Justia Labor & Employment Law Opinion Summaries

Mone Yvette Sanders filed a class and representative action against her former employer, Edward D. Jones & Co., L.P., alleging wage and hour claims under the Labor Code and a cause of action under the Private Attorneys General Act (PAGA). The trial court granted Edward Jones's motions to compel arbitration of Sanders's individual claims and stayed the representative PAGA cause of action. Sanders initiated arbitration, but Edward Jones failed to pay $54,000 in fees within 30 days as required by California Code of Civil Procedure section 1281.98. Sanders then moved to vacate the order compelling arbitration and proceed in court.The trial court denied Sanders's motion, finding section 1281.98 preempted by the Federal Arbitration Act (FAA). Sanders filed a petition for writ of mandate, and the Court of Appeal issued an order to show cause.The California Court of Appeal, Second Appellate District, Division Seven, reviewed the case. The court held that section 1281.98 is not preempted by the FAA, as it furthers the goal of expeditious arbitration. The court also rejected Edward Jones's contention that the arbitration agreement required the arbitrator to decide whether Edward Jones was in default. The court found that section 1281.98 vests the employee with the unilateral right to withdraw from arbitration and proceed in court upon the drafting party's failure to timely pay fees. The court concluded that the trial court erred in denying Sanders's motion to vacate the order compelling arbitration and granted the petition for writ of mandate. The case was remanded for further proceedings consistent with this opinion, including consideration of Sanders's request for monetary sanctions. View "Sanders v. Superior Court" on Justia Law

Plaintiffs, current and former employees of DENSO International America, Inc., alleged that the company's 401(k) Plan overpaid for recordkeeping and administrative services, breaching the fiduciary duty of prudence under the Employee Retirement Income Security Act of 1974 (ERISA). They claimed that the Plan's fiduciaries failed to use their significant bargaining power to negotiate lower fees, resulting in excessive costs compared to similar plans.The United States District Court for the Eastern District of Michigan dismissed the plaintiffs' complaint, stating that it failed to provide the necessary "context specific" facts to support an ERISA overpayment-for-recordkeeping-services claim. The court found that the plaintiffs did not sufficiently detail the types and quality of services provided to the Plan compared to those provided to other plans.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit held that the plaintiffs did not plausibly allege a breach of the duty of prudence because they failed to provide specific details about the services received by the Plan and how they compared to those received by the comparator plans. The court emphasized that a meaningful benchmark is necessary to evaluate whether the fees were excessive relative to the services rendered. The court also noted that general allegations about the fungibility of recordkeeping services and the bargaining power of mega plans were insufficient without specific context.The Sixth Circuit concluded that the plaintiffs' complaint did not meet the required pleading standards and affirmed the district court's dismissal of the case. View "England v. DENSO International America, Inc." on Justia Law

Loretta Mauldin, an employee at the McAlester Army Ammunition Plant (MCAAP) since 1991, filed a lawsuit against the Secretary of the United States Department of the Army. Mauldin, who was born in 1958, claimed retaliation and discrimination based on age under the Age Discrimination in Employment Act (ADEA) and sex discrimination under Title VII of the Civil Rights Act. The case arose after Mauldin was not selected for a promotion to a Grade 9 Explosives Operator Supervisor position in 2018. She alleged that her non-selection was due to her age, sex, and prior Equal Employment Opportunity (EEO) activity, including supporting a co-worker's age discrimination complaint.The United States District Court for the Eastern District of Oklahoma granted summary judgment in favor of the Army, dismissing Mauldin's claims. The court found that Mauldin failed to establish a prima facie case of retaliation and discrimination. It concluded that the Army provided legitimate, nondiscriminatory reasons for selecting another candidate, Scott Harkey, who performed better in the interview process. The court also determined that Mauldin did not provide sufficient evidence to show that the Army's reasons were pretextual.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that the district court correctly considered the Army's evidence, including testimony from the interview panelists and Mauldin's supervisor, Buckner. The court found that Mauldin did not demonstrate a genuine issue of material fact regarding pretext. The court emphasized that the interview process was neutral and that Mauldin's lower interview scores were a legitimate reason for her non-selection. Consequently, the Tenth Circuit upheld the summary judgment in favor of the Army, concluding that Mauldin's claims of retaliation and discrimination were not supported by sufficient evidence. View "Mauldin v. Wormuth" on Justia Law

The Los Angeles College Faculty Guild, AFT Local 1521, sought to reverse the trial court’s denial of its motion to compel arbitration of three grievances against the Los Angeles Community College District. The grievances involved safety-related construction projects at Los Angeles City College, the termination of a faculty member at Pierce College, and the miscalculation of retirement benefits for a faculty member at Los Angeles Trade-Technical College.The Superior Court of Los Angeles County partially granted the motion to compel arbitration for the grievance related to backpay for the retirement benefits issue but denied the motion for the other grievances. The court found that the grievances were beyond the scope of the collective bargaining agreement and were preempted by the Education Code and other statutory requirements.The Court of Appeal of the State of California, Second Appellate District, Division Eight, affirmed the trial court’s decision. The appellate court held that the grievances related to construction projects and employment termination were not arbitrable because they were preempted by the Education Code and the Construction Bonds Act. The court also found that the grievance related to retirement benefits was partially arbitrable only concerning the backpay issue, as the Public Employees’ Retirement Law governed the reporting of service credits to CalPERS, and the arbitrator could not order injunctive relief beyond the scope of the collective bargaining agreement.The appellate court concluded that the Guild failed to demonstrate that the grievances were within the scope of representation as enumerated by the Educational Employment Relations Act and affirmed the trial court’s mixed ruling. View "L.A. College Faculty Guild v. L.A. Community College District" on Justia Law

Rodney Dean Bjornson, the relator, suffered two injuries while employed by McNeilus Companies, Inc. He received treatment at Mayo Clinic, with expenses paid by United Healthcare Services. Bjornson's attorney, David C. Wulff, sought Roraff fees for recovering medical benefits. The compensation judge awarded Wulff $49,000 in Roraff fees, finding that United paid $327,257.37 in medical benefits based on itemized medical bills from Mayo Clinic attached to Bjornson's Employee’s Claim Petition.The Workers’ Compensation Court of Appeals (WCCA) reviewed the case and concluded that the itemized bills from Mayo Clinic were not in the appellate record. The WCCA reversed the compensation judge’s award of Roraff fees due to insufficient evidence regarding the bills and modified the Roraff fees to $500, as per the statutory formula for unascertainable benefits amounts.The Minnesota Supreme Court reviewed the case to determine if Wulff presented sufficient evidence of the ascertainable dollar value of medical benefits. The court found that the WCCA did not assess whether the remaining evidence, including Wulff’s testimony and exhibits, was adequate to support the compensation judge’s conclusion. The Supreme Court reversed the WCCA's decision and remanded the case for further proceedings. The WCCA was directed to clarify whether the itemized medical bills were actual bills or a summary document and to determine if the evidence in the record was adequate to support the compensation judge’s conclusion. View "Bjornson v. McNeilus Companies, Inc." on Justia Law

Javier Hernandez, a farm laborer employed by Ceja Reyes, Inc., was injured in a vanpool accident while commuting home from work. Hernandez did not have a driver's license or own a car, and he used a vanpool arranged by another employee, paying $10 per day for the service. The vanpool was not provided by Ceja Reyes, and the driver at the time of the accident did not have a valid California driver's license. Hernandez sustained catastrophic injuries, including a right leg amputation, and filed a workers' compensation claim.A workers' compensation judge initially heard the case and concluded that Hernandez's claim was not barred by the going and coming rule, applying the special risk and dual purpose exceptions. Zenith Insurance Company, Ceja Reyes's workers' compensation insurer, denied the claim and filed a petition for reconsideration. The Workers' Compensation Appeals Board (the Board) denied the petition and adopted the judge's report, leading Zenith to file a petition for writ of review with the California Court of Appeal, Third Appellate District.The California Court of Appeal reviewed the case and determined that the Board's application of the special risk and dual purpose exceptions was erroneous. The court found that the special risk exception did not apply because the injury did not occur just outside the employer's premises and there was no relationship between the risk and the location of the premises or conditions over which the employer had control. Additionally, the dual purpose exception was deemed inapplicable as the commute did not provide an incidental benefit to the employer beyond the normal need for the employee's presence at work. Consequently, the court annulled the Board's order and remanded the case for further proceedings consistent with its opinion. View "Zenith Insurance Co. v. Workers' Comp. Appeals Bd." on Justia Law

Two former police officers, Mark Zukowski and Joshua Ruggiero, were injured in the line of duty and subsequently awarded both accidental disability retirement (ADR) benefits and workers' compensation benefits under Maryland's Workers' Compensation Act. The ADR benefits exceeded the workers' compensation benefits, resulting in an offset that left the officers with only a small portion of the workers' compensation benefits. The officers' attorney sought fees based on the total workers' compensation award before the offset was applied.The Maryland Workers' Compensation Commission awarded attorney's fees based on the reduced amount of workers' compensation benefits after applying the statutory offset. The Circuit Court for Anne Arundel County affirmed the Commission's decision, holding that attorney's fees should be calculated after the offset.The Supreme Court of Maryland reviewed the case and affirmed the lower courts' decisions. The Court held that the terms "benefits" and "compensation" are interchangeable in this context, meaning that attorney's fees should be calculated based on the amount of compensation actually payable to the claimant after applying the statutory offset. The Court emphasized that the attorney's fees are a lien on the compensation awarded, which is defined as the money payable to the injured employee. Therefore, the offset must be applied before calculating the attorney's fees. The Court also rejected the argument that this interpretation was unconstitutional, stating that the attorney voluntarily agreed to the fee arrangement and was aware of the statutory provisions governing attorney's fees. View "Zukowski v. Anne Arundel Cnty." on Justia Law

The appellants, James Ruble, Linda O’Connor, Cynthia Brill, and Suzanne Holland, were administrators employed by the Switzerland of Ohio Local School District Board of Education. In 2021, the board, following the recommendation of a new superintendent, suspended their contracts to streamline the administration, which was deemed overstaffed. The administrators argued that the local policy under which their contracts were suspended was invalid as it did not meet the requirements of R.C. 3319.171.The Seventh District Court of Appeals denied the administrators' petition for a writ of mandamus, which sought reinstatement to their former positions with back pay and benefits. The court found that the board’s policy was valid and that the reasons for the contract suspensions were legitimate. The administrators then appealed to the Supreme Court of Ohio, focusing solely on the argument that the board’s policy was invalid under R.C. 3319.171.The Supreme Court of Ohio affirmed the lower court’s decision, holding that the administrators failed to demonstrate a clear legal right to reinstatement under R.C. 3319.171. The court noted that the statute does not provide a right to reinstatement if a local policy is found deficient. The court also denied the administrators' motion for oral argument, finding the briefs sufficient to resolve the issues. The judgment of the Seventh District Court of Appeals was thus affirmed, and the administrators' contracts remained suspended under the board’s policy. View "State ex rel. Ruble v. Switzerland of Ohio Local School Dist. Bd. of Edn." on Justia Law

Travon Celey, a former employee of Children’s National Medical Center, was terminated on March 1, 2022, for accumulating six instances of tardiness within a twelve-month period. Celey subsequently applied for unemployment benefits, but a claims examiner from the District of Columbia Department of Employment Services (DOES) disqualified him, citing gross misconduct due to repeated tardiness following warnings.Celey appealed the decision to the Office of Administrative Hearings (OAH). Despite filing the appeal well beyond the fifteen-day deadline, OAH extended the deadline due to good cause and excusable neglect. During the hearing, the Hospital presented evidence and testimony showing that Celey had been warned and suspended for his tardiness, referencing both the independent Attendance Policy and the collective bargaining agreement (CBA) policy. The CBA policy mandated termination after the sixth instance of tardiness, while the independent Attendance Policy allowed for termination only after the eighth instance.The OAH administrative law judge (ALJ) found that the Hospital had issued inconsistent rules, failing to clearly notify Celey of the specific policy that applied to him. The ALJ concluded that Celey did not willfully violate the Hospital’s expectations and was therefore qualified to receive unemployment benefits.The District of Columbia Court of Appeals reviewed the case and affirmed the OAH decision. The court held that substantial evidence supported the ALJ’s finding that Celey was not adequately informed about the CBA policy, which was crucial for determining his eligibility for unemployment benefits. The court emphasized that the issue was whether Celey was on notice that his conduct could lead to termination, not whether the Hospital was justified in terminating him. View "Children's National Medical Center v. Celey" on Justia Law

The plaintiffs are seven members of the South Dakota Air National Guard who also work as federal civilian employees of the Department of the Air Force. They are entitled to 15 days of paid military leave each year in their civilian roles. They allege that the Adjutant General wrongfully denied them military leave while they were serving on active duty, in violation of the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA).The Circuit Court of the Second Judicial Circuit, Minnehaha County, South Dakota, dismissed the USERRA claims sua sponte without reaching the merits of the parties’ arguments. The court concluded that the plaintiffs must demonstrate the existence of an antimilitary animus to prevail under USERRA. The plaintiffs appealed this decision.The Supreme Court of the State of South Dakota reviewed the case and concluded that the plaintiffs are entitled to military leave. The court held that the plaintiffs do not need to show antimilitary animus because the benefit in question, military leave, is only available to members of the military. The court found that the plaintiffs' Title 10 orders converted their status from state militia members to federal service members, making them eligible for the 15 days of paid military leave under 5 U.S.C. § 6323(a)(1). The court reversed the circuit court’s decision and remanded the case for further proceedings consistent with its opinion. View "Christiansen v. Morrell" on Justia Law