Justia Labor & Employment Law Opinion Summaries

Jeff Stacy, a lineman for Unitil Corporation, continued working during the COVID-19 pandemic as his job was classified as an essential service. Despite the Governor's orders to shut down nonessential businesses, Stacy worked closely with colleagues, which led to his exposure to the virus. In February 2021, after working overtime during snowstorms, Stacy contracted COVID-19 from a coworker, resulting in severe illness and total disability. He applied for workers' compensation benefits, which were initially denied by his employer's insurer, Travelers Indemnity Company of Connecticut.An administrative judge from the Department of Industrial Accidents held an evidentiary hearing and ruled in favor of Stacy, finding that the risk of contracting COVID-19 was inherent in his employment during the pandemic. The judge noted that Stacy's job required close physical proximity to coworkers, increasing his risk of infection. The Industrial Accident Reviewing Board affirmed the judge's decision, adopting the factual findings and concluding that the decision was supported by adequate evidence and reasoned decision-making.The Supreme Judicial Court of Massachusetts reviewed the case and affirmed the board's decision. The court held that the board's determination that the risk of contracting COVID-19 was inherent in Stacy's employment was not arbitrary or capricious. The court emphasized that Stacy's role as an essential worker, who continued to work closely with others during a time when most businesses were closed and social distancing was mandated, justified the finding that his employment posed a unique risk of infection. Thus, Stacy's claim for workers' compensation benefits was upheld. View "Stacy's Case" on Justia Law

Two former employees sued Zen Nails Studio LLC and its owners for violating the Fair Labor Standards Act (FLSA) and a similar Maryland state law. After a five-day bench trial, the plaintiffs won and were awarded approximately 60% of their requested damages. The plaintiffs then sought $343,189.85 in attorney’s fees, but the district court awarded them $167,115.49, which was less than half of what they requested. The plaintiffs appealed the district court’s decision regarding the hourly rates used to calculate the attorney’s fees.The United States District Court for the District of Maryland, at Greenbelt, initially reviewed the case. The district court set the hourly rates for the plaintiffs’ attorneys, paralegals, and paraprofessionals based on the local rules' guidelines, which it treated as presumptively reasonable. The court then calculated the hours reasonably worked and reduced the total by 35% due to the plaintiffs achieving a moderately successful outcome. The plaintiffs challenged the district court’s reliance on the local rules' guidelines for setting the hourly rates.The United States Court of Appeals for the Fourth Circuit reviewed the case. The appellate court held that the district court erred by treating the hourly rates in the local rules as presumptively correct and requiring special justification for higher rates. The Fourth Circuit emphasized that while fee matrices can be a useful starting point, they should not be treated as setting a baseline that requires special justification to deviate from. The appellate court vacated the fee award and remanded the case for further proceedings, instructing the district court to consider all relevant evidence to determine the prevailing market rates without giving undue weight to the local rules' guidelines. View "De Paredes v. Zen Nails Studio LLC" on Justia Law

James Stefanski, a former employee of Saginaw County 911 Communications Center Authority, alleged that he was constructively discharged in retaliation for reporting his supervisor's gross negligence. The incident in question involved a 911 call where the supervisor coded the call as "shots fired" instead of "someone shot," resulting in a delayed emergency medical response and the subsequent death of a woman. Stefanski reported his concerns to the director, who dismissed them as a judgment call. Following this, Stefanski experienced increased stress, missed work, and eventually resigned after being suspended for excessive absences, which he believed was a pretext for retaliation.The Saginaw Circuit Court granted summary disposition to the defendant, ruling that reporting gross negligence, a common law violation, was not protected under the Whistleblowers' Protection Act (WPA). The Court of Appeals affirmed this decision, relying on a precedent that reporting common law violations, such as malpractice, does not fall under the WPA's protections.The Michigan Supreme Court reviewed the case and held that the term "law" in the WPA includes the common law. The court reversed the Court of Appeals' decision and remanded the case to determine whether gross negligence is a violation of "a" law under the WPA and whether Stefanski's actions constituted a report under the statute. The Supreme Court emphasized that the WPA should be liberally construed to protect whistleblowers and that excluding common law from its scope would undermine its purpose. View "Stefanski v. Saginaw County 911 Communications Center Authority" on Justia Law

Pablo Arredondo Padron was hired by Hugo Osoy to install two skylights in Osoy’s home. The project was expected to take 10 to 12 days, with Padron working eight hours each day. However, Padron fell from a ladder and was injured before completing 52 hours of work. Padron sued Osoy for negligence, but the trial court granted summary judgment in favor of Osoy, finding that Padron’s claims were exclusively covered by workers’ compensation.The Superior Court of Los Angeles County ruled that Padron’s employment was covered by workers’ compensation under Labor Code section 3351(d), which includes individuals employed by homeowners for duties incidental to the ownership, maintenance, or use of the dwelling. The court also found that Padron did not fall under the exclusion in section 3352(a)(8)(A), which excludes workers employed for less than 52 hours in the 90 days preceding the injury, because Padron had contracted to work for more than 52 hours.The California Court of Appeal, Second Appellate District, Division One, affirmed the trial court’s decision. The appellate court held that the exclusion in section 3352(a)(8)(A) does not apply when the employment is contracted to be for more than 52 hours, regardless of the actual hours worked before the injury. The court also rejected Padron’s arguments that he was not subject to the workers’ compensation system and that Osoy should be estopped from asserting the exclusivity defense. The court concluded that Osoy had secured workers’ compensation coverage through his homeowners’ insurance policy, which included the required coverage by operation of law. Therefore, Padron’s exclusive remedy was under the workers’ compensation system, and the summary judgment in favor of Osoy was affirmed. View "Padron v. Osoy" on Justia Law

Robert Caldwell was recruited by Champlain College's then-president Don Laackman in September 2016 and worked as Vice President of Advancement and later as Chief Advancement Officer from January 2017 to September 2019. His role was primarily as chief fundraiser. In fiscal year 2018, he missed his fundraising goal by approximately seventeen percent, and in fiscal year 2019, he missed his goal by more than 56 percent, resulting in a shortfall of over 2.2 million dollars. In May 2019, Caldwell was diagnosed with chronic kidney disease and informed President Laackman of his diagnosis. Laurie Quinn replaced Laackman as interim-president in June 2019 and discussed Caldwell's performance with him in July 2019. Caldwell mentioned he was dealing with health issues. In September 2019, Quinn fired Caldwell, citing his poor fundraising performance.Caldwell sued Champlain College in March 2021, alleging disability discrimination under the Fair Employment Practices Act (FEPA) and promissory estoppel. The Superior Court, Chittenden Unit, Civil Division granted summary judgment in favor of Champlain College on both claims. Caldwell appealed the decision.The Vermont Supreme Court reviewed the case and affirmed the lower court's decision. The court applied the McDonnell Douglas framework for assessing disability discrimination claims and found that Champlain College provided a legitimate, nondiscriminatory reason for Caldwell's termination—his failure to meet fundraising goals. Caldwell failed to provide evidence that this reason was pretextual. Additionally, the court found that Caldwell did not present any evidence of a specific and definite promise that would support his promissory estoppel claim. Therefore, the court affirmed the summary judgment in favor of Champlain College. View "Caldwell v. Champlain College Inc." on Justia Law

Scott Hampe was employed by Charles Gabus Motors, Inc. (Gabus) from 2008 until December 2019. Gabus conducted an unannounced drug test on December 5, 2019, assisted by Mid-Iowa Occupational Testing (Mid-Iowa). Hampe was selected as an alternate for testing and was ultimately tested. During the test, Hampe provided two insufficient urine samples and decided to leave the testing area to care for his sick child, despite being warned by his manager that leaving would result in termination. Hampe was subsequently fired.Hampe filed a lawsuit against Gabus and Mid-Iowa in May 2020, alleging violations of Iowa Code section 730.5, which governs employer drug testing, and asserting common law claims. The Iowa District Court for Polk County granted summary judgment in favor of Gabus and Mid-Iowa, dismissing all of Hampe’s claims. Hampe appealed, and the Iowa Court of Appeals affirmed the dismissal of claims against Mid-Iowa and most claims against Gabus but reversed the dismissal of claims related to testing pool requirements, supervisor training, and uniform disciplinary policy, finding genuine issues of material fact.The Iowa Supreme Court reviewed the case and focused on Hampe’s claim that Gabus violated section 730.5’s requirements for the composition of testing pools. The court concluded that Gabus failed to substantially comply with the statutory requirements for the testing pool, as the pool included employees who were not scheduled to work at the time of testing. The court also found that Hampe was aggrieved by this failure, as his selection for testing and subsequent termination were based on a non-compliant process. The court reversed the district court’s judgment in part, affirmed it in part, and remanded the case for further proceedings to determine the appropriate relief for Hampe. The court also deemed Hampe’s claims concerning supervisor training and uniform disciplinary policy moot in light of the resolution of the pooling claim. View "Hampe v. Charles Gabus Motors, Inc." on Justia Law

Gregory and Jeffrey Cota, employees of the Oconomowoc Area School District, were accused by a coworker of stealing money from the District. An internal investigation by the District was inconclusive, and the case was handed over to the police. The police investigation did not uncover new evidence, but the Cotas were cited for municipal theft. Approximately a year later, the assistant city attorney informed the District that he believed he could obtain a conviction. The next day, the District terminated the Cotas' employment.The Cotas filed claims of arrest-record discrimination under the Wisconsin Fair Employment Act, alleging that their termination was due to their arrest records. An administrative law judge initially found in favor of the District, but the Labor and Industry Review Commission (LIRC) reversed this decision, concluding that the District had engaged in arrest-record discrimination. The circuit court affirmed LIRC's decision, but the court of appeals reversed, holding that the Act's definition of "arrest record" did not include non-criminal offenses like municipal theft.The Wisconsin Supreme Court reviewed the case and held that the phrase "any . . . other offense" in the Act's definition of "arrest record" includes non-criminal offenses. The Court found that LIRC's conclusion that the District terminated the Cotas because of their arrest records was supported by substantial evidence. The Court rejected the District's argument that it was protected by the "Onalaska defense," which allows termination based on an internal investigation's findings, because LIRC found that the District relied on arrest-record information. The decision of the court of appeals was reversed, affirming LIRC's decision that the District violated the Act by terminating the Cotas due to their arrest records. View "Oconomowoc Area School District v. Cota" on Justia Law

Emily Johnston began teaching in the North Olmsted City School District in the 2018-2019 school year. Initially, the school board offered her a salary based on ten years of teaching experience, but before she signed the contract, they recalculated it based on six years of experience. Johnston signed the contract with the lower salary. She did not file a grievance under the collective-bargaining agreement (CBA) and later sought a writ of mandamus for the higher salary and backpay.The Eighth District Court of Appeals dismissed Johnston’s complaint, reasoning that she had an adequate remedy through the CBA’s grievance procedure. Johnston argued that the grievance procedure was inadequate because it did not allow for backpay and that she could not use it until her contract was signed. The court found that she had ample opportunity to file a grievance from her first paycheck and that her failure to do so did not make the remedy inadequate.The Supreme Court of Ohio affirmed the Eighth District’s decision. The court held that Johnston had an adequate remedy in the ordinary course of law through the CBA’s grievance procedure, which she failed to utilize. The court also rejected Johnston’s argument that her claim was purely statutory and not subject to the CBA, noting that the CBA implemented the board’s authority under relevant statutes and addressed salary-schedule placement. Therefore, Johnston’s claim was governed by the CBA, and her failure to file a grievance precluded mandamus relief. View "State ex rel. Johnston v. North Olmsted City School District Board of Education" on Justia Law

Jamilah Way, a lawyer employed by the City of Missouri City, Texas, from August 2018 to January 2021, developed anxiety and fibroids during her employment. She requested accommodations and took leave under the Family and Medical Leave Act (FMLA). Shortly after returning from her FMLA leave, she was terminated. Way sued the City under the FMLA, the Americans with Disabilities Act (ADA), and the Texas Commission on Human Rights Act (TCHRA), alleging discrimination, retaliation, and interference.The United States District Court for the Southern District of Texas granted summary judgment in favor of the City on all of Way’s claims. The court found that Way did not sufficiently inform the City about the limitations caused by her anxiety or fibroids and that the City had legitimate, non-retaliatory reasons for her termination.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the summary judgment on Way’s fibroid-related ADA and TCHRA claims, ADA and TCHRA retaliation claims, and FMLA interference claim. However, it reversed the summary judgment on Way’s anxiety-related ADA and TCHRA discrimination claims and her FMLA retaliation claim. The court found that Way provided sufficient evidence to suggest that her anxiety was a qualifying disability, that she informed her employer of her condition, and that the City failed to accommodate her reasonably. Additionally, the court found that the timing of her termination, shortly after her FMLA leave, and the City’s inconsistent explanations for her termination could support a finding of pretext for retaliation.The case was remanded for further proceedings consistent with the appellate court’s findings. View "Way v. City of Missouri City" on Justia Law

In 2019, the Rhode Island Department of Corrections (DOC) implemented changes to its Absenteeism Management Program (AMP), citing abuse of the existing sick-time policy. The changes included new discipline tracks, sanctions for absenteeism, stricter sick note requirements, and closer scrutiny of pattern sick time use. The Rhode Island Brotherhood of Correctional Officers (RIBCO) requested bargaining over these changes, which the DOC refused, leading RIBCO to file an unfair labor practice charge.The Rhode Island State Labor Relations Board (SLRB) found that the DOC had committed an unfair labor practice by making substantial changes to working conditions without bargaining. The board rejected the DOC's defenses, including the argument that the changes were within the director’s statutory authority and the management-rights clause of the collective bargaining agreement (CBA).The DOC appealed to the Superior Court, which reversed the SLRB's decision. The Superior Court found that the board's decision was not supported by substantial evidence and that the changes were within the DOC director’s statutory authority under Rhode Island law.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Court held that the SLRB's decision was not supported by reliable, probative, and substantial evidence. It also agreed that the changes to the AMP were within the DOC director’s statutory authority under sections 42-56-10(2), (5), and (7) of the Rhode Island General Laws, which grant the director broad discretion in managing the department, maintaining safety and order, and disciplining employees. Thus, the DOC was not obligated to bargain over the AMP changes. View "State of Rhode Island v. Rhode Island State Labor Relations Board" on Justia Law