Justia Labor & Employment Law Opinion Summaries

Sarah Anoke and other employees initiated arbitration proceedings against their employer, X (comprising Twitter, Inc., X Holdings I, Inc., X Holdings Corp., X Corp., and Elon Musk), for employment-related disputes. The arbitration provider issued an invoice for $27,200, which Anoke’s counsel mistakenly paid. The arbitration provider marked the invoice as paid and closed, then refunded the payment and issued a new invoice to X, which X paid within 30 days.Anoke petitioned the Superior Court of the City and County of San Francisco to compel X to pay her arbitration-related attorney fees and costs, arguing that X’s payment was untimely because it was not made within 30 days of the first invoice. The superior court denied the petition, reasoning that since the first invoice was nullified after Anoke’s attorney mistakenly paid it and X timely paid the second invoice, X met the statutory deadline.The California Court of Appeal, First Appellate District, reviewed the case. The court held that the statutory deadline for payment was tied to the due date set by the arbitration provider’s invoice. Since the first invoice was paid (albeit mistakenly) and the second invoice was paid within 30 days, there was no default. The court affirmed the superior court’s order, concluding that the arbitrator acted within its authority by issuing a second invoice and that the statute did not require the arbitrator to reinstate the first invoice after it had been paid and closed. The court also noted that the reasons for a timely payment are irrelevant under the statute. View "Anoke v. Twitter" on Justia Law

In July 1, 2021, the United Electrical, Radio, and Machine Workers of America sought to represent employees of Hudson Institute of Process Research Incorporated, a legal outsourcing and staffing company. The National Labor Relations Board (NLRB) was tasked with determining the appropriate bargaining unit, excluding supervisors. Hudson and the union disagreed on whether certain personnel, including team leads and revision specialists, were supervisors. Hudson also objected to an employer-wide bargaining unit. The NLRB held a hearing in September 2021, where Hudson argued that these personnel had supervisory authority.The NLRB regional director found that Hudson failed to prove that the disputed personnel were supervisors and approved an employer-wide bargaining unit. Hudson appealed to the NLRB, which denied the request for review. An election was conducted, and the union was certified. Hudson refused to bargain, leading the NLRB to find it had committed an unfair labor practice. Hudson then petitioned for review.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court found that the NLRB lacked substantial evidence to support its findings that certain personnel were not supervisors. Specifically, the court determined that I-140 team leads, team lead assistants, floating team lead assistants, RFE team leads, and I-485 team leads possessed supervisory authority, including assigning work and recommending rewards, using independent judgment. The court also upheld the NLRB’s certification of an employer-wide bargaining unit but found that the unit improperly included supervisors.The Fifth Circuit granted Hudson’s petition for review, reversed the NLRB’s bargaining order, and denied enforcement, concluding that Hudson did not violate the National Labor Relations Act by refusing to bargain with the union. View "Hudson Institute of Process Research Incorporated v. NLRB" on Justia Law

Dignity Health, operating as French Hospital Medical Center, filed a complaint against orthopedic surgeon Troy I. Mounts, M.D., and his corporation to recover an advance paid under their Physician Recruitment Agreement. Mounts filed a cross-complaint alleging retaliation for his complaints about patient care quality, interference with his economic opportunities, and unlawful business practices. Dignity responded with an anti-SLAPP motion to strike the cross-complaint, which the trial court initially denied. The appellate court reversed this decision and remanded the case for further consideration.Upon remand, the trial court concluded that Mounts had not demonstrated a probability of prevailing on his claims. The court found that Dignity's actions were protected by the litigation privilege, the common interest privilege, and were barred by the statute of limitations. Consequently, the court granted Dignity's motion to strike the cross-complaint and ordered Mounts to pay Dignity's attorney fees and costs.The California Court of Appeal, Second Appellate District, Division Six, reviewed the case. The court affirmed the trial court's decision, holding that all of Mounts' claims were based on conduct protected by the litigation privilege (Civil Code § 47, subd. (b)) and the common interest privilege (Civil Code § 47, subd. (c)). The court also found that Dignity's actions were immune under federal law (42 U.S.C. § 11137) and that some claims were barred by the statute of limitations. The appellate court upheld the trial court's orders granting the motion to strike and awarding attorney fees to Dignity. View "Dignity Health v. Mounts" on Justia Law

The plaintiff, a manufacturer of resinous flooring systems, sued a former employee, the defendant, for breaching a noncompete agreement, violating the Connecticut Uniform Trade Secrets Act (CUTSA), and breaching a common-law duty of confidentiality. The defendant, who had signed a noncompete agreement as a condition of continued employment, later established his own floor coating business and used the plaintiff’s proprietary information to develop competing products. The plaintiff alleged that the defendant also assisted competitors in developing their products.In a separate but related case, the trial court found the noncompete agreement unenforceable due to lack of consideration and ruled that the common-law duty of confidentiality claim was preempted by CUTSA. The court also determined that a payment made to the defendant after his resignation was severance pay, not compensation for reaffirming the noncompete agreement. Based on these findings, the trial court in the present case granted summary judgment for the defendant, applying collateral estoppel to preclude further consideration of the issues.The Connecticut Supreme Court reviewed the case and concluded that the trial court had incorrectly determined the noncompete agreement was unenforceable for lack of consideration. The Supreme Court reversed the trial court’s judgment on the breach of the noncompete agreement claim and remanded the case for further proceedings to determine whether the agreement was supported by adequate consideration. The court upheld the trial court’s findings that the severance payment was not consideration for reaffirming the noncompete agreement and that the common-law duty of confidentiality claim was preempted by CUTSA. These rulings were binding in the present case. The judgment was reversed in part and affirmed in part, with further proceedings required to determine the enforceability and potential breach of the noncompete agreement. View "Dur-A-Flex, Inc. v. Dy" on Justia Law

Daniel’la Deering, an in-house lawyer for Lockheed Martin, was terminated and subsequently sued the company for discrimination and retaliation. While her discrimination claim was dismissed at the summary judgment stage, her retaliation claim was set to go to trial. However, during the litigation, Deering misled Lockheed Martin and the district court about her employment status and income. She falsely claimed to be employed by nVent and did not disclose her higher-paying job elsewhere, even submitting false information in a deposition, declaration, and settlement letters.The United States District Court for the District of Minnesota, presided over by Judge David S. Doty, found that Deering’s actions constituted intentional, willful, and bad-faith misconduct. Lockheed Martin discovered the deception shortly before the trial, leading to an emergency motion for sanctions. The district court dismissed Deering’s case with prejudice and awarded Lockheed Martin $93,193 in attorney fees. Deering’s motions for a continuance and reconsideration were also denied by the district court.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court did not abuse its discretion in dismissing the case due to Deering’s prolonged and intentional deception. The court emphasized that dismissal was appropriate given the severity and duration of the misconduct. Additionally, the appellate court found no abuse of discretion in the district court’s denial of Deering’s motions for a continuance and reconsideration. However, the appellate court dismissed Deering’s appeal regarding the attorney fee award due to a premature notice of appeal. View "Deering v. Lockheed Martin Corp." on Justia Law

United Scrap Metal PA, LLC (USM) was found by the National Labor Relations Board (NLRB) to have engaged in unfair labor practices during a union organizing campaign. Specifically, USM unlawfully changed employees’ work schedules shortly after a unit of employees elected Laborers’ International Union of North America, Local 57, as their exclusive collective bargaining representative. The NLRB also overruled USM’s objections to the election result and certified the union. Additionally, USM was found to have unlawfully refused to bargain with and provide information to Local 57.The administrative law judge (ALJ) found that USM violated Section 8(a)(1) of the National Labor Relations Act (NLRA) by instructing employees not to accept union organizing material and by confiscating union shirts. The ALJ also found that USM discriminatorily changed its employees’ work schedules after the representation election. USM argued that the changes were due to the economic impact of the COVID-19 pandemic, but the Board found this justification not credible, noting that USM had not cut hours or overtime for most of the pandemic and that the timing of the changes immediately after the election suggested retaliation for union activity.The United States Court of Appeals for the Third Circuit reviewed the case. The court granted the NLRB’s applications for enforcement and denied USM’s cross-petitions for review. The court held that substantial evidence supported the Board’s findings that USM engaged in unfair labor practices and that the union election was conducted fairly. The court also agreed with the Board’s decision to overrule USM’s objections to the election and found that USM’s refusal to bargain with the union violated Sections 8(a)(5) and (1) of the NLRA. The court concluded that the Board’s orders were final and reviewable, and that the Board’s factual determinations were supported by substantial evidence. View "National Labor Relations Board v. United Scrap Metal PA, LLC" on Justia Law

The plaintiffs, all State troopers, filed a lawsuit against the Commonwealth and the heads of the State Police and the State Board of Retirement. They claimed that the defendants' policy of denying the accrual of benefits, such as seniority, length-of-service credit, and vacation and sick time while on leave under the Paid Family and Medical Leave Act (PFMLA), violated the act. Additionally, they argued that the policy discriminated against female employees in violation of other state laws.A Superior Court judge dismissed the portion of the complaint alleging violations of the PFMLA. The judge concluded that the act does not guarantee the accrual of benefits during PFMLA leave. The plaintiffs then sought clarification on the interpretation of the act, and the case was reported to the Appeals Court. The Supreme Judicial Court of Massachusetts transferred the case to itself for review.The Supreme Judicial Court of Massachusetts held that the PFMLA does not require employers to guarantee the accrual of vacation and sick time during an employee's leave. The court interpreted the plain language of the statute, particularly sections 2(e) and 2(f), and concluded that while employees must be restored to their previous position with the same status and benefits upon returning from leave, the act does not mandate the continued accrual of benefits during the leave period. The court affirmed the lower court's dismissal of the PFMLA claims and remanded the case for further proceedings consistent with its opinion. View "Bodge v. Commonwealth" on Justia Law

Two employees sued their employers, alleging underpayment for work at a restaurant due to improper wage deductions for meal breaks. The employers deducted thirty minutes twice daily for breakfast and lunch breaks, but the employees claimed their breaks lasted only ten to fifteen minutes each.The Superior Court of the District of Columbia held a bench trial and found in favor of the employers, concluding that the breaks lasted at least twenty minutes. The court based its decision on the credibility of the employees' testimony and other evidence, including testimony from another employee and the restaurant's rules. The employees appealed, arguing that the trial court's findings were clearly erroneous and that the breaks should have been classified as compensable rest periods.The District of Columbia Court of Appeals reviewed the case and determined that the trial court had clearly erred in its evaluation of the employees' credibility and the evidence. The appellate court noted that the trial court misunderstood key aspects of the employees' testimony and other evidence. Consequently, the appellate court vacated the trial court's judgment and remanded the case for further examination of the evidence.The appellate court did not decide whether the breaks should be classified as rest periods, as this determination depends on the length of the breaks, which the trial court must reassess on remand. The burden of proof remains on the employees to demonstrate that their meal breaks were compensable. View "Sanchez v. Sundely" on Justia Law

Christian Greene, the Ombudsman for the District of Columbia Child & Family Services Agency (CFSA), was terminated from her position and subsequently filed a lawsuit against the District, claiming her termination violated the District of Columbia Whistleblower Protection Act (WPA). Greene argued that her termination was in retaliation for her disclosures about CFSA's non-compliance with the Foster Youth Statements of Rights and Responsibilities Amendment Act of 2012 (FYAA).The Superior Court of the District of Columbia granted summary judgment in favor of CFSA, concluding that Greene's disclosures were merely policy disagreements about the role of the Ombudsman and not protected under the WPA. The court did not address whether Greene reasonably believed her disclosures revealed unlawful activity or whether there was a causal connection between her disclosures and her termination.The District of Columbia Court of Appeals reviewed the case and found that Greene's disclosures were indeed protected under the WPA. The court held that Greene reasonably believed her disclosures revealed violations of the FYAA, which required CFSA to report on the outcomes of investigations and ensure compliance with relevant laws. The court noted that Greene's belief was genuine and reasonable, given the evidence she provided and the context of her role.The Court of Appeals reversed the trial court's grant of summary judgment in part and remanded the case for further proceedings. The trial court was instructed to determine whether there is a genuine dispute of material fact regarding whether Greene's WPA-protected disclosures were a cause of her termination. View "Greene v. D.C. Child & Family Services Agency" on Justia Law

Robert Mayfield, a small-business owner operating thirteen fast-food restaurants in Austin, Texas, challenged the Department of Labor's (DOL) 2019 Minimum Salary Rule. This rule raised the minimum salary required to qualify for the White Collar Exemption under the Fair Labor Standards Act (FLSA) from $455 per week to $684 per week. Mayfield argued that the DOL exceeded its statutory authority by imposing any salary requirement and that such a requirement violated the nondelegation doctrine.The United States District Court for the Western District of Texas granted summary judgment in favor of the DOL, finding that the 2019 Minimum Salary Rule was within the DOL's authority to define and delimit the terms of the White Collar Exemption. The court also held that this delegation of authority did not violate the nondelegation doctrine.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The Fifth Circuit held that the DOL's authority to define and delimit the terms of the White Collar Exemption included the power to set a minimum salary level. The court found that this power was explicitly delegated by Congress and was not an unconstitutional delegation of legislative power. The court also determined that the major questions doctrine did not apply, as the economic and political significance of the rule did not meet the threshold for invoking the doctrine. Additionally, the court concluded that the FLSA's purpose and the text of the exemption itself provided sufficient guidance to satisfy the nondelegation doctrine's requirements. View "Mayfield v. Department of Labor" on Justia Law