Justia Labor & Employment Law Opinion Summaries

Plaintiff-appellant Kimberly A. Ripoli, a decorated veteran, claimed she experienced gender-based discrimination when terminated from her role as Associate Director of the Rhode Island Office of Veterans Affairs (OVA). She sued the State of Rhode Island, Department of Human Services, Office of Veterans Affairs under Title VII of the Civil Rights Act of 1964 and various Rhode Island statutes. The district court granted summary judgment in favor of the State on all claims.The United States District Court for the District of Rhode Island granted summary judgment for the State, dismissing Ripoli's claims of gender-based discrimination, retaliation, and hostile work environment. Ripoli did not address the district court's adverse rulings on her retaliation or hostile work environment claims in her appeal, leaving those rulings intact.The United States Court of Appeals for the First Circuit reviewed the case. The court vacated the district court's order on Ripoli's disparate treatment claims, finding that she had established a prima facie case of discrimination and raised genuine issues of material fact regarding whether the State's reasons for her termination were pretextual. The court noted that Ripoli presented evidence suggesting her role was not redundant, that the reorganization was not driven by budgetary constraints, and that she was replaced by a less-qualified heterosexual male. The court affirmed the district court's summary judgment on Ripoli's retaliation and hostile work environment claims, as she did not pursue these on appeal. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Ripoli v. Rhode Island Department of Human Services" on Justia Law

ArrMaz Products, Inc. (ArrMaz), a specialty chemical manufacturer, and the International Chemical Workers Union Council of the United Food and Commercial Workers Union (the Union) entered into a stipulated election agreement to determine if the Union would represent ArrMaz’s employees. During the election, the Union challenged two ballots from employees of AMP Trucking, Inc. (AMP), a wholly owned subsidiary of ArrMaz. The challenged ballots were not counted, and the Union won the election by a 20 to 18 vote. The National Labor Relations Board (the Board) sustained the Union’s challenge, certifying the Union as the bargaining representative of ArrMaz’s employees, finding that only ArrMaz’s employees were eligible to vote under the agreement.ArrMaz refused to bargain with the Union, leading to a second Board order mandating that ArrMaz engage in bargaining. The Board severed the issue of whether to require ArrMaz to compensate employees for the lost opportunity to bargain during the post-election proceedings for further consideration. The Board then applied for enforcement of its orders, and ArrMaz cross-petitioned for review.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that it had jurisdiction to review the Board’s orders, as the Board had completed its decision-making process regarding the Union’s certification and ArrMaz’s duty to bargain. On the merits, the court agreed with the Board that the stipulated election agreement unambiguously provided that only ArrMaz employees were eligible to vote, thus excluding AMP employees. Consequently, the Board properly sustained the Union’s challenge. The court granted the Board’s application for enforcement and denied ArrMaz’s petition for review. View "National Labor Relations Board v. Arrmaz Products Inc." on Justia Law

Sarah Lindsley filed a discrimination lawsuit against her employer, Omni Hotels Management Corporation, alleging sex-based pay discrimination under the Equal Pay Act (EPA) and Title VII of the Civil Rights Act of 1964. Lindsley claimed that her initial salary was set too low due to her sex, causing her to earn less than her male colleagues despite subsequent raises. She also alleged that she faced harassment and that her complaints about pay discrepancies were ignored.The United States District Court for the Northern District of Texas initially granted summary judgment in favor of Omni on all claims. However, the United States Court of Appeals for the Fifth Circuit reversed and remanded the case for trial on the pay-discrimination claims under Title VII and the EPA. At trial, the jury found Omni not liable under the EPA but awarded Lindsley over $25 million in Title VII damages despite finding no liability under Title VII. The district court deemed the jury's answers inconsistent, amended the verdict form, and ordered further deliberation. The jury then found for Lindsley on her Title VII claim, again awarding over $25 million in damages, which the district court reduced under the statutory cap.The United States Court of Appeals for the Fifth Circuit reviewed the case and held that the district court did not err in handling the first verdict form but did err in handling the second verdict form. The appellate court found that the jury's answers in the second verdict form were inconsistent, as they found that any pay disparity resulted from a factor other than sex (an affirmative defense to both the EPA and Title VII claims) but still awarded Title VII damages. The court vacated the district court's judgment and remanded the case for a new trial. View "Lindsley v. Omni Hotels" on Justia Law

Randell Shepherd, a career coal miner, filed a claim for benefits under the Black Lung Benefits Act (BLBA), invoking the Act’s presumption that he was entitled to benefits due to his over fifteen years of mining and total disability from chronic obstructive pulmonary disease (COPD), bronchitis, and emphysema. Incoal, Inc., Shepherd’s most recent employer, contested his entitlement, arguing that his disability was caused by smoking, not mining. An administrative law judge (ALJ) found Incoal’s expert opinions unpersuasive and inconsistent with the Act’s regulations and preamble, which recognize pneumoconiosis as a latent and progressive disease. The ALJ ruled that Incoal failed to rebut the presumption that Shepherd was entitled to benefits. The Benefits Review Board (BRB) affirmed the ALJ’s decision.Incoal petitioned the United States Court of Appeals for the Sixth Circuit for review, arguing that the ALJ improperly relied on the regulatory preamble over their evidence and that the presumption was effectively irrebuttable, violating the Constitution and the Administrative Procedure Act (APA). The court reviewed the case de novo, focusing on whether the ALJ’s decision was supported by substantial evidence and correctly applied the law.The Sixth Circuit held that the ALJ was entitled to reference the preamble to assess the credibility of expert opinions and found that the ALJ’s decision was supported by substantial evidence. The court noted that the BLBA’s rebuttable presumption is constitutional, as it is based on a rational relationship between the length of a miner’s career and the risk of pneumoconiosis. The court concluded that Incoal’s arguments were unpersuasive and that the ALJ applied the correct legal principles. Consequently, the court denied Incoal’s petition for review. View "Incoal, Inc. v. OWCP" on Justia Law

Ariel Torres, a former Starbucks employee, and Raphyr Lubin, the husband of another former Starbucks employee, filed a putative class action against Starbucks. They alleged that Starbucks sent them deficient health-insurance notices under the Employee Retirement Income Security Act (ERISA), as amended by the Consolidated Omnibus Budget Reconciliation Act (COBRA). Starbucks moved to compel arbitration based on employment agreements signed by Torres and Lubin’s wife. Torres agreed to arbitration, but Lubin opposed it, arguing he was not a party to his wife’s employment agreement.The United States District Court for the Middle District of Florida denied Starbucks’s motion to compel arbitration for Lubin. The court found that Lubin was not a party to his wife’s employment agreement and was not suing to enforce it. Instead, Lubin sought to enforce his own statutory right to an adequate COBRA notice. The court held that no equitable doctrine of Florida contract law required Lubin to arbitrate and that Starbucks waived its argument that Lubin’s rights were derivative of his wife’s rights.The United States Court of Appeals for the Eleventh Circuit reviewed the case and affirmed the district court’s decision. The court held that Lubin, not being a party to the arbitration agreement, could not be compelled to arbitrate. The court also found that the arbitration agreement’s delegation clause did not apply to Lubin, as he was not a party to the agreement. Additionally, the court rejected Starbucks’s arguments based on equitable estoppel, third-party beneficiary doctrine, and the derivative claim theory, concluding that none of these principles required Lubin to arbitrate his claim. The court affirmed the district court’s order denying Starbucks’s motion to compel arbitration. View "Lubin v. Starbucks Corporation" on Justia Law

Harold Winston, an African-American male with over 30 years of service, sued his employer, the County of Los Angeles, alleging race-based discrimination, retaliation, and failure to maintain a discrimination-free environment under the California Fair Employment and Housing Act (FEHA) and whistleblower retaliation in violation of Labor Code section 1102.5. While the case was pending, section 1102.5 was amended to allow courts to award reasonable attorney fees to prevailing whistleblower plaintiffs. After the jury found in Winston’s favor on his retaliation claim under section 1102.5, he filed a motion for attorney fees based on the new provision.The Superior Court of Los Angeles County denied Winston’s motion for attorney fees, ruling that the fee provision did not apply retroactively to his case, which was filed in 2019 before the amendment took effect. The court found no legislative intent supporting retroactive application and noted that Winston did not prevail on his FEHA claims, which could have provided a basis for attorney fees.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case. The court held that a new statute authorizing an award of attorney fees applies to actions pending on the statute’s effective date. The court cited case precedent establishing that newly enacted attorney fee provisions are procedural and apply to pending litigation. The court reversed the trial court’s decision and remanded the case with directions for the trial court to determine the appropriateness and reasonableness of Winston’s fee request. The judgment was reversed, and the case was remanded for further proceedings. View "Winston v. County of Los Angeles" on Justia Law

Celestia Chapman, a finance manager at Brentlinger Enterprises, requested leave under the Family and Medical Leave Act (FMLA) to care for her terminally ill sister. Her employer denied the request, stating that the FMLA did not cover leave to care for an adult sibling. When Chapman did not show up for work on a scheduled day, she was terminated. Subsequently, Brentlinger Enterprises falsely informed workers' compensation authorities that Chapman had quit and threatened her with Rule 11 sanctions if she pursued an FMLA lawsuit. Chapman sued, alleging violations of the FMLA, the Americans with Disabilities Act (ADA), and other statutes.The United States District Court for the Southern District of Ohio granted summary judgment to Brentlinger Enterprises on all claims except for the COBRA violation, for which it imposed a statutory penalty. Both parties appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court reversed the district court's grant of summary judgment on Chapman's FMLA interference claim, finding that an in loco parentis relationship could form between adults, including siblings, under the FMLA. The court also reversed the summary judgment on Chapman's FMLA retaliation claims related to her termination and the false statements made to the unemployment agency, as well as her ADA and Ohio law associational disability discrimination claims. The court affirmed the summary judgment on the FMLA retaliation claim related to the Rule 11 sanctions letter and upheld the district court's award of $85 per day in statutory penalties for the COBRA violation. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Chapman v. Brentlinger Enterprises" on Justia Law

Martin B. Sturdivant, an employee of the North Carolina Department of Public Safety, sustained a back injury while working as a corrections officer. The injury led to chronic back pain, and Sturdivant received temporary total disability payments through the workers' compensation system. As he approached the 500-week limit for these payments, he applied for extended compensation, claiming a total loss of wage-earning capacity.The North Carolina Industrial Commission denied Sturdivant's claim, concluding that he had not sustained a total loss of wage-earning capacity. The Commission interpreted this phrase to mean a total loss of the ability to earn wages in any employment. Sturdivant appealed to the North Carolina Court of Appeals, which rejected the Commission's interpretation. The Court of Appeals held that "total loss of wage-earning capacity" was synonymous with "total disability," incorporating a broader legal test.The Supreme Court of North Carolina reviewed the case and held that the phrase "total loss of wage-earning capacity" means the complete elimination of the capacity to earn any wages. The Court clarified that this phrase does not share the same legal meaning as "total disability." The Court found that the Industrial Commission's interpretation was correct and that the Commission's findings were supported by competent evidence. The Supreme Court modified the Court of Appeals' opinion to reject its statutory interpretation but otherwise affirmed the decision. View "Sturdivant v. Department of Public Safety" on Justia Law

Acumen Capital Partners, LLC, a commercial property management company, discharged engineer Gregory Zapata, allegedly due to his failure to comply with a COVID-19 vaccination mandate. Zapata had been involved in union activities, including signing union authorization cards and discussing unionization with colleagues. Acumen's chief engineer, Salvatore Coppola, who was aware of Zapata's union activities, had informed Zapata that the company's owner, Jeffrey Rosenblum, did not want a union in the building.The National Labor Relations Board (NLRB) found that Acumen discharged Zapata because of his protected union activities, violating Section 8(a)(1) and (3) of the National Labor Relations Act. The Administrative Law Judge (ALJ) credited the testimonies of Zapata and another engineer, Gabriel Garcia, while discrediting Rosenblum's testimony. The ALJ concluded that Acumen's stated reason for discharging Zapata—non-compliance with the vaccination mandate—was pretextual, as the company had not enforced the mandate consistently and had not excluded other unvaccinated employees from the workplace.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found substantial evidence supporting the NLRB's findings that Acumen had knowledge of Zapata's union activities and that anti-union animus was a motivating factor in his discharge. The court noted the timing of the discharge, the pretextual nature of Acumen's explanation, and the disproportionate response to Zapata's unvaccinated status. The court denied Acumen's petition for review and granted the NLRB's cross-application for enforcement of its decision and order, which included reinstating Zapata with backpay. View "Acumen Capital Partners, LLC v. National Labor Relations Board" on Justia Law

A police officer in Buffalo, Texas, was terminated by the City Council after engaging in a high-speed chase with a civilian in his patrol vehicle, resulting in an accident. The officer, Gregory Moliere, received a written reprimand from the Chief of Police, which he accepted. Subsequently, the City Council voted to terminate his employment. Moliere sued, claiming the City Council lacked the authority to fire him and that his due process rights were violated.The trial court dismissed Moliere's suit, finding that the City Council had the authority to terminate him. Moliere appealed, and the Court of Appeals for the Tenth District of Texas reversed the trial court's decision, concluding that there was a fact issue regarding the City Council's authority to terminate Moliere. The appellate court noted ambiguities in the City's employee manual and the police department's policy-and-procedure manual and remanded the case for further proceedings without addressing Moliere's due process claim.The Supreme Court of Texas reviewed the case and determined that the City Council had the authority to terminate Moliere under Texas Local Government Code Section 341.001, which allows the governing body of a Type A general-law municipality to establish and regulate a municipal police force. The court held that the City Council's authority to regulate the police force included the power to terminate officers for cause. Consequently, the Supreme Court of Texas reversed the Court of Appeals' judgment and reinstated the trial court's judgment dismissing Moliere's claims based on the alleged lack of authority to fire him.However, the Supreme Court of Texas remanded the case to the Court of Appeals to address Moliere's due process claim, which had not been considered previously. View "City of Buffalo v. Moliere" on Justia Law