Justia Labor & Employment Law Opinion Summaries

An employee of a California corporation, who was represented by a union and covered by two successive collective bargaining agreements (CBAs), brought two lawsuits in state court against her employer. She alleged violations of various California labor and business statutes, including claims for unpaid wages, overtime, meal and rest breaks, sick leave, wage statement inaccuracies, expense reimbursement, and retaliation. The CBAs included provisions regarding pay, leave, breaks, and a dispute resolution process for grievances.The employer removed both cases to the United States District Court for the Eastern District of California, arguing that the employee’s claims were preempted by § 301 of the Labor Management Relations Act (LMRA), which would create federal jurisdiction. The district court determined that only the claims related to untimely wage payments were preempted and thus converted to federal claims under § 301. These federal claims were dismissed because the employee had not exhausted the grievance procedures required by the CBAs. The court found that the remaining state law claims were not preempted, declined to exercise supplemental jurisdiction over them, and remanded those claims to state court. The employer appealed the remand orders.The United States Court of Appeals for the Ninth Circuit held that it had jurisdiction to review the remand orders because the district court’s remand was not based on a lack of subject matter jurisdiction or a defect in removal procedure. The Ninth Circuit affirmed the district court’s conclusion that the remaining state law claims were not preempted by § 301, as they arose from California statutes rather than the CBAs and did not require interpretation of the CBAs. The court also held that the district court did not abuse its discretion in remanding the non-preempted claims to state court. The judgment was affirmed. View "RENTERIA-HINOJOSA V. SUNSWEET GROWERS, INC." on Justia Law

The plaintiff, a former employee of a dental supply company, suffered a traumatic brain injury and later filed a claim for long-term disability (LTD) benefits under her employer’s LTD plan, which was insured and administered by an independent insurance company. After her claim was denied, she left her job and entered into a separation agreement with her employer. This agreement included a broad release of claims against the employer and its “parents, subsidiaries, related or affiliated entities,” as well as their agents, including claims under the Employee Retirement Income Security Act of 1974 (ERISA). Before signing, the plaintiff sought clarification from her employer about whether the release would affect her ability to pursue her LTD claim against the insurer. The employer’s representatives assured her that the insurer was a separate, independent entity and that the agreement would not impact her ability to appeal the denial of her LTD claim.After the insurer denied her appeal, the plaintiff sued the insurer in the United States District Court for the Southern District of New York, alleging violations of ERISA. The insurer moved for summary judgment, arguing that the release in the separation agreement barred her claims. The district court agreed, holding that the insurer was covered by the release and that the plaintiff knowingly and voluntarily waived her ERISA claims against it. The court granted summary judgment in favor of the insurer, and the plaintiff appealed.The United States Court of Appeals for the Second Circuit reviewed the case de novo. The court held that, based on the totality of the circumstances, the plaintiff did not knowingly and voluntarily release her ERISA claims against the insurer. The court emphasized the employer’s express assurances to the plaintiff that the release would not affect her LTD claim and found no evidence to create a genuine dispute on this point. The Second Circuit vacated the district court’s judgment and remanded the case for further proceedings. View "Schuyler v. Sun Life Assurance Company of Canada" on Justia Law

Brian Flores, a current NFL coach, brought a putative class action against the National Football League and several of its member clubs, including the Denver Broncos, New York Giants, and Houston Texans, alleging racial discrimination under federal, state, and local law. Flores’s claims stemmed from his interviews and employment experiences with these teams, during which he alleged discriminatory hiring practices. His employment contracts with various NFL teams incorporated the NFL Constitution, which contains a broad arbitration provision granting the NFL Commissioner authority to arbitrate disputes between coaches and member clubs.The United States District Court for the Southern District of New York reviewed the defendants’ motion to compel arbitration based on Flores’s employment agreements. The District Court granted the motion for claims against the Miami Dolphins, Arizona Cardinals, and Tennessee Titans, but denied it for Flores’s claims against the Broncos, Giants, Texans, and related claims against the NFL. The court found the NFL Constitution’s arbitration provision illusory and unenforceable under Massachusetts law, as it allowed unilateral modification by the NFL and lacked a signed agreement in one instance. The District Court also denied the defendants’ motion for reconsideration.On appeal, the United States Court of Appeals for the Second Circuit affirmed the District Court’s orders. The Second Circuit held that the NFL Constitution’s arbitration provision, which vested unilateral substantive and procedural authority in the NFL Commissioner, did not qualify for protection under the Federal Arbitration Act and was unenforceable because it failed to guarantee Flores the ability to vindicate his statutory claims in an impartial arbitral forum. The court also affirmed the denial of the motion for reconsideration, concluding there was no abuse of discretion. View "Flores v. N.Y. Football Giants" on Justia Law

A registered nurse, who identified as a dark-skinned Salvadoran woman, was employed at an acute care hospital. After a night in which she took a prescribed opioid for shingles, she reported to work without notifying her supervisor of her medication use. On that day, two incidents occurred in which controlled opioids were improperly removed from the hospital’s secure medication dispensing system. Several coworkers observed that the nurse appeared disoriented, drowsy, and exhibited slurred speech. Following these observations and the missing medication, supervisors required her to undergo a fitness for duty exam and drug test, which was positive for opiates but later deemed explained by her prescription. The hospital conducted an internal investigation, reviewed security logs, and ultimately terminated her employment for suspected drug diversion, policy violations, and unsafe patient care.The United States District Court for the Northern District of Illinois, Eastern Division, granted summary judgment in favor of the hospital on all claims. The nurse had alleged discrimination and retaliation based on color and national origin under Title VII, disability discrimination and failure to accommodate under the ADA, interference and retaliation under the FMLA, and violations of the Illinois Human Rights Act. The district court found that no reasonable factfinder could conclude the hospital’s actions were unlawful.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and affirmed the district court’s grant of summary judgment. The appellate court held that the nurse failed to establish a prima facie case of discrimination or retaliation under Title VII, as her conduct and observed behavior distinguished her from other employees. The court also found insufficient evidence to support her ADA, FMLA, and IHRA claims, concluding that the hospital’s actions were not shown to be motivated by unlawful animus or to have violated any statutory rights. The court affirmed the judgment in favor of the hospital on all claims. View "Lohmeier v Gottlieb Memorial Hospital" on Justia Law

A firefighter in Forrest City, Arkansas, was terminated after posting a provocative anti-abortion image on his personal Facebook page. The image, intended to express his pro-life views, was interpreted by some as racially insensitive, particularly because it included the caption “I can’t breathe!”—a phrase associated with protests following George Floyd’s death. After complaints from a retired fire supervisor and others, the firefighter deleted the post. However, the mayor placed him on administrative leave and, following a brief investigation, fired him, citing the public outcry and concerns about the city’s ability to provide public services. The firefighter, who had served over four years without prior incident, learned of his termination through a press release.The firefighter filed suit in the United States District Court for the Eastern District of Arkansas, alleging First Amendment retaliation against the mayor in both his individual and official capacities, and against the city for an alleged unwritten policy allowing officials to censor employee speech. The district court granted summary judgment for the defendants, holding that the mayor was entitled to qualified immunity and that there was no evidence of an unwritten policy justifying the official-capacity and policy-based claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court held that the firefighter’s Facebook post addressed a matter of public concern and was made as a private citizen. The court found insufficient evidence of actual or reasonably predicted disruption to the fire department’s operations to justify summary judgment for the defendants. The court reversed the district court’s grant of summary judgment on the First Amendment retaliation claims against the mayor and the city, affirmed the dismissal of the unbridled-discretion claim, and remanded for further proceedings. View "Melton v. City of Forrest City, Arkansas" on Justia Law

Kevin Rhodes, a former employee of the Missouri Highways and Transportation Commission, was terminated in December 2019 following an investigation into allegations of workplace misconduct, including the use of a racial slur. Rhodes filed grievances about his treatment during the investigation and, after his termination, brought charges of discrimination with the Missouri Commission on Human Rights. He subsequently received notices of right to sue and filed a lawsuit in circuit court alleging sex discrimination, retaliation, and hostile work environment under the Missouri Human Rights Act.A jury in the Circuit Court of Jackson County found in favor of the commission on the sex discrimination claim but ruled for Rhodes on his retaliation and hostile work environment claims, awarding him various damages. The circuit court applied a statutory damages cap and entered judgment accordingly. The commission moved for judgment notwithstanding the verdict, which the circuit court denied. Both parties appealed: Rhodes challenged the constitutionality of the damages cap, while the commission argued that Rhodes had not made a submissible case. The case was transferred to the Supreme Court of Missouri due to the constitutional issues raised.The Supreme Court of Missouri determined that the circuit court’s judgment was not final because it failed to address Rhodes’s requests for equitable relief and prejudgment interest. The court explained that a final judgment must dispose of all claims and forms of relief sought. Because the judgment did not resolve all aspects of Rhodes’s claims, the Supreme Court of Missouri dismissed the appeal for lack of a final judgment, declining to address the merits of the parties’ arguments. View "Rhodes v. Missouri Highways and Transportation Commission" on Justia Law

David Carter, who was 61 years old when he began working for the Missouri Department of Corrections, experienced repeated harassment from his supervisor, including disparaging remarks about his age and his medical condition, shingles. The supervisor’s conduct included denying Carter access to necessary tools and training, which worsened Carter’s health issues and ultimately led to his resignation. Carter subsequently filed a lawsuit alleging violations of the Missouri Human Rights Act, claiming constructive discharge due to age and disability discrimination, hostile work environment, and retaliation. In his petition, Carter sought compensatory and punitive damages, attorney fees, costs, prejudgment and post-judgment interest, and equitable relief.A jury in the Circuit Court of Jackson County found in Carter’s favor, awarding him substantial damages for non-economic harm, back pay, future economic losses, and punitive damages. The circuit court initially entered judgment for the full amount of the jury’s award, then later amended the judgment to reduce the damages in accordance with the statutory cap under section 213.111.4. The court also awarded attorney fees and costs but did not address Carter’s requests for prejudgment interest or equitable relief in its final judgment.The Supreme Court of Missouri reviewed the case on appeal. The court determined that the circuit court’s judgment was not final because it failed to resolve Carter’s requests for prejudgment interest and equitable relief, and did not include a statement denying all other requested relief. As a result, the Supreme Court of Missouri dismissed the appeal for lack of a final judgment, without reaching the merits of the parties’ arguments regarding the damages cap, attorney fees, or the sufficiency of the evidence. View "Carter v. Missouri Department of Corrections" on Justia Law

Three California-based truck drivers who worked for a national transportation company challenged the legality of their employer’s compensation system. The drivers alleged that the company’s pay plan, which combined hourly wages with a bonus based on certain activities, violated California’s Labor Code by failing to properly compensate for nonproductive time and by not reimbursing necessary business expenses, such as personal cell phone use. They also claimed the company failed to provide accurate wage statements and sought penalties under the Private Attorneys General Act (PAGA) and California’s Unfair Competition Law.After the case was removed from state court, the United States District Court for the Central District of California denied class certification and granted summary judgment to the employer on most claims. The court found that the pay plan qualified for a statutory “safe harbor” because it paid at least minimum wage for all hours worked, with additional bonuses for certain activities, and thus did not require separate compensation for nonproductive time. The court also found no evidence that the employer knew or should have known about any off-the-clock work. The only claims that proceeded to trial were for failure to reimburse business expenses. At trial, the jury found in favor of the employer, and the court entered judgment accordingly, also awarding costs to the employer.The United States Court of Appeals for the Ninth Circuit affirmed the district court’s judgment. The Ninth Circuit held that the employer’s pay plan met the requirements of California Labor Code § 226.2(a)(7)’s safe harbor, as it paid at least minimum wage for all hours worked and provided additional bonuses. The court also found no genuine dispute of material fact regarding off-the-clock work or wage statement violations, and it upheld the district court’s evidentiary rulings, jury instructions, and award of costs. View "WILLIAMS V. J.B. HUNT TRANSPORT, INC." on Justia Law

Stella Paterakos, a white woman, worked as an Assistant Community Living Specialist for the City of Chicago. In 2020, after Crystal Warren, a black woman, became her supervisor, Paterakos was disciplined three times, resulting in suspensions of one, three, and five days. The cited reasons for discipline included violations of office policies, work assignments, and issues related to her use of Family and Medical Leave Act (FMLA) leave. Paterakos admitted to much of the conduct underlying the suspensions but alleged she was singled out for harsh treatment due to her race. She also claimed that her third suspension interfered with or retaliated against her for taking FMLA leave. Additionally, she was temporarily assigned to a different office, which she argued was racially motivated.After her third suspension, Paterakos filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, alleging violations of Title VII of the Civil Rights Act, the Equal Protection Clause, the FMLA, and the Age Discrimination in Employment Act. The defendants moved for summary judgment. The district court granted summary judgment on all claims, finding no reasonable jury could conclude that the suspensions or the temporary assignment were motivated by race, age, or constituted unlawful FMLA interference or retaliation. Paterakos appealed, dropping her age discrimination claim but challenging the summary judgment on her Title VII, Equal Protection, and FMLA claims.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The Seventh Circuit affirmed the district court’s judgment, holding that no reasonable jury could find that the suspensions or assignment were based on race rather than documented performance issues. For the FMLA claims, the court held that the defendants’ honest belief that Paterakos was abusing her FMLA leave defeated her interference and retaliation claims. View "Paterakos v City of Chicago" on Justia Law

A newspaper requested records from a school district related to an investigation into allegations that a long-time employee had sexually harassed other employees. The district hired a law firm to conduct a Title IX investigation, which resulted in a report. The district and the employee entered into a settlement agreement ending his employment, with the district paying him a lump sum and a portion of his health insurance. The newspaper sought all documents related to the investigation and settlement, but the district repeatedly denied the requests, citing statutory exemptions for confidential and personnel records.The Superior Court of New Hampshire reviewed the case after the newspaper filed suit. The court granted the district’s request for in camera review of the records, conducted the review without counsel present, and ordered redacted records to be distributed. It found that some records were protected by attorney-client privilege or the attorney work product doctrine and exempt under RSA 91-A:5, XII. The court also found that the remaining records, including the settlement agreement, were exempt as confidential or personnel files under RSA 91-A:5, IV. The court denied the newspaper’s request for attorney’s fees and costs, concluding the district had satisfied its obligations regarding records of payments to the employee.The Supreme Court of New Hampshire held that in camera review without counsel present is permissible when disclosure may cause an invasion of privacy. It affirmed that records protected by attorney-client privilege or the attorney work product doctrine are exempt from disclosure without a balancing test. However, it found the lower court erred in applying the exemption for confidential and personnel files, holding that the public interest in disclosure outweighed privacy concerns if identifying information was redacted. The court also held that the district must disclose unaltered records of payments made to the employee and awarded attorney’s fees and costs for that violation. The case was affirmed in part, reversed in part, and remanded. View "Keene Publ'g Corp. v. Fall Mountain Reg'l Sch. Dist." on Justia Law