Justia Labor & Employment Law Opinion Summaries

J.H. participated in an employee welfare-benefit plan insured by Anthem Blue Cross Life and Health Insurance Company, with her son, A.H., as a beneficiary. After seeking benefits for A.H.'s yearlong stay at a mental-health treatment center, Anthem denied coverage, and Plaintiffs' appeal to Anthem was unsuccessful. Over a year after their final appeal through Anthem was decided, Plaintiffs filed a lawsuit to recover benefits under § 502(a)(1)(B) of the Employee Retirement Income Security Act of 1974 (ERISA).The United States District Court for the District of Utah dismissed the action, concluding it was time-barred under a provision of the Plan that required civil actions under ERISA § 502(a) to be brought within one year of the grievance or appeal decision. Plaintiffs argued that another sentence in the Plan set a three-year limitations period, creating an ambiguity that should be interpreted in their favor.The United States Court of Appeals for the Tenth Circuit reviewed the case and held that the two provisions were not inconsistent and both applied. The court explained that the one-year limitations period for § 502(a) actions and the three-year limitations period for other actions were distinct and could both be applicable. The court affirmed the district court's dismissal, concluding that Plaintiffs' action was time-barred as it was filed beyond the one-year limitations period specified in the Plan. View "J.H. v. Anthem Blue Cross Life and Health Insurance" on Justia Law

The plaintiffs, La Kimba Bradsbery and Cheri Brakensiek, sued their former employer, Vicar Operating, Inc., alleging that Vicar failed to provide the required meal periods as mandated by California Labor Code section 512 and IWC Wage Orders Nos. 4 and 5. The plaintiffs had signed a written agreement waiving their right to a meal period for shifts between five and six hours, which they could revoke at any time. They argued that these prospective waivers allowed Vicar to circumvent statutory meal break requirements.The Superior Court of Los Angeles County granted summary adjudication in favor of Vicar, determining that the prospective meal period waivers were valid under section 512 and the wage orders. The court found that the waivers were enforceable as they were revocable and there was no evidence of coercion or unconscionability. The plaintiffs appealed the decision.The California Court of Appeal, Second Appellate District, reviewed the case and affirmed the lower court's decision. The appellate court held that the prospective written waivers of meal periods for shifts between five and six hours were consistent with the text and purpose of section 512 and Wage Orders Nos. 4 and 5. The court found that the legislative and administrative history supported the validity of such waivers, noting that the IWC had long viewed prospective written waivers as protective of both employees and employers. The court also concluded that the case of Brinker Restaurant Corp. v. Superior Court did not require a contrary result, as it did not address the timing or form of meal period waivers. View "Bradsbery v. Vicar Operating, Inc." on Justia Law

In August 2021, the Cook County Health and Hospitals System implemented a policy requiring all personnel to be fully vaccinated against infectious diseases, including COVID-19. Exemptions were allowed for disability, medical conditions, or sincerely held religious beliefs. Plaintiffs, who are healthcare employees or contractors, requested religious exemptions, which were granted. However, the accommodation provided was a transfer to unpaid status pending termination, with a limited time to find a non-existent remote position. Plaintiffs argued this was religious discrimination violating the Free Exercise Clause of the First Amendment.The United States District Court for the Northern District of Illinois previously denied plaintiffs' motions for preliminary injunctions against the vaccine mandates, including Cook County’s. The Seventh Circuit affirmed this denial, rejecting the plaintiffs' facial challenge to the mandate. On remand, plaintiffs amended their complaint but were denied permission to add a claim under the Illinois Religious Freedom Restoration Act until after the court ruled on the County’s motion to dismiss. The district court dismissed the second amended complaint, considering it a facial challenge, which had already been ruled upon.The United States Court of Appeals for the Seventh Circuit reviewed the case and held that the plaintiffs waived their as-applied challenge by not raising it in the district court or their opening brief on appeal. The court also noted that plaintiffs conceded they no longer sought injunctive relief and did not pursue a facial challenge. Consequently, the court affirmed the district court’s dismissal of the constitutional claim. Additionally, the court found no abuse of discretion in the district court’s denial of leave to amend the complaint to include the Illinois RFRA claim. The court criticized the plaintiffs' counsel for poor advocacy and procedural errors. View "Lukaszczyk v Cook County" on Justia Law

Saul Arellano, a roofer, was injured while working on a construction project for Sunrise Homes, Inc. He fell from a roof without fall protection equipment and sustained multiple injuries. Arellano received worker’s compensation benefits through Sunrise Homes after it was discovered that his direct employer did not carry worker’s compensation insurance. Subsequently, Arellano filed negligence and negligence per se claims against Sunrise Homes, arguing that his injuries fell under the “unprovoked physical aggression” exception to Idaho’s worker’s compensation exclusive remedy rule.The District Court of the Seventh Judicial District, Madison County, granted summary judgment in favor of Sunrise Homes. The court concluded that Arellano failed to provide clear and convincing evidence that his claims fell within the statutory exception to the exclusive remedy rule. Specifically, the court found no genuine issues of material fact that Sunrise Homes knew injury or death was substantially likely to occur due to the lack of fall protection equipment.The Supreme Court of the State of Idaho reviewed the case and affirmed the district court’s decision. The Supreme Court held that the district court erred in applying the “clear and convincing” evidentiary standard at the summary judgment stage. However, upon de novo review, the Supreme Court found that Arellano did not raise a genuine issue of material fact regarding Sunrise Homes’ knowledge that injury was substantially likely to occur. The court also rejected Arellano’s arguments that the 2020 amendments to Idaho Code section 72-209(3) codified a more lenient standard or reduced the burden of proof for plaintiffs. Consequently, the Supreme Court affirmed the district court’s order granting summary judgment to Sunrise Homes and awarded costs on appeal to Sunrise Homes. View "Arellano v. Sunrise Homes, Inc." on Justia Law

James Napier, the Director of the Middle School at the Orchard School, was not renewed for his contract in 2019 following orders from the new Head of School, Dr. Sherri Helvie. Napier, believing his termination was due to his sex, filed an employment discrimination suit against Orchard. After being rejected when he reapplied for his position, he added a retaliation claim to his lawsuit.The United States District Court for the Southern District of Indiana granted summary judgment in favor of Orchard on both claims. The court concluded that Napier had not presented sufficient evidence to establish a prima facie case of discrimination or retaliation. Specifically, the court found that Napier failed to show that his sex was the reason for his termination and that there was no connection between his protected activity and the rejection of his reapplication.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 Napier did not provide sufficient evidence to demonstrate that Helvie's reason for terminating him—breaching her trust—was pretextual. The court noted that Helvie's explanation for the termination was consistent and credible. Additionally, the court found that Napier's retaliation claim failed because there was no evidence that his litigation was the but-for cause of Orchard's decision not to rehire him. The court concluded that the decision was based on Napier's past performance issues and the fractured relationship with Helvie. View "Napier v Orchard School Foundation" on Justia Law

Alisha Strife, a former U.S. Army service member with disabilities, requested that her employer, Aldine Independent School District (AISD), allow her service dog to accompany her at work. Strife's disabilities include PTSD and physical impairments, and her service dog, Inde, assists her with these conditions. Strife submitted her accommodation request on August 30, 2022, but AISD took six months to approve it, during which time Strife provided multiple medical documents supporting her need for the service dog.The United States District Court for the Southern District of Texas dismissed Strife's claims for failure to accommodate and hostile work environment. The court also granted AISD's motion for summary judgment on Strife's claims of disability discrimination, retaliation, and interference. The district court found that Strife did not suffer a physical injury during the six-month period and that she failed to allege a hostile work environment. The court also concluded that AISD had legitimate reasons for its actions and that Strife did not demonstrate that AISD's rationale was pretextual.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's dismissal of the hostile work environment claim, agreeing that Strife's allegations did not meet the standard for a hostile work environment. The court also affirmed the summary judgment on the disability discrimination, retaliation, and interference claims, finding that AISD had legitimate reasons for its actions and that Strife did not provide sufficient evidence of pretext.However, the Fifth Circuit reversed the dismissal of Strife's failure-to-accommodate claim. The court found that Strife had pled sufficient facts to suggest that AISD's six-month delay in granting her accommodation request could constitute a failure to accommodate her disability. The case was remanded to the district court for further proceedings on this claim. View "Strife v. Aldine Independent School District" on Justia Law

Pamela McKenzie was shopping at a Walgreens in Houston in 2019 when she was detained on suspicion of shoplifting. A Walgreens employee called the police, suspecting McKenzie was the same person who had stolen from the store earlier that day. After reviewing surveillance footage, the police determined McKenzie was not the thief and released her. McKenzie claimed that other Walgreens employees had agreed she was not the thief, but the employee called the police anyway. She sued Walgreens for intentional infliction of emotional distress, negligence, gross negligence, respondeat superior liability for employee negligence, and negligent hiring, training, and supervision (NHTS).The trial court denied Walgreens' motion to dismiss under the Texas Citizens Participation Act (TCPA), which allows for early dismissal of legal actions based on the exercise of free speech. A divided Court of Appeals for the Fourteenth District of Texas affirmed in part and reversed in part. The court held that the trial court erred by not dismissing McKenzie’s claims of intentional infliction of emotional distress, negligence, gross negligence, and vicarious liability for employee negligence. However, it held that the NHTS claim was not subject to dismissal under the TCPA because it was not entirely based on the employee’s exercise of free speech rights.The Supreme Court of Texas reviewed the case and held that the TCPA does apply to McKenzie’s NHTS claim. The court concluded that McKenzie failed to meet her evidentiary burden to avoid dismissal, as she did not provide clear and specific evidence for each essential element of her NHTS claim. Consequently, the court reversed the Court of Appeals' judgment in part and remanded the case to the trial court for further proceedings, specifically for the dismissal of McKenzie’s NHTS claim. The remainder of the Court of Appeals' judgment was left undisturbed. View "WALGREENS v. MCKENZIE" on Justia Law

A former high school tennis coach was accused of inappropriate touching and harassment by students. The school district investigated and found no inappropriate touching or bullying but recommended the coach avoid touching players. After the investigation, the coach posted on social media, which was perceived as targeting former players. At a public school board meeting, two students expressed dissatisfaction with the investigation. The school district posted an unaltered video of the meeting online, placed the coach on paid administrative leave, and did not renew her contract. The coach requested the video be altered or removed, but the district refused.The coach filed claims of defamation and wrongful termination in violation of public policy against the school district. The Iowa District Court for Johnson County granted summary judgment in favor of the school district, finding the republication of the statements was protected by the fair-report privilege and that the coach failed to demonstrate a well-established public policy. The Iowa Court of Appeals affirmed the district court's decision.The Iowa Supreme Court reviewed the case and affirmed the decisions of the lower courts. The court held that the fair-report privilege protected the school district's republication of the students' statements made at the public meeting, as the video was an accurate and complete report of an official proceeding. The court also found that the coach did not identify a clearly defined and well-recognized public policy that was violated by her termination. Thus, the defamation and wrongful termination claims were dismissed. View "Villarini v. Iowa City Community School District" on Justia Law

Lisa Barnhill, a white woman, sued the U.S. Attorney General, alleging racial and gender discrimination, retaliation, and a hostile work environment under Title VII of the Civil Rights Act of 1964. Barnhill claimed she faced discrimination from her African American supervisor and others while employed by the DEA. Some of her claims were dismissed under Fed. R. Civ. P. 12(b)(6), and others were resolved on summary judgment under Fed. R. Civ. P. 56(a).The United States District Court for the Eastern District of Virginia dismissed Barnhill's race and gender discrimination claims, finding she failed to allege facts showing discriminatory animus. The court also dismissed her retaliation claims related to promotion denials and a five-day suspension, concluding she did not plausibly allege a connection between her EEO proceeding and these adverse actions. However, the court allowed her retaliation claims related to a management review and temporary duty reassignment, as well as her hostile work environment claim, to proceed.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court affirmed the dismissal of Barnhill's discrimination claims, agreeing she did not plausibly allege discriminatory animus. The court also affirmed the dismissal of her retaliation claims related to promotion denials and the suspension, finding no causal connection to her EEO proceeding. On summary judgment, the court found that the management review was initiated by a supervisor without discriminatory animus and that the temporary duty reassignment was justified by legitimate, nonretaliatory reasons. The court also concluded that Barnhill's hostile work environment claim failed because the adverse actions she experienced were responses to her own behavior, not severe or pervasive harassment.The Fourth Circuit affirmed the district court's decision, holding that Barnhill failed to establish the necessary elements for her claims. View "Barnhill v. Bondi" on Justia Law

Tracy Turner, a railway conductor employed by BNSF Railway for fifteen years, failed two vision tests required by federal law in 2020. The first test was the Ishihara 14-plate clinical vision test, which Turner failed due to a color deficiency affecting his perception of red and green. At his request, Turner was given a second vision field test by BNSF’s medical examiner, which he also failed. Consequently, BNSF did not recertify Turner as a conductor, as required by federal regulations.Turner did not appeal the denial of his recertification through the Federal Railway Administration (FRA) administrative review process. Instead, he filed a disability-discrimination charge with the Equal Employment Opportunity Commission (EEOC), which provided him with a right-to-sue letter. Turner then sued BNSF, claiming that the company violated the Americans with Disabilities Act (ADA) by not recertifying him due to his color deficiency. BNSF moved for judgment on the pleadings, and the United States District Court for the Northern District of Texas granted the motion, ruling that Turner was not a "qualified individual" under the ADA and that his claim was precluded.The United States Court of Appeals for the Fifth Circuit reviewed the district court’s judgment de novo. The court affirmed the district court’s decision, holding that Turner was not a "qualified individual" under the ADA because he failed to obtain the FRA-required certification and did not exhaust the available administrative remedies. The court emphasized that BNSF was bound by federal law and FRA regulations, which mandated the vision tests and certification process. Turner’s failure to pursue the FRA’s appeals process meant he could not establish an essential element of his ADA claim. View "Turner v. BNSF Railway" on Justia Law