Justia Labor & Employment Law Opinion Summaries

Angel Tudor, a teacher with post-traumatic stress disorder (PTSD), worked for Whitehall Central School District for approximately 20 years. Tudor had an accommodation allowing her to leave campus for 15-minute breaks during her prep periods to manage her PTSD symptoms. In 2016, Whitehall prohibited teachers from leaving school grounds during prep periods, leading Tudor to take medical leave. Upon her return, Whitehall provided inconsistent accommodations, which Tudor claimed were insufficient. For the 2019-20 school year, Tudor's schedule included a study hall period during which she was not guaranteed her requested break, leading her to take unauthorized breaks.The United States District Court for the Northern District of New York granted summary judgment in favor of Whitehall, holding that Tudor's ability to perform her job without accommodation was fatal to her failure-to-accommodate claim under the Americans with Disabilities Act (ADA). The court assumed Tudor had a qualifying disability but found that she could not establish the third element of her claim because she could perform her job's essential functions without accommodation.The United States Court of Appeals for the Second Circuit reviewed the case and concluded that the district court erred. The appellate court held that an employee may qualify for a reasonable accommodation under the ADA even if they can perform the essential functions of their job without it. The court emphasized that the ADA requires employers to provide reasonable accommodations, not just necessary ones. The judgment of the district court was vacated, and the case was remanded for further proceedings consistent with this opinion. View "Tudor v. Whitehall Central School District" on Justia Law

Members of a local union sued their national parent organization for imposing an illegal trusteeship. The plaintiffs, members of NABET-CWA Local 41, claimed that the national union imposed the trusteeship in bad faith following a local officer election. The district court agreed with the plaintiffs and issued a temporary restraining order, later converting it into a preliminary injunction. The parties eventually settled, resulting in a consent judgment that dissolved the trusteeship and required the national union to pay Local 41 approximately $26,000 in trusteeship costs. The only unresolved issue was whether the plaintiffs were entitled to attorneys' fees.The United States District Court for the Northern District of Illinois denied the plaintiffs' request for attorneys' fees. The court acknowledged its broad discretion and the American Rule, which presumes against fee shifting. It considered two exceptions: bad faith and common benefit. The court found that while the national union acted in bad faith in imposing the trusteeship, both parties litigated the dispute in good faith, thus not justifying fee shifting. Additionally, the court recognized that the plaintiffs conferred common benefits on Local 41 and the national union but concluded that these benefits were not substantial enough to merit an award of attorneys' fees.The United States Court of Appeals for the Seventh Circuit reviewed the district court's decision for abuse of discretion. The appellate court affirmed the district court's ruling, finding that the lower court had appropriately applied the American Rule and its exceptions. The district court's decision to deny attorneys' fees was deemed reasonable and within its broad discretion, as it provided a sound explanation for its conclusions. The appellate court emphasized the highly deferential standard of review for such decisions and upheld the district court's judgment. View "Siddiqui v National Association of Broadcast Employees & Tec" on Justia Law

Mr. Dourdounas, a high school math teacher, was assigned to the Absent Teacher Reserve (ATR) in 2012. The ATR is a pool of teachers whose positions were eliminated but who were not terminated. In 2017, the DOE and UFT created a voluntary severance package for ATR teachers. Mr. Dourdounas, believing he was still in the ATR pool, applied for the severance package but was denied because the DOE claimed he had been permanently hired at Bronx International High School.Mr. Dourdounas followed the grievance process outlined in the collective bargaining agreement (CBA) between the DOE and UFT. After exhausting the grievance process, including an internal appeal within the UFT, he commenced an article 78 proceeding against the City, alleging breach of contract for denying him the retirement incentive. The DOE moved to dismiss the petition on several grounds, including timeliness and failure to state a cause of action.The Supreme Court dismissed the petition as time-barred, and the Appellate Division affirmed, stating that the statute of limitations began when Mr. Dourdounas was informed of the denial in July 2017. The Appellate Division held that pursuing the grievance process did not toll the statute of limitations.The New York Court of Appeals affirmed the dismissal but on different grounds. The court held that under the precedent set in Ambach, an employee cannot seek judicial review of a claim arising under a CBA without alleging a breach of the duty of fair representation by the union. Since Mr. Dourdounas did not allege such a breach, his claim was dismissed. The court also clarified that claims arising solely from a CBA must be brought as a breach of contract action, not through an article 78 proceeding. View "Matter of Dourdounas v City of New York" on Justia Law

Haylee Hinton was injured in a car accident caused by another motorist running a red light. She initially sought compensation from her employer’s workers’ compensation insurer and later settled with the motorist’s insurance carrier. Hinton then filed a claim for underinsured motorist benefits with Midwest Family Mutual Insurance, her underinsured motorist coverage provider, and submitted the claim to arbitration as permitted by Utah law.Midwest sought a declaratory judgment from the district court to limit the categories of damages Hinton could recover in arbitration, citing Utah Code section 31A-22-305.3(4)(c)(i), which excludes benefits paid or payable under the Workers’ Compensation Act from underinsured motorist coverage. The district court interpreted the statute to mean that past and future medical expenses and two-thirds of lost wages were payable under workers’ compensation and ruled that Hinton could not recover these categories of damages from Midwest.Hinton petitioned for interlocutory review, arguing that the district court lacked jurisdiction and misinterpreted the statute. The Utah Supreme Court found that the district court had jurisdiction but misinterpreted the statute. The court concluded that “payable” means benefits that can or may be paid to a specific claimant in a particular case, not just categories of damages generally available under workers’ compensation. The court vacated the district court’s order and remanded the matter for further proceedings to determine what benefits remain payable to Hinton under the Workers’ Compensation Act. View "Hinton v. Midwest Family Mutual Insurance" on Justia Law

Mark R. Schmidt, a workers' compensation attorney, sustained a work-related injury while loading files into a trial bag. His treatment included pain management with medications like OxyContin and Oxycodone. To avoid increasing his medication dosage, his physician, Dr. Murphy, prescribed CBD oil. Schmidt purchased CBD oil and lotion over the counter and used them as directed. He sought reimbursement from his employer, Schmidt, Kirifides and Rassias, PC, for the CBD oil costs, which the employer refused, arguing that CBD oil is not a pharmaceutical drug.A Workers' Compensation Judge (WCJ) granted Schmidt's penalty petition, ordering the employer to reimburse him for the CBD oil costs. The Workers' Compensation Appeal Board (Board) reversed this decision, stating that Schmidt did not follow the necessary rules for reimbursement and that CBD oil is not a "supply" under the Workers' Compensation Act (WCA) due to the lack of FDA approval. The Commonwealth Court reversed the Board's decision, concluding that CBD oil is a "medicine" or "supply" under the WCA and that Schmidt, not being a provider, was not required to submit standard billing forms for reimbursement.The Supreme Court of Pennsylvania reviewed the case and held that any item prescribed by a health care provider as part of a treatment plan for a work-related injury falls within the meaning of "medicines and supplies" under Section 306(f.1)(1)(i) of the WCA. The court also held that the cost containment provisions of the WCA and related regulations do not apply to claimants who are not providers. Therefore, Schmidt was entitled to reimbursement for the CBD oil costs, and the Commonwealth Court's order was affirmed. View "Schmidt v. Schmidt, Kirifides & Rassias" on Justia Law

Jason Earlywine was employed as a teacher by the Board of Education of Paris Independent School District (BEP) from August 2007 to June 2019. In 2011, a student accused him of inappropriate conduct, leading to his placement on paid administrative leave, which was later changed to unpaid leave. He faced a criminal charge of Sexual Abuse in the First Degree, but the trial court granted him a directed verdict in January 2015, and the charge was expunged. Earlywine was reinstated in February 2015 but was terminated in 2019 for unspecified reasons. In 2020, he sued BEP to recover lost wages during his unpaid leave.The Bourbon Circuit Court initially handled the case, determining that BEP was within the waiver of immunity under KRS 45A.245(1) but transferred the case to Franklin Circuit Court due to venue appropriateness. BEP appealed, arguing governmental immunity and failure to exhaust administrative remedies. The Court of Appeals ruled that BEP's immunity was waived under KRS 45A.245(1) but concluded that Earlywine's failure to exhaust administrative remedies deprived the court of subject matter jurisdiction.The Supreme Court of Kentucky reviewed the case, affirming that BEP is subject to the waiver of immunity under KRS 45A.245(1). However, it reversed the Court of Appeals' conclusion regarding the exhaustion of administrative remedies, stating that this issue is subject to exceptions and should not have been addressed on interlocutory appeal. The Supreme Court remanded the case to Franklin Circuit Court for further proceedings, allowing Earlywine to argue any applicable exceptions to the exhaustion requirement. View "BOARD OF EDUCATION OF PARIS, KENTUCKY V. EARLYWINE" on Justia Law

Timothy Hoffstead, a canine handler for Metra, was suspended after testing positive for amphetamines and opioids during a random drug test. Hoffstead attributed the positive result to his prescribed medications for ADD, migraines, and a wrist injury. The medical review officer (MRO) attempted to contact Hoffstead for an explanation but was unsuccessful. Consequently, Hoffstead was suspended and later not considered for an open canine handler position. Despite providing proof of his prescriptions and having his test results revised to negative, Metra required him to complete a rehabilitation program. Hoffstead eventually returned to work but left Metra for other employment.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Metra. The court found that Hoffstead failed to demonstrate that Metra's actions were due to his disability. The court also ruled that it could not consider Hoffstead's claim regarding the exercise of seniority under the collective bargaining agreement (CBA) due to the Railway Labor Act (RLA), which prohibits courts from interpreting CBAs.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court held that Hoffstead did not provide sufficient evidence to show that Metra's actions were motivated by his disability. The court noted that Hoffstead's failure to respond to the MRO and his decision to waive an investigation in favor of the rehabilitation program were the primary reasons for Metra's actions. The court also found that the RLA did not preclude adjudicating Hoffstead's claim regarding the seniority rules but concluded that Hoffstead failed to demonstrate a link between his disability and Metra's actions. View "Hoffstead v Northeast Illinois Regional Commuter Railroad Corp" on Justia Law

Scott Cannon, individually and as the personal representative of the estate of Blaise Cannon, filed a wrongful death and punitive damages claim against Blue Cross and Blue Shield of Massachusetts (BCBS). Cannon alleged that BCBS's denial of coverage for a specific inhaler led to asthma-related complications that contributed to Blaise's death. Blaise was a beneficiary of his partner's BCBS health insurance policy, which was governed by the Employee Retirement Income Security Act of 1974 (ERISA).The United States District Court for the District of Massachusetts granted summary judgment to BCBS on the grounds of ERISA preemption. The court found that Cannon's wrongful death claim was preempted by ERISA because it related to an employee benefit plan and arose from the denial of benefits under that plan. The court also held that the claim conflicted with the remedial scheme established by ERISA, which provides specific civil enforcement mechanisms.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that Cannon's claim was statutorily preempted under ERISA because it had a connection with the ERISA-regulated health insurance plan. The court also found that the claim was preempted under ERISA's civil enforcement provisions, as it sought remedies for the denial of benefits under the plan. The court rejected Cannon's argument that the Supreme Court's decision in Rutledge v. Pharmaceutical Care Management Association altered the preemption analysis, reaffirming that ERISA preempts state laws that relate to employee benefit plans. The court concluded that Cannon's wrongful death claim was derivative of Blaise's potential claim for benefits, which would have been preempted by ERISA. View "Cannon v. Blue Cross and Blue Shield of Massachusetts, Inc." on Justia Law

The plaintiff, an employee of the Department of Mental Health and Addiction Services, sustained a work-related injury to her left wrist in April 2016. After undergoing two surgeries and being diagnosed with posttraumatic chronic synovitis, she was determined to have reached maximum medical improvement in March 2020. The defendant sought to convert her temporary partial incapacity benefits to permanent partial disability benefits based on this determination.An administrative law judge approved the defendant's request to convert the benefits, concluding that he lacked the authority to award ongoing temporary partial incapacity benefits once the plaintiff reached maximum medical improvement. The plaintiff appealed to the Compensation Review Board, which affirmed the administrative law judge's decision, agreeing that ongoing temporary partial incapacity benefits are unavailable after reaching maximum medical improvement.The plaintiff then appealed to the Appellate Court, which also affirmed the board's decision. The Appellate Court concluded that an administrative law judge does not have the discretion to award ongoing temporary partial incapacity benefits under General Statutes § 31-308 (a) once a claimant reaches maximum medical improvement and becomes eligible for permanent partial disability benefits under § 31-308 (b).The Supreme Court of Connecticut reviewed the case and reversed the Appellate Court's judgment. The court held that the clear and unambiguous language of § 31-308 (b) gives an administrative law judge the discretion to award a claimant ongoing temporary partial incapacity benefits under § 31-308 (a) in lieu of permanent partial disability benefits under § 31-308 (b) after reaching maximum medical improvement, up to the statutory maximum of 520 weeks. The case was remanded to the administrative law judge for further proceedings consistent with this interpretation. View "Gardner v. Dept. of Mental Health & Addiction Services" on Justia Law

Jon Woods, a workers' compensation attorney, was convicted of 37 felony counts of workers' compensation fraud. Woods had engaged in unlawful kickback and referral fee arrangements, referring copy and subpoena work to companies that provided financial benefits to him and his firm. This corruption affected the workers' compensation system, as the employer's insurance company had to cover the costs.The Superior Court of Orange County reviewed the case, where Woods was found guilty on all counts and received a four-year prison sentence. He was also ordered to pay $701,452 in restitution. Woods appealed, arguing that the Williamson rule precluded convictions on counts 5 through 37, and that the court erred in limiting his cross-examination of certain prosecution witnesses.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court agreed with Woods that the Williamson rule applied, as his conduct fell under a more specific statute, Labor Code section 139.32, which criminalizes kickback schemes and is a misdemeanor. Therefore, the court reversed Woods's convictions on counts 5 through 37, the white-collar sentencing enhancement, and the restitution award based on these charges. However, the court found no error in the trial court's limitation of cross-examination of prosecution witnesses and affirmed the remainder of the judgment. View "People v. Woods" on Justia Law