Justia Labor & Employment Law Opinion Summaries

The City and County of Butte-Silver Bow, Montana (BSB) hired Rhonda Staton as a police officer in 2001, promoting her to detective in 2008. Staton received two verbal reprimands in 2017 and 2018 for tardiness and refusal to investigate underage drinking, respectively. In 2019, Staton filed a hostile work environment complaint, which was not substantiated. In early 2020, Staton lost her department-issued taser, leading to a Fit for Duty Evaluation (FFDE) by Dr. George Watson, who found her unfit for duty. Staton was terminated in August 2020 based on this evaluation and her performance issues.The Butte Police Protective Association (BPPA) filed a grievance on Staton’s behalf, leading to arbitration. Arbitrator A. Ray McCoy found Watson’s FFDE unreliable and ruled that BSB had not established just cause for Staton’s termination. McCoy ordered Staton’s reinstatement, back pay, and an additional evaluation to determine rehabilitative strategies. BSB did not comply with the reinstatement or compensation but arranged for an Independent Medical Evaluation (IME) by Dr. William Patenaude, which did not provide a diagnosis or rehabilitative recommendations.BSB petitioned to vacate the arbitration award, arguing it was a manifest disregard of Montana law. The Second Judicial District Court denied the motion to vacate but remanded the matter to the arbitrator to reconcile the award with Staton’s inability to return to service. BSB appealed.The Supreme Court of the State of Montana reviewed the case and held that the arbitrator’s award did not violate Montana law or public policy. The court found that the District Court abused its discretion by remanding the matter, as it exceeded the permissible scope of review for arbitration awards. The Supreme Court reversed the District Court’s order and remanded with instructions to confirm the original arbitration award. View "Butte v Butte Police" on Justia Law

Edgar Gonzalez worked for Nowhere Santa Monica, one of ten related LLCs operating Erewhon markets in Los Angeles. As a condition of employment, Gonzalez signed an arbitration agreement with Nowhere Santa Monica. He later filed a lawsuit against all ten LLCs, alleging various Labor Code violations and claiming they were joint employers. The non-Santa Monica entities moved to compel arbitration based on the agreement with Nowhere Santa Monica, but Gonzalez opposed, arguing they were not parties to the agreement.The Superior Court of Los Angeles County granted the motion to compel arbitration for Nowhere Santa Monica but denied it for the other entities, finding no evidence that Gonzalez's claims against the non-signatory defendants were intertwined with the arbitration agreement. Gonzalez then dismissed his complaint against Nowhere Santa Monica, and the other entities appealed.The California Court of Appeal, Second Appellate District, Division One, reviewed the case. The court held that Gonzalez was equitably estopped from avoiding arbitration with the non-Santa Monica entities because his claims against them were intimately founded in and intertwined with the employment agreement with Nowhere Santa Monica. The court reasoned that Gonzalez's joint employment theory inherently linked his claims to the obligations under the employment agreement, which contained the arbitration clause. Therefore, the court reversed the lower court's order denying the motion to compel arbitration for the non-Santa Monica entities. View "Gonzalez v. Nowhere Beverly Hills LLC" on Justia Law

Stephnie Trujillo filed a complaint against her former employer, J-M Manufacturing Company (JMM), and four former coworkers, alleging unlawful sexual/gender discrimination, harassment, failure to prevent such acts, retaliation, and seeking injunctive relief. The parties negotiated and entered into a post-dispute stipulation for arbitration, which was approved by the trial court. Arbitration commenced, and JMM paid the arbitrator’s invoices timely for over a year. However, JMM paid one invoice late, leading Trujillo to file a motion to withdraw from arbitration under California Code of Civil Procedure section 1281.98, which the trial court granted.The Superior Court of Los Angeles County granted Trujillo’s motion to withdraw from arbitration, finding that JMM’s late payment constituted a material breach under section 1281.98, despite acknowledging that the delay did not prejudice Trujillo. The court lifted the stay on trial court proceedings, allowing the case to proceed in court.The California Court of Appeal, Second Appellate District, Division Eight, reviewed the case and reversed the trial court’s decision. The appellate court held that section 1281.98 did not apply because the parties had entered into a post-dispute stipulation to arbitrate, not a pre-dispute arbitration agreement. Additionally, JMM was not considered the “drafting party” as defined by section 1280, subdivision (e), since the stipulation was primarily drafted by Trujillo. The appellate court remanded the case with instructions to deny Trujillo’s motion to withdraw from arbitration and to reinstate the stay of trial court proceedings pending the completion of arbitration. View "Trujillo v. J-M Manufacturing Co., Inc." on Justia Law

Four former employees of Litster Frost Injury Lawyers (LFIL) filed a lawsuit against LFIL and its former sole shareholder, Martha Frost, for unpaid wages and breach of an employment agreement. They claimed LFIL owed them compensation in the form of wages, bonuses, profit sharing, and other expenses incurred while employed. The district court granted summary judgment in favor of LFIL, concluding that the employees' claims were time-barred by the one-year statute of limitations under Idaho Code section 45-614 and that the employment agreement was an unenforceable "agreement to agree."The employees appealed, arguing that the district court erred in determining that the provisions of the employment agreement were not severable or enforceable and that the court should have supplied a "reasonable time" for performance. LFIL cross-appealed, arguing that the district court erred in denying their request for attorney fees following summary judgment.The Supreme Court of Idaho reviewed the case and held that the district court did not err in granting summary judgment on the employees' breach of contract claims because the employment agreement was unenforceable. The court found that the agreement's essential terms were too indefinite and subject to future negotiations. However, the court reversed the district court's decision regarding Sarah's reimbursement claim, finding that issues of material fact existed as to whether her claim fell within Idaho's Wage Claim Act. The court affirmed the district court's grant of summary judgment on all other claims.The Supreme Court also reversed the district court's decision on attorney fees, holding that the district court did not apply the correct legal standard. The court remanded the case for further proceedings consistent with its opinion. Attorney fees on appeal were awarded to LFIL for the time spent responding to certain claims, and costs were awarded to LFIL. View "Litster v. Litster Frost Injury Lawyers PLLC" on Justia Law

Adrianne Cotton filed a charge of discrimination against the Montana Department of Corrections (DOC), alleging retaliation for protected activity when her position was eliminated. Cotton had been employed by DOC since 2011 and held the position of government relations director. She reported concerns about the conduct of DOC Director Reginald Michael in 2017, which led to an investigation. Subsequently, an organizational assessment recommended eliminating Cotton's position, among others, due to budgetary and structural issues.The case was first reviewed by Hearing Officer Holien, who held a contested case hearing and found that DOC had legitimate, non-discriminatory reasons for eliminating Cotton's position and did not retaliate against her. Cotton appealed to the Human Rights Commission, which rejected Holien's conclusions of law, citing the temporal proximity between Cotton's protected activity and the adverse employment action as sufficient evidence of retaliation. The Commission did not find that Holien's findings of fact were unsupported by substantial evidence.The case was then reviewed by the District Court of the First Judicial District, which found that the Commission exceeded its statutory authority by reweighing the evidence and substituting its judgment for that of the hearing officer. The District Court reversed the Commission's order and reinstated Holien's decision as the final agency decision.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The Court held that the Commission had abused its discretion by not adhering to the proper standard of review and by reweighing evidence that supported Holien's findings. The Supreme Court concluded that the District Court did not err in reinstating Holien's findings as the final agency decision, as they were supported by substantial evidence in the record. View "Cotton v. Dept. of Corrections" on Justia Law

The case involves Patricia A. Heilman, the surviving spouse of Arthur J. Heilman, who died from an industrial accident. Patricia Heilman sought scheduled-loss compensation under Ohio law, claiming her husband had lost the use of both arms, both legs, sight in both eyes, and hearing in both ears before his death. The Industrial Commission of Ohio denied her request based on a nonexamining physician's report, which did not fully accept the findings of the examining physicians.The Tenth District Court of Appeals reviewed the case and granted a limited writ of mandamus. The court ordered the Industrial Commission to vacate its denial of scheduled-loss compensation and to re-evaluate whether Patricia Heilman had established her claims under the relevant statute. The court found that the Commission had improperly relied on the nonexamining physician's report, which did not comply with the requirements set forth in Wallace v. Industrial Commission.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's judgment. The court held that the Industrial Commission abused its discretion by relying solely on the nonexamining physician's report, which failed to accept the objective findings of the examining physicians. The Supreme Court clarified that while the Commission could not base its decision solely on the nonexamining physician's report, it could use the report as guidance in evaluating the remaining medical evidence. The court ordered the Commission to vacate its previous order and issue a new decision based on a proper evaluation of the evidence. View "State ex rel. Heilman v. Industrial Commission" on Justia Law

Capstone Logistics, LLC, a company providing labor to other businesses, began supplying auditors to Associated Wholesale Grocers in 2019. The auditors, including Joyce Henson, were responsible for checking groceries and ensuring order accuracy. Henson, hired as lead auditor, raised concerns about safety, training, and pay on behalf of the auditors. She also contacted Donny Rouse, a major customer, about her pay. After a meeting with Capstone officials, Henson sent a LinkedIn message to Rouse about the auditors' pay issues. Following a brief interaction with Associated Wholesale Grocers' Director Chris Griffin, Henson was terminated by Capstone's Vice President Tim Casey.The National Labor Relations Board (NLRB) issued a complaint against Capstone, alleging violations of the National Labor Relations Act (NLRA) for discharging Henson due to her protected concerted activities. An administrative law judge (ALJ) dismissed the allegations, finding no sufficient causal connection between Henson's protected activities and her termination. The ALJ concluded that Henson's termination was more likely due to her efforts to secure better compensation for herself.The NLRB reversed the ALJ's decision, finding that Henson was discharged for engaging in protected concerted activity by sending the LinkedIn message to Rouse and because Capstone believed she had engaged in such activity during her conversation with Griffin. Capstone petitioned for review, and the NLRB cross-petitioned for enforcement of its order.The United States Court of Appeals for the Fifth Circuit found insufficient evidence to support the NLRB's finding that Capstone discharged Henson for sending the LinkedIn message. However, the court affirmed the NLRB's alternative determination that Capstone violated Section 8(a)(1) of the NLRA by discharging Henson because it believed she had engaged in protected concerted activity. The court denied Capstone's petition for review and granted the NLRB's cross-application to enforce its order. View "Capstone Logistics v. National Labor Relations Board" on Justia Law

Plaintiffs Antonio Juarez, Jose Hinojosa, Jose Espinosa, and Maria Morfin filed a lawsuit against the San Bernardino City Unified School District following an incident involving Officer Alejandro Brown, a District employee. In February 2018, Juarez found a cell phone and later, Officer Brown, tracking his phone, confronted the plaintiffs, identifying himself as a District police officer. Brown, armed and displaying his badge, demanded compliance, struck Juarez with his firearm, and threatened the others. Brown later pled guilty to assault and battery and threatening the plaintiffs under color of law.The Superior Court of Riverside County sustained the District’s demurrer to the plaintiffs’ second amended complaint without leave to amend, leading to the dismissal of the case. The court found the complaint insufficient to establish that Officer Brown was acting within the scope of his employment with the District and dismissed the claims of negligence, battery, assault, negligent hiring, supervision, and retention, false arrest and imprisonment, intentional and negligent infliction of emotional distress, and violation of the Bane Act.The Court of Appeal, Fourth Appellate District, Division One, State of California, reversed and remanded the case. The appellate court held that the scope of employment is a factual issue that cannot be resolved as a matter of law on demurrer. The court found that Officer Brown’s off-duty misconduct, while investigating a suspected theft and wielding his authority as a peace officer, could be regarded as an outgrowth of his employment. The court directed the trial court to vacate its order sustaining the demurrer, enter a new order overruling the demurrer, and conduct further proceedings. The appellate court also rejected the District’s arguments regarding the Bane Act and found the plaintiffs’ allegations sufficient to state a cause of action for negligent hiring, supervision, and retention. View "Juarez v. San Bernardino City Unified Sch. Dist." on Justia Law

Nattalia Castell was employed as a senior accountant for Money Metals Exchange, LLC. She was discharged after allegedly mishandling an Idaho Department of Labor (IDOL) notice regarding her boyfriend's unemployment benefits application. Castell applied for unemployment benefits, but an IDOL appeals examiner excluded her boyfriend from testifying, denied her request to reopen the hearing to read a statement, and found that she was terminated for employment-related misconduct, making her ineligible for benefits.Castell appealed to the Idaho Industrial Commission, which denied her request to reopen the hearing and affirmed the appeals examiner's decision. The Commission found that Castell's actions constituted misconduct, as she failed to disclose a conflict of interest and mishandled the notice. Castell then appealed to the Idaho Supreme Court.The Idaho Supreme Court reviewed the case and affirmed the Commission's decision. The Court held that the appeals examiner did not err in excluding the boyfriend's testimony or in denying Castell's request to reopen the hearing. The Court also found that the Commission's determination that Castell was discharged for employment-related misconduct was supported by substantial and competent evidence. The Court concluded that Castell's actions disregarded a standard of behavior that Money Metals had a right to expect from its employees, and her claim of retaliation was not supported by evidence. View "Castell v. IDOL" on Justia Law

In 2013, Dr. Johnathan Slone began working as a general surgeon at El Centro Regional Medical Center (Center) on a locum tenens basis. Despite not being board-certified, he was granted full staff privileges in January 2015. In April 2016, Slone became an employee of the Imperial Valley MultiSpecialty Medical Group (IVMSMG) and later entered into a contract with Community Care IPA (IPA) to provide healthcare administrative services. In July 2017, Slone was informed by the Center that he had until July 2020 to become board-certified. Subsequently, he resigned from IVMSMG and began working full-time for IPA. In September 2017, the Center suspended his privileges for failing to complete medical records, and by March 2018, his suspension was deemed a voluntary resignation.Slone filed a fourth amended complaint in February 2021, alleging that the Center retaliated against him in violation of Health and Safety Code section 1278.5 after he reported concerns about patient care. The case proceeded to a bench trial solely on this cause of action. The Superior Court of Imperial County found in favor of the Center, concluding that Slone did not suffer retaliation and had not proven any economic or noneconomic damages.The Court of Appeal, Fourth Appellate District, Division One, reviewed the case. The court affirmed the lower court's judgment, holding that Slone did not carry his burden on appeal. The court found substantial evidence supporting the trial court's findings that the Center did not retaliate against Slone for his complaints about patient care. The court also upheld the trial court's findings that Slone voluntarily resigned from his surgical practice to pursue a career as a medical administrator and did not suffer any economic or noneconomic damages as a result of the alleged retaliation. View "Slone v. El Centro Regional Medical Center" on Justia Law