sufficed to survive Defendants' motion for summary judgment. View "Taite v. Bridgewater State University" on Justia Law

Taylor was fired from his job as a Cook County Sheriff’s officer. He sued the Sheriff’s Office under Title VII of the Civil Rights Act and Ways, Whittler, and Ernst under 42 U.S.C. 1983 for violating the Equal Protection Clause. The defendants maintain that Taylor was terminated for having fired pellets with an air rifle at his neighbor, a charge that Taylor denies. Ernst was the lead investigator assigned to Taylor’s case. Taylor offered evidence that Ernst engineered his firing based on racial animosity. Taylor also asserted that Ways and Whittler, Sheriff’s Office officials, are liable because they reviewed Ernst’s final report and endorsed his recommendation of termination.On interlocutory appeal, the Seventh Circuit upheld the denial of qualified immunity as to Ernst. Taylor presented evidence of Ernst’s significant role in the investigative and disciplinary proceedings that brought about Taylor’s termination. Any reasonable official in Ernst’s position would have known that intentional racial discrimination toward another employee was unconstitutional and what Taylor alleges against Ernst is textbook racial discrimination: the word “n****r,” used by Ernst, a white man, aimed at Taylor on several occasions. The court reversed the denials of qualified immunity to Ways and Whittler; evidence that they played key roles in approving Ernst’s termination does not signal that either harbored any racial animus or that they knew or suspected that Ernst was motivated by race. Taylor’s Title VII claim remains pending. View "Taylor v. Ernst" on Justia Law

D.C. was employed by Applied, 1996-2008, and claimed three industrial injuries: a specific injury to her neck and right upper extremity in 2001, a specific injury to her neck and both upper extremities in 2005, and a cumulative trauma injury to her neck, both upper extremities, and psyche ending on her last day working. D.C. claimed her injuries were due to the constant use of a computer keyboard. In 2006, she developed a pain disorder, anxiety, and depression, which she claimed were compensable consequences of her physical injuries. She later claimed that she was sexually exploited by Dr. Massey, the physician primarily responsible for the treatment of her industrial injuries. D.C. was diagnosed with PTSD. Applied's workers’ compensation carriers disputed liability for her psychiatric injuries.A workers’ compensation judge found that all of D.C.’s injury claims were industrial; awarded D.C. 100 percent permanent disability (PD) based on her PTSD alone; found no apportionment; and concluded that the insurers were jointly and severally liable for that award since Dr. Massey treated all three of her industrial injuries. The Workers’ Compensation Appeals Board generally affirmed.The court of appeal concluded there was substantial evidence of repeated exposure to injury-causing events and new injuries after 2005 that supported the finding of cumulative trauma ending in 2008. D.C. met her burden of proving that her PTSD was a compensable consequence injury that resulted from the treatment for her industrial injuries and that her employment was a contributing cause; as a matter of law, a patient cannot consent to sexual contact with her physician. The court rejected several challenges to the sufficiency of the evidence. The 100 percent PD award must be annulled as based on an incorrect legal theory, the alternative path theory. View "Applied Materials v. Workers' Compensation Appeals Board" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the circuit court awarding a class of Missouri corrections officers $113 million plus post-judgment interest for breach of contract, holding that the circuit court's determination that all preshift and postshift activities are compensable was erroneous.On appeal, the Missouri Department of Corrections (MDOC) argued that the circuit court erroneously determined that MDOC was liable on the corrections officers' breach of contract claims for time spent performing all preshift and postshift activities. The Supreme Court held (1) the circuit court erred in determining that all corrections officers' preshift and postshift activities were compensable principal activities that must be compensated; (2) because the award of damages and the court's declaratory and injunctive relief were based on the erroneous finding of liability, those rulings were erroneous; and (3) the circuit court correctly determined that MDOC must compensate corrections officers for time spent retrieving keys and radios and time spent monitoring and supervising offenders while not on post. View "Hootselle v. Missouri Department of Corrections" on Justia Law

M&K Construction (M&K) appealed a workers’ compensation court’s order (the Order) making it reimburse plaintiff Vincent Hager for the ongoing costs of the medical marijuana he was prescribed after sustaining a work-related injury while employed by M&K. Specifically, M&K contends that New Jersey’s Jake Honig Compassionate Use Medical Cannabis Act was preempted as applied to the Order by the federal Controlled Substances Act (CSA). Compliance with the Order, M&K claims, would subject it to potential federal criminal liability for aiding-and-abetting or conspiracy. M&K also claimed medical marijuana was not reimbursable as reasonable or necessary treatment under the New Jersey Workers’ Compensation Act (WCA). Finally, M&K argued that it fit within an exception to the Compassionate Use Act and was therefore not required to reimburse Hager for his marijuana costs. After review, the New Jersey Supreme Court determined: (1) M&K did not fit within the Compassionate Use Act’s limited reimbursement exception; (2) Hager presented sufficient credible evidence to the compensation court to establish that the prescribed medical marijuana represents, as to him, reasonable and necessary treatment under the WCA; and (3) the Court interpretsed Congress’ appropriations actions of recent years as suspending application of the CSA to conduct that complied with the Compassionate Use Act. As applied to the Order, the Court thus found the Act was not preempted and that M&K did not face a credible threat of federal criminal aiding-and-abetting or conspiracy liability. M&K was ordered to reimburse costs for, and reasonably related to, Hager’s prescribed medical marijuana. View "Hager v. M&K Construction" on Justia Law

Two police officers retired from the Anchorage Police Department (APD) due to discrimination and retaliation. Years later, a jury found that they had been constructively discharged and awarded them lost past wages and benefits. The officers requested that the Anchorage Police and Fire Retirement System (APFRS) increase their retirement benefits based on the award of lost wages. When the APFRS Board denied their request, they appealed to the superior court. The superior court affirmed the Board’s decision and awarded it attorney’s fees. The officers appealed the court’s decision denying them an increase in retirement benefits, arguing that the Anchorage Municipal Code required a recalculation of benefits. They also appealed the attorney’s fee award as unreasonably high. Because the Anchorage Municipal Code did not permit the requested increase in retirement benefits, the Alaska Supreme Court affirmed the superior court’s order denying the officers’ administrative appeal. Because the superior court did not abuse its discretion when it awarded fees, the attorney’s fee award was also affirmed. View "Kennedy et al. v. Anchorage Police & Fire Retirement System et al." on Justia Law