Justia Labor & Employment Law Opinion Summaries

Matthew Kale sued his employer, Aero Simulation, Inc. (ASI), alleging religious and disability discrimination under Title VII of the Civil Rights Act, the Americans with Disabilities Act (ADA), the Religious Freedom Restoration Act (RFRA), the Constitution, and state law. ASI required all employees to receive the Covid-19 vaccine, with non-compliance resulting in disciplinary action, including termination. Kale requested a religious exemption, citing his belief that his body is a temple of the Holy Spirit and should not be subjected to unwanted intrusions. ASI denied his request, and Kale was terminated. He filed a charge with the EEOC, which issued a right to sue letter.The United States District Court for the District of South Dakota dismissed Kale’s claims, ruling that he failed to plausibly plead religious beliefs conflicting with ASI’s Covid-19 policy, did not allege that ASI regarded him as disabled due to his unvaccinated status, and that his proposed amended complaint was futile. Kale appealed the dismissal of his federal law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court’s dismissal, holding that Kale failed to allege facts showing that ASI’s testing requirement conflicted with his bona fide religious beliefs. The court noted that Kale’s complaint did not adequately connect his objection to testing with specific religious principles. Additionally, the court found that Kale did not exhaust his administrative remedies for his ADA claim, as he only asserted religious discrimination in his EEOC charge. The court also upheld the denial of Kale’s motion to amend his complaint, deeming it futile as it contained the same deficiencies as the original complaint. The judgment was affirmed. View "Kale v. Aero Simulation, Inc." on Justia Law

Matthew Bare sued his former employer, Rainforest Alliance, Inc., in the Superior Court of the District of Columbia, alleging that the company failed to pay him a redundancy settlement after his position was made redundant due to a reorganization. Bare claimed that he had agreed to resign in exchange for the settlement, which was contingent upon his execution of a release-of-claims agreement. However, after Bare made critical comments about the company, Rainforest Alliance terminated him and refused to pay the settlement, leading to claims of breach of contract and violation of the District of Columbia Wage Payment and Collection Law.The Superior Court dismissed Bare's complaint with prejudice, agreeing with Rainforest Alliance that Bare had failed to allege the occurrence of a condition precedent—specifically, the execution of a release agreement. The court found that without alleging this, Bare could not claim he had earned the redundancy payment under the contract or the wage law. Bare had argued that the issue of the condition precedent was a factual matter for summary judgment or trial and that Rainforest Alliance had waived the condition by not providing a release agreement. He also requested leave to amend his complaint if the motion to dismiss was granted.The District of Columbia Court of Appeals reviewed the case and held that the trial court should have granted Bare's request to amend his complaint. The appellate court found that Bare's request to amend was his first, the case had been pending for a short time, there was no evidence of bad faith or dilatory motives, and there was no prejudice to Rainforest Alliance. The court also determined that Bare's proposed amendment, which would include allegations that Rainforest Alliance waived the condition precedent by not providing a release agreement, was not futile. Consequently, the appellate court reversed the dismissal and remanded the case for further proceedings. View "Bare v. Rainforest Alliance, Inc." on Justia Law

The U.S. Department of Education announced a reduction in force (RIF) on March 13, 2025, affecting about half of its employees. Subsequently, twenty-one states and several labor organizations and school districts filed lawsuits against the Secretary of Education, the Department, and the President, claiming that the RIF violated the U.S. Constitution and the Administrative Procedure Act (APA). They also sought an injunction against the transfer of certain functions out of the Department, announced by the President on March 21, 2025.The U.S. District Court for the District of Massachusetts consolidated the cases and granted the plaintiffs' motions for a preliminary injunction. The court found that the plaintiffs were likely to succeed on the merits of their claims, determining that the RIF and the transfer of functions were likely ultra vires and violated the APA. The court concluded that the actions were arbitrary and capricious, lacking a reasoned explanation and failing to consider the substantial harms to stakeholders.The United States Court of Appeals for the First Circuit reviewed the case. The court denied the appellants' motion for a stay pending appeal. The court found that the appellants did not make a strong showing that they were likely to succeed on the merits, particularly regarding the APA claims. The court also determined that the plaintiffs would suffer substantial injury without the injunction, as the RIF made it effectively impossible for the Department to carry out its statutory functions. The court concluded that the public interest favored maintaining the injunction to ensure the Department could fulfill its legal obligations. View "New York v. McMahon" on Justia Law

Anna Palova, a flight attendant for United Airlines since 1992, was terminated in February 2020 for allegedly engaging in "parking," a prohibited scheduling tactic. United Airlines claimed that Palova manipulated flight assignments, violating the collective bargaining agreement (CBA). Palova, however, argued that her termination was due to age discrimination, as she and two other older flight attendants were fired while younger attendants who committed similar infractions were not.The United States District Court for the Southern District of Texas granted summary judgment in favor of United Airlines. The court concluded that the Railway Labor Act (RLA) precluded Palova's Age Discrimination in Employment Act (ADEA) claim and preempted her Texas Commission on Human Rights Act (TCHRA) claim. The court reasoned that resolving Palova's claims would require interpreting the CBA, which falls outside the court's jurisdiction under the RLA.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the RLA does not preclude or preempt Palova's age discrimination claims. The court found that Palova's claims of age discrimination were independent of the CBA and did not require its interpretation. The court noted that while the CBA might be referenced, it was not dispositive of the discrimination claims. Consequently, the Fifth Circuit vacated the district court's summary judgment order and remanded the case for further proceedings consistent with its opinion. View "Palova v. United Airlines" on Justia Law

In 1996, Katherine Stovall, while employed at New England Telephone Company, experienced pain in her hands and wrists due to a work-related injury. By 1998, the pain had spread, leading her to take a leave of absence. She returned to work in 1999 but ultimately stopped working in June 2001 due to increased pain. Stovall notified her employer of a new injury/aggravation in August 2001. In 2004, she filed petitions for benefits for both the 1996 and 2001 injuries. In 2006, a hearing officer awarded her benefits for the 2001 injury but not for the 1996 injury, which she had withdrawn.The Workers’ Compensation Board hearing officer found that the 2001 injury was a significant aggravation of the 1996 injury. In 2011, New England Telephone filed a petition to review the benefits, asserting that the 520-week limit on compensation payments had been reached. The hearing officer granted the petition, finding that Stovall had achieved maximum medical improvement and had no permanent impairment from the 2001 injury.Stovall filed a petition for restoration of benefits for the 1996 injury in 2017, nearly eleven years after payments for the 1996 injury had ceased. An ALJ denied the petition as time-barred, concluding that Stovall had not shown that New England Telephone was on notice that its payments for the 2001 injury were related to the 1996 injury. The Appellate Division vacated this decision, ruling that the payments for the 2001 injury tolled the statute of limitations for the 1996 injury.The Maine Supreme Judicial Court vacated the Appellate Division's decision, holding that Stovall failed to prove that New England Telephone was on notice that its payments for the 2001 injury were related to the 1996 injury. The case was remanded for the Appellate Division to affirm the denial of Stovall’s petition as time-barred. View "Stovall v. New England Telephone Company" on Justia Law

In August 2022, a bin full of phosphate rock collapsed at the Lee Creek Mine in Beaufort, North Carolina, injuring three miners. Industrial TurnAround Corporation (ITAC), the independent contractor responsible for checking the structural integrity of the bin's support columns, was cited by the Mine Safety and Health Administration (MSHA) for failing to take defective equipment out of service. MSHA sent a notice of proposed penalty to ITAC's outdated address of record, and ITAC did not contest the penalty, which became final 30 days later. ITAC subsequently filed a motion to reopen the penalty, claiming it had inadvertently failed to update its address of record.The Federal Mine Safety and Health Review Commission granted ITAC's motion to reopen the penalty, citing excusable neglect under Federal Rule of Civil Procedure 60(b). The Commission noted that ITAC had not occupied the address since 2009 and had only discovered the MSHA notice when an employee checked for missing packages. The Secretary of Labor, representing MSHA, opposed the motion, arguing that ITAC's failure to update its address could not be excused under FRCP 60(b).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Commission’s order to reopen the penalty was not an appealable collateral order and dismissed the Secretary’s petition for lack of jurisdiction. The court emphasized that the order did not impose an obligation, deny a right, or fix a legal relationship, and that the interest in immediate review did not meet the high threshold required under the collateral order doctrine. The court concluded that the Commission’s decision to reopen the penalty did not involve a substantial public interest or a particular value of a high order that justified immediate appeal. View "Secretary of Labor v. Industrial TurnAround Corporation" on Justia Law

Garten Trucking LC, a company specializing in the transportation of paper products, faced a union organizing campaign by the Association of Western Pulp and Paper Workers (AWPPW) in mid-2021. After losing a union representation election, AWPPW filed multiple unfair labor practice charges against Garten Trucking, alleging various violations of the National Labor Relations Act (NLRA). An Administrative Law Judge (ALJ) found Garten Trucking guilty of several violations, including unlawful interrogation and threats, and ordered a new election. The National Labor Relations Board (NLRB) affirmed the ALJ's findings and mandated bargaining with AWPPW.While the initial case was pending, AWPPW continued its organizing efforts, distributing a flyer claiming that Garten Trucking was required to bargain with the union and that the union's presence led to employee raises. In response, Garten Trucking's owner, Robert Garten, posted a message on the company's internal board, refuting the union's claims and suggesting that employees would have already received raises if not for the union's actions. The union filed another unfair labor practice charge, and the ALJ ruled that Garten's message violated Section 8(a)(1) of the NLRA by implying that union activities negatively impacted wage increases.The United States Court of Appeals for the Fourth Circuit reviewed the case, focusing on whether Garten's message constituted a coercive threat. The court upheld the NLRB's decision, finding substantial evidence that Garten's statement linking wage increases to union activities was coercive and violated the NLRA. The court emphasized that while employers are entitled to express their opinions on union activities, they cannot make statements that imply threats or promises of benefits based on union support. The court denied Garten Trucking's petition and granted the NLRB's cross-petition for enforcement. View "Garten Trucking LC v. National Labor Relations Board" on Justia Law

An employee, Delbert P. Costa, Jr., suffered a workplace injury on May 9, 2012, while employed by the County of Hawai'i, Department of Water Supply. Costa reported the injury, and the County filed an industrial injury claim, contesting compensability pending investigation. The County did not contest that temporary total disability (TTD) benefits would be due if the injury was compensable. The Director of the Department of Labor and Industrial Relations found the injury compensable on June 24, 2013, but the County did not appeal this decision or pay TTD benefits.Costa applied for a hearing to address the nonpayment of TTD benefits, and the Director issued a supplemental decision on April 25, 2014, awarding TTD benefits and imposing a 20% penalty for late payment. The County appealed to the Labor and Industrial Relations Appeals Board (LIRAB), which reversed the Director’s supplemental decision, finding no statutory basis for the penalty as the TTD benefits were not due before the Director’s decision on compensability.The Intermediate Court of Appeals (ICA) affirmed the LIRAB’s decision, although it noted errors in the LIRAB’s application of the evidentiary standard and its characterization of HRS § 386-92 as punitive. The ICA agreed with the LIRAB that the Director’s decision did not order TTD benefits and thus did not support the imposition of a penalty.The Supreme Court of the State of Hawai'i reviewed the case and held that a penalty under HRS § 386-92 is appropriate where an employer fails to make timely TTD benefit payments after a final decision on compensability. The Court vacated the ICA’s judgment and the LIRAB’s decision, remanding the case to the LIRAB to assess the penalty and determine attorneys’ fees and costs. View "Costa v. County of Hawai'i" on Justia Law

Alexander Smith, a Christian firefighter in Atlantic City, was prohibited from growing a beard due to the city's grooming policy, which he claimed violated his religious beliefs. Smith sued the city, alleging violations of the Free Exercise Clause, the Equal Protection Clause, and Title VII’s accommodation and anti-retaliation provisions. The District Court denied his motion for a preliminary injunction and later granted summary judgment for the city on all claims.The United States District Court for the District of New Jersey initially denied Smith's motion for a preliminary injunction, finding that his claims were unlikely to succeed on the merits. After discovery, the court granted summary judgment in favor of the city on all four claims, leading Smith to appeal the decision.The United States Court of Appeals for the Third Circuit reviewed the case. The court vacated the District Court’s judgment regarding Smith’s Title VII accommodation claim and his free exercise claim, finding that the city's grooming policy was not generally applicable and failed strict scrutiny. The court affirmed the District Court’s judgment on the equal protection claim and the Title VII retaliation claim, concluding that Smith did not establish a prima facie case of retaliation. Additionally, the court reversed the denial of Smith’s motion for a preliminary injunction, recognizing a likelihood of success on the merits and the irreparable harm caused by the loss of First Amendment freedoms. View "Smith v. City of Atlantic City" on Justia Law

Brett Jens resigned from his position at Wilbur-Ellis Company, LLC, and subsequently joined a competitor, J.R. Simplot Company. Wilbur-Ellis filed a lawsuit against Jens and Simplot, seeking a preliminary injunction to enforce restrictive covenants in Jens’s employment agreement and to prevent Simplot’s alleged tortious interference with the agreement. The district court denied the motion for a preliminary injunction, concluding that the restrictive covenants were no longer enforceable.The United States District Court for the District of South Dakota reviewed the case and determined that Wilbur-Ellis was unlikely to succeed on the merits of its breach of contract claim against Jens. The court found that the restrictive covenants in Jens’s employment agreement did not survive past the agreement’s expiration date of February 28, 2010. Wilbur-Ellis appealed the denial of the preliminary injunction, arguing that the restrictive covenants were intended to begin when Jens’s employment ended. Simplot cross-appealed, contending that Wilbur-Ellis could not enforce the restrictive covenants because the employer in the agreement was Wilbur-Ellis Air, LLC, not Wilbur-Ellis Company, LLC.The United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision for abuse of discretion. The appellate court affirmed the district court’s denial of the preliminary injunction, agreeing that the restrictive covenants did not survive the expiration of the employment agreement. The court emphasized that the agreement did not contain a survival clause or any language indicating that the restrictive covenants were intended to extend beyond the termination of the agreement. Consequently, the court concluded that Wilbur-Ellis was unlikely to succeed on the merits, which is the most significant factor in determining whether to issue a preliminary injunction. View "Wilbur-Ellis Company LLC v. Jens" on Justia Law