Justia Labor & Employment Law Opinion Summaries

Employees of Smith International, Inc. filed a claim for unpaid overtime wages under the Fair Labor Standards Act (FLSA). The employees, known as reamers, supervised the use of Smith’s underreaming tool on offshore drilling rigs. They were paid an annual salary plus daily-rate job bonuses, with their total annual compensation exceeding $100,000. The employees argued that they were misclassified as exempt from overtime requirements and sought to recover unpaid overtime wages, liquidated damages, and attorney fees.The United States District Court for the Western District of Louisiana conditionally certified the action as a collective action. Later, the claims of some plaintiffs were severed into separate individual actions, while others continued as a collective action. The district court consolidated the five proceedings for all purposes except for trial. After discovery, both parties filed cross motions for summary judgment. The district court granted Smith’s motion for summary judgment, finding that the employees were exempt from the FLSA’s overtime pay guarantee as bona fide executives. The employees appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that each employee met the criteria for the bona fide executive exemption under the FLSA. Specifically, the employees satisfied the salary basis test, the salary level test, and the job duties test. The court found that the employees were paid a guaranteed annual salary, which was not subject to reduction based on the quality or quantity of work performed, and that the additional daily-rate compensation did not defeat their qualification for the exemption. The court affirmed the district court’s grant of summary judgment in favor of Smith International, Inc. View "Venable v. Smith International" on Justia Law

Tonya Anderson was terminated from her position at Diamondback Investment Group, LLC after failing two drug tests. She filed a lawsuit against Diamondback, alleging disability discrimination under the Americans with Disabilities Act (ADA) and a violation of North Carolina law that prohibits discrimination against employees for using lawful hemp-derived products containing THC during nonworking hours.The United States District Court for the Middle District of North Carolina granted summary judgment in favor of Diamondback on all claims. The court found that Anderson failed to provide sufficient evidence to establish that she was disabled under the ADA. Even if she had, the court concluded that Diamondback had a legitimate, nondiscriminatory reason for her termination—failing drug tests. The court also found that Anderson did not request a reasonable accommodation for her alleged disability. Regarding the state law claim, the court determined that Diamondback’s drug policy was a bona fide occupational requirement reasonably related to its employment activities, thus falling under an exception to the state law.The United States Court of Appeals for the Fourth Circuit affirmed the district court’s decision. The appellate court agreed that Anderson did not provide adequate evidence to show she was disabled under the ADA or that she requested an accommodation. The court also upheld the district court’s finding that Diamondback’s drug policy was a bona fide occupational requirement reasonably related to its employment activities, which justified the restriction on Anderson’s use of hemp-derived products. Therefore, the court affirmed the summary judgment in favor of Diamondback on all claims. View "Anderson v. Diamondback Investment Group, LLC" on Justia Law

Andrew Morgan, a millwright laborer, was employed by Allison Crane & Rigging LLC until his termination on November 18, 2020. Morgan injured his lower back on September 29, 2020, and was diagnosed with a bulged or herniated disc by a chiropractor. He was placed on light duty and given restrictions on bending and lifting. Despite these accommodations, Morgan was terminated, allegedly for failing to follow company policies and not showing up for work on November 17, 2020. Morgan filed a lawsuit claiming disability-based discrimination, retaliation, and failure to accommodate under the ADA and PHRA, as well as wrongful discharge under Pennsylvania common law.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of Allison Crane. The court held that Morgan did not establish an actual or perceived disability under the ADA and PHRA, as his testimony about the chiropractor's diagnosis was inadmissible hearsay and he failed to provide necessary medical evidence. The court also found that Morgan's back pain was transitory and minor, thus not qualifying as a disability. Additionally, the court dismissed Morgan's wrongful discharge claim for lack of prima facie evidence of protected activity.The United States Court of Appeals for the Third Circuit reviewed the case and found that the District Court applied an incorrect legal standard. The Third Circuit clarified that under the ADA Amendments Act of 2008, temporary impairments can qualify as disabilities if they substantially limit major life activities. The court reversed the District Court's dismissal of Morgan's back pain-based discrimination claims, vacated the dismissal of his retaliation and failure to accommodate claims, and affirmed the dismissal of his wrongful discharge claim. The case was remanded for further proceedings consistent with the Third Circuit's opinion. View "Morgan v. Allison Crane & Rigging LLC" on Justia Law

In 2018, North American Senior Benefits, LLC (NASB) entered into employment contracts with Ryan and Alisha Wimmer, which included a restrictive covenant prohibiting them from recruiting NASB employees for two years post-termination. In 2021, after the Wimmers left NASB and allegedly started a competing business, NASB sued to enforce the covenant. The Wimmers argued that the covenant was unenforceable due to the lack of an express geographic term.The Statewide Business Court agreed with the Wimmers and granted their motion for judgment on the pleadings, finding the covenant unenforceable without an express geographic term. The Court of Appeals affirmed this decision, relying on its prior ruling in CarpetCare Multiservices v. Carle, which held that a restrictive covenant must include an express geographic term to comply with OCGA § 13-8-53 (a). One judge dissented, arguing that the GRCA does not require an express geographic term for non-recruitment provisions.The Supreme Court of Georgia reviewed the case and concluded that the Court of Appeals erred. The Supreme Court held that OCGA § 13-8-53 (a) does not mandate an express geographic term for a restrictive covenant to be enforceable. Instead, the statute requires that the restrictions be reasonable in time, geographic area, and scope of prohibited activities. The Court emphasized that the reasonableness of a covenant's geographic scope should be assessed based on the totality of the circumstances, not solely on the presence of an express geographic term.The Supreme Court reversed the judgment of the Court of Appeals and remanded the case for further proceedings to determine the reasonableness of the non-recruitment provision under the GRCA. View "NORTH AMERICAN SENIOR BENEFITS, LLC v. WIMMER" on Justia Law

American Building Innovation LP (ABI) was hired by Balfour Beatty Construction, LLC (Balfour Beatty) as a subcontractor for a school construction project. ABI had a workers’ compensation insurance policy when it began work, but the policy was canceled due to ABI’s refusal to pay outstanding premiums from a previous policy. This cancellation led to the automatic suspension of ABI’s contractor’s license. Despite knowing it was unlicensed and uninsured, ABI continued working on the project.The Superior Court of Orange County found that ABI was not duly licensed at all times during the performance of its work, as required by California law. ABI’s license was suspended because it failed to maintain workers’ compensation insurance. ABI later settled its premium dispute and had the policy retroactively reinstated, but the court found this retroactive reinstatement meaningless because it occurred long after the statute of limitations for any workers’ compensation claims had expired. The court ruled that ABI could not maintain its action to recover compensation for its work due to its lack of proper licensure.The California Court of Appeal, Fourth Appellate District, Division Three, affirmed the lower court’s judgment. The court held that ABI was not entitled to retroactive reinstatement of its license because the failure to maintain workers’ compensation insurance was not due to circumstances beyond ABI’s control. ABI’s decision not to pay the premiums and its false representations to the Contractors’ State License Board were within its control. Consequently, ABI was barred from bringing or maintaining the action under section 7031 of the Business and Professions Code. The court also affirmed the award of attorney fees to Balfour Beatty under the subcontract’s prevailing party attorney fee provision. View "American Building Innovations v. Balfour Beatty Construction" on Justia Law

A group of Union Pacific Railroad Company employees filed a class action lawsuit against the company, alleging that its fitness-for-duty program violated the Americans with Disabilities Act (ADA). Todd DeGeer, believing he was part of this class, filed an Equal Employment Opportunity Commission (EEOC) charge and an individual lawsuit after the class was decertified. DeGeer argued that his claims were tolled under the American Pipe & Construction Co. v. Utah doctrine. The district court dismissed his claims as untimely, finding that DeGeer was not a member of the narrowly defined class.The United States District Court for the District of Nebraska initially certified a class that included Union Pacific employees subjected to fitness-for-duty evaluations due to a reportable health event. DeGeer was on a list of employees provided by Union Pacific and submitted a declaration supporting the plaintiffs' certification motion. However, the class definition was later narrowed, and the district court certified the class under this new definition. The Eighth Circuit Court of Appeals later reversed the class certification, leading DeGeer to file his individual claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court's decision. The Eighth Circuit held that DeGeer was entitled to American Pipe tolling because the revised class definition did not unambiguously exclude him. The court emphasized that ambiguities in class definitions should be resolved in favor of applying tolling. Consequently, DeGeer's claims were tolled during the pendency of the class action, making his individual lawsuit timely. The case was remanded for further proceedings. View "DeGeer v. Union Pacific Railroad Co." on Justia Law

Four former Tesla employees, Sharonda Taylor, Shaka Green, Tatianna Smith, and Zenobia Milligan, requested personnel records from Tesla under the California Labor Code. These individuals are also part of a class action lawsuit, Vaughn v. Tesla, which alleges racial discrimination and harassment at Tesla's Fremont plant. Despite the requests, Tesla did not provide the requested records, citing a stay in the Vaughn case due to an ongoing appeal. The plaintiffs then filed a Private Attorneys General Act (PAGA) action against Tesla for failing to comply with the Labor Code.The Superior Court of California, County of Alameda, denied Tesla's anti-SLAPP motion, which argued that the PAGA claims arose from protected petitioning activity related to the Vaughn case. The court found that the plaintiffs' requests for personnel records were independent of the Vaughn litigation and were merely an exercise of their statutory rights under the Labor Code.The California Court of Appeal, First Appellate District, Division Four, affirmed the lower court's decision. The appellate court held that Tesla's refusal to provide the requested records did not constitute protected activity under the anti-SLAPP statute. The court distinguished this case from Crossroads Investors, L.P. v. Federal National Mortgage Assn., noting that the plaintiffs' PAGA claims did not rely on any "written or oral statement or writing" by Tesla. The court also found that Tesla's conduct did not meet the criteria for protection under the anti-SLAPP statute's "catchall" provision, as it did not contribute to any public issue or debate. Consequently, the court affirmed the denial of Tesla's anti-SLAPP motion. View "Taylor v. Tesla, Inc." on Justia Law

The case involves a long-standing employment discrimination dispute between a well-known columnist, T.J. Simers, and his former employer, Los Angeles Times Communications LLC. Simers was demoted in 2013 and subsequently filed a lawsuit alleging constructive termination and age and disability discrimination under the Fair Employment and Housing Act (FEHA). The litigation spanned nine years and included three jury trials. The first trial resulted in a mixed verdict, with the jury awarding significant economic and noneconomic damages. However, the trial court granted the defendant's motion for judgment notwithstanding the verdict (JNOV) on the constructive termination claim and ordered a new trial on noneconomic damages. Both parties appealed, and the appellate court affirmed the trial court's orders, necessitating a second trial.In the second trial, the jury awarded Simers $15.4 million in noneconomic damages, but the trial court granted a new trial due to misconduct by Simers's counsel during closing arguments and the excessive nature of the damages awarded. The third trial focused solely on the amount of noneconomic damages, resulting in a $1.25 million award, which matched a pre-trial settlement offer made by the defendant.The Superior Court of Los Angeles County awarded Simers $3,264,906 in attorney fees and $210,882.55 in costs, but excluded fees and costs incurred after the defendant's settlement offer. The defendant appealed, arguing that fees for the second trial and the unsuccessful appeal should not be awarded due to counsel's misconduct and the unrelated nature of the work. The plaintiff cross-appealed, seeking recovery of appellate fees despite the trial court's ruling.The California Court of Appeal, Second Appellate District, Division Eight, affirmed the trial court's order. The appellate court found no abuse of discretion in awarding fees for the second trial and the appeal, noting that the trial court had considered the misconduct and the overall reasonableness of the fees. The court also upheld the exclusion of post-offer fees and costs, in line with statutory requirements under section 998. View "Simers v. Los Angeles Times Communications LLC" on Justia Law

Plaintiffs Tommy Coleman and Jason Perkins, who worked as oil and gas pipeline inspectors for System One Holdings, LLC, were paid a flat daily rate without overtime compensation, even when working over forty hours a week. They filed a lawsuit claiming this violated the Fair Labor Standards Act (FLSA) and sought unpaid overtime on behalf of themselves and a putative class of similarly compensated inspectors.The United States District Court for the Western District of Pennsylvania reviewed the case. System One moved to dismiss and compel arbitration, arguing that the plaintiffs had signed arbitration agreements enforceable under the Federal Arbitration Act (FAA). The plaintiffs countered that they fell under the transportation workers' exemption to the FAA. The District Court, following the precedent set in Guidotti v. Legal Helpers Debt Resolution, L.L.C., ordered limited discovery into the arbitrability of the claims before deciding on the motion to compel arbitration. System One's motion for reconsideration of this order was denied.The United States Court of Appeals for the Third Circuit reviewed the case to determine if it had jurisdiction over the interlocutory appeal from the District Court's order. The Third Circuit held that it lacked appellate jurisdiction because the District Court's order did not formally deny the motion to compel arbitration but rather deferred its decision pending limited discovery. The court emphasized that the FAA permits appeals from specific types of orders, and the order in question did not fall within those categories. Consequently, the appeal was dismissed for lack of jurisdiction. View "Coleman v. System One Holdings LLC" on Justia Law

Robert Guthrie, a former employee of Rainbow Fencing Inc. (RFI), filed a lawsuit seeking unpaid wages and statutory damages for RFI's failure to provide wage notices and wage statements as required by New York law. Guthrie worked as a welder for RFI from 2014 to 2021 and claimed he was not paid for overtime hours. The district court entered a default judgment for the unpaid wages but dismissed Guthrie's claim for statutory damages, ruling that he lacked standing because he did not allege an injury-in-fact resulting from the failure to provide the required notices and statements.The United States District Court for the Eastern District of New York initially reviewed the case. The court granted a default judgment for Guthrie's unpaid wages but dismissed his claim for statutory damages due to lack of standing. The court concluded that Guthrie did not allege a concrete injury-in-fact caused by the absence of wage notices and statements, which is necessary to meet the case-or-controversy requirement of Article III.The United States Court of Appeals for the Second Circuit reviewed the case on appeal. The court affirmed the district court's decision, agreeing that Guthrie lacked standing to pursue statutory damages. The appellate court held that a plaintiff must allege a concrete injury-in-fact resulting from the statutory violation to have standing. Guthrie's general claims about potential harms did not suffice, as he failed to link these potential harms to any actual injury he experienced. Therefore, the court concluded that Guthrie did not meet the requirements for Article III standing and affirmed the dismissal of his claim for statutory damages. View "Guthrie v. Rainbow Fencing Inc." on Justia Law