Justia Labor & Employment Law Opinion Summaries

Jason Earlywine was employed as a teacher by the Board of Education of Paris Independent School District (BEP) from August 2007 to June 2019. In 2011, a student accused him of inappropriate conduct, leading to his placement on paid administrative leave, which was later changed to unpaid leave. He faced a criminal charge of Sexual Abuse in the First Degree, but the trial court granted him a directed verdict in January 2015, and the charge was expunged. Earlywine was reinstated in February 2015 but was terminated in 2019 for unspecified reasons. In 2020, he sued BEP to recover lost wages during his unpaid leave.The Bourbon Circuit Court initially handled the case, determining that BEP was within the waiver of immunity under KRS 45A.245(1) but transferred the case to Franklin Circuit Court due to venue appropriateness. BEP appealed, arguing governmental immunity and failure to exhaust administrative remedies. The Court of Appeals ruled that BEP's immunity was waived under KRS 45A.245(1) but concluded that Earlywine's failure to exhaust administrative remedies deprived the court of subject matter jurisdiction.The Supreme Court of Kentucky reviewed the case, affirming that BEP is subject to the waiver of immunity under KRS 45A.245(1). However, it reversed the Court of Appeals' conclusion regarding the exhaustion of administrative remedies, stating that this issue is subject to exceptions and should not have been addressed on interlocutory appeal. The Supreme Court remanded the case to Franklin Circuit Court for further proceedings, allowing Earlywine to argue any applicable exceptions to the exhaustion requirement. View "BOARD OF EDUCATION OF PARIS, KENTUCKY V. EARLYWINE" on Justia Law

Timothy Hoffstead, a canine handler for Metra, was suspended after testing positive for amphetamines and opioids during a random drug test. Hoffstead attributed the positive result to his prescribed medications for ADD, migraines, and a wrist injury. The medical review officer (MRO) attempted to contact Hoffstead for an explanation but was unsuccessful. Consequently, Hoffstead was suspended and later not considered for an open canine handler position. Despite providing proof of his prescriptions and having his test results revised to negative, Metra required him to complete a rehabilitation program. Hoffstead eventually returned to work but left Metra for other employment.The United States District Court for the Northern District of Illinois granted summary judgment in favor of Metra. The court found that Hoffstead failed to demonstrate that Metra's actions were due to his disability. The court also ruled that it could not consider Hoffstead's claim regarding the exercise of seniority under the collective bargaining agreement (CBA) due to the Railway Labor Act (RLA), which prohibits courts from interpreting CBAs.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 Hoffstead did not provide sufficient evidence to show that Metra's actions were motivated by his disability. The court noted that Hoffstead's failure to respond to the MRO and his decision to waive an investigation in favor of the rehabilitation program were the primary reasons for Metra's actions. The court also found that the RLA did not preclude adjudicating Hoffstead's claim regarding the seniority rules but concluded that Hoffstead failed to demonstrate a link between his disability and Metra's actions. View "Hoffstead v Northeast Illinois Regional Commuter Railroad Corp" on Justia Law

Scott Cannon, individually and as the personal representative of the estate of Blaise Cannon, filed a wrongful death and punitive damages claim against Blue Cross and Blue Shield of Massachusetts (BCBS). Cannon alleged that BCBS's denial of coverage for a specific inhaler led to asthma-related complications that contributed to Blaise's death. Blaise was a beneficiary of his partner's BCBS health insurance policy, which was governed by the Employee Retirement Income Security Act of 1974 (ERISA).The United States District Court for the District of Massachusetts granted summary judgment to BCBS on the grounds of ERISA preemption. The court found that Cannon's wrongful death claim was preempted by ERISA because it related to an employee benefit plan and arose from the denial of benefits under that plan. The court also held that the claim conflicted with the remedial scheme established by ERISA, which provides specific civil enforcement mechanisms.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that Cannon's claim was statutorily preempted under ERISA because it had a connection with the ERISA-regulated health insurance plan. The court also found that the claim was preempted under ERISA's civil enforcement provisions, as it sought remedies for the denial of benefits under the plan. The court rejected Cannon's argument that the Supreme Court's decision in Rutledge v. Pharmaceutical Care Management Association altered the preemption analysis, reaffirming that ERISA preempts state laws that relate to employee benefit plans. The court concluded that Cannon's wrongful death claim was derivative of Blaise's potential claim for benefits, which would have been preempted by ERISA. View "Cannon v. Blue Cross and Blue Shield of Massachusetts, Inc." on Justia Law

The plaintiff, an employee of the Department of Mental Health and Addiction Services, sustained a work-related injury to her left wrist in April 2016. After undergoing two surgeries and being diagnosed with posttraumatic chronic synovitis, she was determined to have reached maximum medical improvement in March 2020. The defendant sought to convert her temporary partial incapacity benefits to permanent partial disability benefits based on this determination.An administrative law judge approved the defendant's request to convert the benefits, concluding that he lacked the authority to award ongoing temporary partial incapacity benefits once the plaintiff reached maximum medical improvement. The plaintiff appealed to the Compensation Review Board, which affirmed the administrative law judge's decision, agreeing that ongoing temporary partial incapacity benefits are unavailable after reaching maximum medical improvement.The plaintiff then appealed to the Appellate Court, which also affirmed the board's decision. The Appellate Court concluded that an administrative law judge does not have the discretion to award ongoing temporary partial incapacity benefits under General Statutes § 31-308 (a) once a claimant reaches maximum medical improvement and becomes eligible for permanent partial disability benefits under § 31-308 (b).The Supreme Court of Connecticut reviewed the case and reversed the Appellate Court's judgment. The court held that the clear and unambiguous language of § 31-308 (b) gives an administrative law judge the discretion to award a claimant ongoing temporary partial incapacity benefits under § 31-308 (a) in lieu of permanent partial disability benefits under § 31-308 (b) after reaching maximum medical improvement, up to the statutory maximum of 520 weeks. The case was remanded to the administrative law judge for further proceedings consistent with this interpretation. View "Gardner v. Dept. of Mental Health & Addiction Services" on Justia Law

Jon Woods, a workers' compensation attorney, was convicted of 37 felony counts of workers' compensation fraud. Woods had engaged in unlawful kickback and referral fee arrangements, referring copy and subpoena work to companies that provided financial benefits to him and his firm. This corruption affected the workers' compensation system, as the employer's insurance company had to cover the costs.The Superior Court of Orange County reviewed the case, where Woods was found guilty on all counts and received a four-year prison sentence. He was also ordered to pay $701,452 in restitution. Woods appealed, arguing that the Williamson rule precluded convictions on counts 5 through 37, and that the court erred in limiting his cross-examination of certain prosecution witnesses.The California Court of Appeal, Fourth Appellate District, Division Three, reviewed the case. The court agreed with Woods that the Williamson rule applied, as his conduct fell under a more specific statute, Labor Code section 139.32, which criminalizes kickback schemes and is a misdemeanor. Therefore, the court reversed Woods's convictions on counts 5 through 37, the white-collar sentencing enhancement, and the restitution award based on these charges. However, the court found no error in the trial court's limitation of cross-examination of prosecution witnesses and affirmed the remainder of the judgment. View "People v. Woods" on Justia Law

Plaintiffs filed a class action lawsuit against Nike, Inc., alleging gender discrimination and hostile workplace claims. During discovery, a collection of internal workplace complaints, known as the Starfish complaints, was produced under a protective order. Three media organizations, including The Oregonian, intervened in the case to gain access to these documents. Plaintiffs' attorney inadvertently sent confidential documents to a reporter from The Oregonian, who refused to return or destroy them upon request.The United States District Court for the District of Oregon initially granted a motion to intervene by the media organizations. However, when the inadvertent disclosure occurred, the magistrate judge ordered The Oregonian to return or destroy the documents. The district court vacated this order, reasoning that it lacked authority to compel a non-party to return the documents. The magistrate judge then denied the motion, and the district court affirmed this decision.The United States Court of Appeals for the Ninth Circuit reviewed the case and held that the district court had the inherent authority to order The Oregonian, as an intervenor and thus a party to the case, to return or destroy the confidential documents. The court determined that The Oregonian did not have a First Amendment right to withhold the documents because pretrial discovery proceedings are not public components of the judicial process. The court applied relaxed First Amendment scrutiny and concluded that the district court's exercise of its inherent authority over discovery furthered a substantial government interest unrelated to the suppression of expression. The Ninth Circuit vacated the district court's order and remanded the case for further proceedings consistent with its opinion. View "CAHILL V. NIKE, INC." on Justia Law

Plaintiff Christian L. Johnson sued his employer, the California Department of Transportation (Caltrans), alleging discrimination, harassment, and retaliation. During the litigation, Caltrans attorney Paul Brown sent an email to Johnson’s supervisor, Nicolas Duncan, which Duncan then shared with Johnson. Johnson forwarded the email to his attorney, John Shepardson, who further disseminated it to several experts and individuals. Caltrans sought a protective order, claiming the email was covered by attorney-client privilege. The trial court granted the order and later disqualified Shepardson and three experts for non-compliance with the order.The Superior Court of San Joaquin County issued the protective order, finding the email privileged. Johnson and Shepardson were ordered to destroy all copies and cease further dissemination. Caltrans later filed a motion to enforce the order and subsequently a motion to disqualify Shepardson and the experts, arguing continued non-compliance and misuse of the privileged email. The trial court granted the disqualification, citing Shepardson’s breach of ethical duties and the potential prejudice to Caltrans.The California Court of Appeal, Third Appellate District, reviewed the case. The court affirmed the trial court’s decision, holding that the Brown email was protected by attorney-client privilege. The court found no merit in Johnson’s arguments that the privilege was waived or that the crime-fraud exception applied. The court also upheld the disqualification of Shepardson and the experts, concluding that Shepardson’s actions violated ethical obligations and posed a risk of unfair advantage and harm to the integrity of the judicial process. The court emphasized the importance of maintaining public trust in the administration of justice. View "Johnson v. Dept. of Transportation" on Justia Law

Rosalyn Musker worked in sales for Suuchi, Inc., which sells software subscriptions to apparel manufacturers. In addition to her base salary, Musker was eligible for commissions under Suuchi’s Sales Commission Plan (SCP). In March 2020, Suuchi decided to sell Personal Protective Equipment (PPE) on a commission basis due to the COVID-19 pandemic. Musker generated approximately $34,448,900 in gross revenue by selling PPE. The parties disputed whether her 4% commission was based on gross or net revenue and whether these commissions were considered "wages" under the Wage Payment Law (WPL) or excluded as "supplementary incentives."The trial judge dismissed Musker’s WPL claims, holding that her PPE commissions were not "wages" under the WPL. The Appellate Division affirmed this decision, agreeing that the commissions were "supplementary incentives" and not "wages" under the WPL. Musker appealed the decision.The Supreme Court of New Jersey reviewed the case. The Court held that under the WPL, "wages" are defined as "direct monetary compensation for labor or services rendered by an employee, where the amount is determined on a time, task, piece, or commission basis." The Court concluded that compensating an employee by paying a "commission" for "labor or services" always constitutes a wage under the WPL. Therefore, a "commission" cannot be excluded from the definition of "wages" as a "supplementary incentive."The Supreme Court of New Jersey reversed the Appellate Division’s judgment, vacated the trial judge’s order dismissing Musker’s WPL claims, and remanded the case for further proceedings. The Court clarified that Musker’s PPE commissions are "wages" under the WPL, regardless of whether they are based on gross or net revenue, and that receiving a base salary does not turn "commissions" into "supplementary incentives." View "Musker v. Suuchi, Inc." on Justia Law

Three former employees of Amazon filed a class action complaint seeking payment for straight-time and overtime wages under Connecticut’s wage laws for time spent undergoing mandatory security screenings after clocking out. The employees argued that this time should be compensable under state law. Amazon required employees to pass through security screenings when exiting the secured area of their fulfillment centers, but not upon entry. The screenings involved metal detectors and varied based on the personal belongings employees carried. Employees were not compensated for the time spent in these screenings.The United States District Court for the District of Connecticut granted summary judgment in favor of Amazon, dismissing the employees' complaint. The court relied on the United States Supreme Court’s decision in Integrity Staffing Solutions, Inc. v. Busk, which held that time spent in mandatory security screenings is not compensable under federal law. The employees appealed the decision and moved to certify a question to the Connecticut Supreme Court regarding the applicability of Connecticut’s wage laws to their case.The United States Court of Appeals for the Second Circuit reviewed the case and determined that the question of whether Connecticut’s wage laws require compensation for time spent in mandatory security screenings is unresolved. The court decided to certify this question to the Connecticut Supreme Court for a definitive resolution. Additionally, the court asked the Connecticut Supreme Court to address whether a de minimis exception applies to such compensable time and, if so, what amount of time is considered de minimis. The Second Circuit reserved its decision and dismissed the employees' motion to certify as moot, pending the Connecticut Supreme Court's response. View "Del Rio v. Amazon.com.DECE, LLC" on Justia Law

The plaintiff, Matthew Theisz, was assaulted by an MBTA bus driver with a known history of anger management issues and prior violent incidents. The MBTA had hired, promoted, and retained the driver despite his problematic behavior, including a previous assault on a passenger and an arrest following a confrontation with a police officer. On the day of the incident, Theisz, lost and frustrated, attempted to get the driver's attention, leading to a violent altercation where the driver severely beat him, resulting in a traumatic brain injury.The Superior Court denied the MBTA's motion for summary judgment, which argued that it was immune from liability under the Massachusetts Tort Claims Act (MTCA), specifically G. L. c. 258, § 10 (j). The MBTA contended that the claim was based on a failure to prevent harm by a third person. The Appeals Court affirmed the denial, and the MBTA sought further appellate review.The Supreme Judicial Court of Massachusetts reviewed the case and concluded that § 10 (j) does not provide immunity to the MBTA for its own negligence in hiring, promoting, retaining, and supervising the bus driver. The court held that the MBTA's affirmative act of placing the driver in a public-facing position, despite his known violent tendencies, materially contributed to the harm suffered by Theisz. The court also reaffirmed that § 10 (c) of the MTCA, which provides immunity for intentional torts, does not shield the MBTA from liability for its own negligent supervision and retention of the driver. The court affirmed the denial of summary judgment and remanded the case for further proceedings. View "Theisz v. Massachusetts Bay Transportation Authority" on Justia Law