Justia Labor & Employment Law Opinion Summaries

The plaintiff, Guillermo Gray, sued Killick Group, L.L.C. for wages and overtime pay under the Fair Labor Standards Act (FLSA). Gray, an experienced welding and coding inspector, performed inspection services for Killick on a project-by-project basis through his own company, Veritas Inspectors, Inc. He used his own equipment and submitted invoices under his business name. In a previous criminal court proceeding, Gray had sworn that he was self-employed to obtain an essential-need license after a DWI conviction.The United States District Court for the Southern District of Texas granted summary judgment to Killick, holding that Gray was judicially estopped from claiming employee status under the FLSA due to his prior sworn statement of being self-employed. The court also dismissed Gray’s breach of contract and quantum meruit claims. Gray appealed, seeking reversal only on the FLSA claim.The United States Court of Appeals for the Fifth Circuit affirmed the district court’s decision. The appellate court reviewed the use of judicial estoppel for abuse of discretion and found that Gray’s previous self-employed statement was inconsistent with his current claim of being an employee. However, the court chose to resolve the appeal by determining whether Gray was an employee under the FLSA. Applying the economic-realities test, the court concluded that Gray was an independent contractor. The court considered factors such as Gray’s control over his work, his investment in his business, his ability to profit, the skill required for his job, and the project-based nature of his work. All factors supported the conclusion that Gray was not economically dependent on Killick and was thus an independent contractor, not an employee under the FLSA. The court affirmed the summary judgment in favor of Killick. View "Gray v. Killick Group" on Justia Law

Meng Huang, a former Ph.D. student at The Ohio State University (OSU), alleged that her advisor, Professor Giorgio Rizzoni, sexually harassed and assaulted her during her studies. Huang filed a lawsuit against OSU and Rizzoni, claiming Title VII quid pro quo sexual harassment and retaliation against OSU, and a due process violation against Rizzoni under 42 U.S.C. § 1983.The United States District Court for the Southern District of Ohio granted summary judgment to OSU on Huang’s Title VII claims, concluding she was not an "employee" under Title VII until August 2017. The court also ruled that Huang’s retaliation claim failed because her first protected activity occurred after the alleged adverse actions. Huang’s § 1983 claim against Rizzoni proceeded to trial, where the court trifurcated the trial and excluded evidence of Rizzoni’s alleged manipulation and coercion. The jury found in favor of Rizzoni.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the district court erred in determining Huang was not an employee under Title VII before August 2017, as her research work and the control Rizzoni exerted over her indicated an employment relationship. The court also held that Huang’s resistance to Rizzoni’s advances constituted protected activity under Title VII, and she presented sufficient evidence of adverse employment actions linked to her resistance.The Sixth Circuit reversed the district court’s summary judgment on Huang’s Title VII claims, vacated the trial verdict in favor of Rizzoni on the § 1983 claim, and remanded for a new trial. The court emphasized that the district court’s exclusion of relevant evidence regarding Rizzoni’s power and manipulation was an abuse of discretion, which prejudiced Huang’s ability to present her case. View "Huang v. Ohio State University" on Justia Law

Raymond Black, a skilled mechanic at Swift Pork Company, was responsible for operating and fixing the loin-puller machine. He frequently took FMLA leave to care for his wife, who had severe cardiovascular disease. After returning to work from a bout of pneumonia, Black was reassigned to a different task, which led to a dispute with his supervisor. Black requested vacation time, which was denied, and then opted for FMLA leave to care for his sick wife. He was subsequently fired after a meeting with the human-resources director and plant manager.The United States District Court for the Southern District of Iowa granted summary judgment in favor of Swift Pork Company on both of Black's FMLA claims—interference and discrimination. Black then appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court found that there was sufficient evidence to create a jury question on whether Black's FMLA leave was medically necessary and whether Swift interfered with his FMLA rights by not crediting his absences and firing him. Therefore, the court reversed the summary judgment on the interference claim and remanded it for further proceedings.However, the court affirmed the summary judgment on the discrimination claim. The court concluded that there was no evidence that Swift fired Black because he took FMLA leave, especially given his extensive history of taking FMLA leave without repercussions. Negative comments from supervisors who did not make the termination decision were insufficient to establish a discriminatory motive.In summary, the Eighth Circuit reversed and remanded the interference claim but affirmed the dismissal of the discrimination claim. View "Black v. Swift Pork Company" on Justia Law

The case involves a dispute between the Boston Teachers Union, Local 66, American Federation of Teachers, AFL-CIO (the union), and the School Committee of Boston (the committee). The union alleged that the committee failed to hire eighteen "cluster" paraprofessional substitutes as required by their collective bargaining agreement. An arbitrator sustained the union's grievance in July 2020 and ordered the committee to comply with the hiring requirement. The committee did not seek to vacate or modify the award. Nineteen months later, the union sought judicial confirmation of the arbitration award, which the committee opposed, claiming substantial compliance.In the Superior Court, the union filed a complaint to confirm the arbitration award and moved for judgment on the pleadings. The committee responded with a motion to dismiss for failure to state a claim. The Superior Court judge granted the committee's motion to dismiss and denied the union's motion, reasoning that there was no statutory right to confirmation when no dispute was alleged.The Supreme Judicial Court of Massachusetts reviewed the case. The court held that under General Laws c. 150C, § 10, the Superior Court is required to confirm an arbitration award upon application by a party unless a timely motion to vacate or modify the award has been made. The court emphasized that the statute's language is clear and mandatory, stating that the Superior Court "shall" confirm the award if no such motion is pending. The court rejected the committee's argument that confirmation should be discretionary and noted that the purpose of § 10 is to enforce arbitration awards.The Supreme Judicial Court reversed the Superior Court's order, granting the committee's motion to dismiss and denying the union's motion for judgment on the pleadings. The court ordered that the arbitration award be confirmed. View "Boston Teachers Union, Local 66, American Federation of Teachers, AFL-CIO v. School Committee of Boston" on Justia Law

In August 2020, Kimberly Strable, who was under 18, inquired about a managerial position at Arby’s in Great Falls but was told she could not apply due to her age. Strable filed an age discrimination claim with the Montana Human Rights Bureau (HRB), which issued a reasonable cause determination. The parties entered into a conciliation process, and Strable’s attorney and Arby’s attorney reached an agreement in principle for a $25,000 settlement, subject to a mutually agreeable settlement agreement. However, the parties did not finalize or sign the draft conciliation agreement, which included affirmative relief provisions required by the HRB.The First Judicial District Court, Lewis and Clark County, granted summary judgment in favor of Arby’s, finding that no enforceable contract existed between the parties. The court noted that the negotiations were part of an ongoing HRB case and that Arby’s had not consented to the affirmative relief provisions, which were essential terms of the conciliation agreement.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decision. The court held that the essential element of consent was lacking because the parties had not agreed on all essential terms, including the HRB’s affirmative relief provisions. The court emphasized that a binding contract requires mutual consent on all essential terms, and in this case, Arby’s could not consent to terms it was unaware of. Therefore, the court concluded that no enforceable contract existed, and summary judgment in favor of Arby’s was appropriate. View "Strable v. Carisch" on Justia Law

Marlo Spaeth, an individual with Down syndrome, was employed by Wal-Mart for over 15 years. Her work schedule was changed from 12:00 p.m. to 4:00 p.m. to 1:00 p.m. to 5:30 p.m., causing her significant difficulty in adapting due to her disability. Despite requests from Spaeth and her sister to revert to her original schedule, Wal-Mart did not accommodate her, leading to her termination for attendance issues. The Equal Employment Opportunity Commission (EEOC) filed a lawsuit on Spaeth’s behalf under the Americans with Disabilities Act (ADA), alleging failure to accommodate her disability.The United States District Court for the Eastern District of Wisconsin held a jury trial, which resulted in a verdict in favor of the EEOC. The jury awarded Spaeth $150,000 in compensatory damages and $125 million in punitive damages, which the court reduced to $150,000 to comply with the ADA’s damages cap. The court also awarded backpay, prejudgment interest, and compensation for tax consequences, totaling $419,662.59. However, the district court denied the EEOC’s requests for broader injunctive relief, ordering only Spaeth’s reinstatement and communication with her guardian regarding future issues.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court affirmed the jury’s findings on liability and the awards of compensatory and punitive damages. It held that Wal-Mart was aware of Spaeth’s need for a schedule accommodation due to her Down syndrome and failed to engage in the interactive process required by the ADA. The court found sufficient evidence to support the jury’s award of punitive damages, noting Wal-Mart’s reckless indifference to Spaeth’s rights. The court also upheld the compensatory damages, finding them rationally related to the evidence of Spaeth’s emotional distress and depression.However, the Seventh Circuit vacated the district court’s denial of broader injunctive relief and remanded for reconsideration. The court noted that the district court had incorrectly characterized all requested injunctive relief as “obey the law” injunctions and failed to consider the possibility of recurring discriminatory conduct. The district court was directed to reassess the need for injunctive measures to prevent future violations. View "EEOC v. Wal-Mart Stores East, L.P." on Justia Law

Darren J. Gray suffered a heart attack while working on a road construction project and applied for workers' compensation benefits. The Wyoming Workers’ Safety and Compensation Division denied his request. After a contested case hearing, the Office of Administrative Hearings also denied the request, and the district court affirmed that decision. Mr. Gray appealed, arguing that his work exertion was unusual or abnormal under Wyoming law.The Office of Administrative Hearings found that Mr. Gray did not meet his burden of proof under Wyo. Stat. Ann. § 27-14-603(b)(ii) to show that his work exertion was unusual or abnormal for his employment. The Hearing Examiner determined that the tasks Mr. Gray performed on the day of his heart attack, including lifting and slamming metal pipes, were consistent with the job duties of similarly-situated employees. The district court affirmed this decision, agreeing that Mr. Gray's exertion was not clearly unusual or abnormal for his type of employment.The Wyoming Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the Hearing Examiner's conclusion was supported by substantial evidence, including job descriptions and testimony from Mr. Gray's supervisor. The court found that the tasks Mr. Gray performed were within the normal scope of his employment duties. The court also noted that the independent medical examiner's testimony did not establish that the exertion was unusual. Therefore, the court concluded that Mr. Gray did not meet the statutory requirements for workers' compensation benefits for his heart attack. View "Gray v. State, Ex Rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

The case involves Ariel Schlosser, who was hired by VRHabilis, LLC (VRH) to perform unexploded ordnance (UXO) remediation. Schlosser, the only female diver, faced several incidents of alleged discrimination and harassment. She was singled out for a knot-tying test, prohibited from diving and driving the company vehicle, and subjected to verbal abuse by her supervisor, Tyler Sanders, and co-worker, Aaron Brouse. Schlosser reported the harassment, but VRH's response was inadequate, leading her to resign after ten weeks.The United States District Court for the Eastern District of Tennessee denied VRH's motion for summary judgment, allowing the case to proceed to trial. After a four-day trial and three days of deliberations, the jury found that Schlosser was subjected to a hostile work environment based on her sex or gender, in violation of Title VII of the Civil Rights Act of 1964. The jury awarded Schlosser $58,170 in back pay. VRH filed a renewed motion for judgment as a matter of law, arguing that the evidence did not support the jury's verdict. The district court denied this motion, holding that the jury could reasonably conclude that Schlosser experienced severe and pervasive harassment based on her gender.The United States Court of Appeals for the Sixth Circuit reviewed the district court's denial of VRH's renewed motion for judgment as a matter of law de novo. The court affirmed the district court's judgment, finding that the jury could reasonably determine that Schlosser was subjected to a hostile work environment based on her sex or gender. The court held that the harassment was severe and pervasive, and that VRH was liable for the actions of Schlosser's supervisor and co-worker. The court emphasized the substantial deference owed to the jury's verdict and concluded that VRH had not overcome this deference. View "Schlosser v. VRHabilis, LLC" on Justia Law

James Moyer and other captive insurance agents sued GEICO, claiming they were misclassified as independent contractors and denied benefits under the Employee Retirement Income Security Act of 1974 (ERISA). They argued that GEICO should have classified them as employees, making them eligible for various benefits plans. The agents did not attach the relevant benefits-plan documents to their complaint, which are integral to their claims.The United States District Court for the Southern District of Ohio ordered the parties to provide the relevant plan documents. GEICO submitted documents it claimed governed the dispute, but the agents argued that the court could not rely on these documents without converting the motion to dismiss into a summary judgment motion and requested additional discovery. The district court disagreed, relied on the documents provided by GEICO, and dismissed the complaint, finding that the agents lacked statutory standing as they were not eligible for the benefits under the plan documents.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that there were legitimate questions about whether GEICO had provided a complete set of the relevant plan documents. The court noted issues with the authenticity and completeness of the documents, including redlines, handwritten notes, and missing pages. The court held that the district court should not have relied on these documents to dismiss the complaint without allowing the agents to conduct discovery. Consequently, the Sixth Circuit reversed the district court's decision and remanded the case for further proceedings. View "Moyer v. GEICO" on Justia Law

Fernando Yates, a math teacher in his late sixties, alleged that Spring Independent School District (Spring ISD) discriminated and retaliated against him based on age, race, national origin, color, and disability. Yates was placed on multiple support plans due to performance concerns, reassigned from his eighth-grade math teaching position to a "push-in" role, and later to a seventh-grade math position before being replaced by a younger teacher. He was also placed on administrative leave following complaints from students and parents. Yates filed a Charge of Discrimination with the EEOC and later a lawsuit against Spring ISD.The United States District Court for the Southern District of Texas granted summary judgment in favor of Spring ISD. The court concluded that the actions taken against Yates did not constitute adverse employment actions under the pre-Hamilton standard, which required an "ultimate employment decision." The court also found that Yates failed to establish a prima facie case of age discrimination and that Spring ISD provided legitimate, nondiscriminatory reasons for its actions, which Yates could not prove were pretextual.The United States Court of Appeals for the Fifth Circuit reviewed the case and affirmed the district court's decision. The appellate court acknowledged that the district court had applied an outdated standard but still found that Spring ISD had provided legitimate, nondiscriminatory reasons for its actions. The court held that Yates failed to show that these reasons were pretextual. Consequently, the summary judgment in favor of Spring ISD was affirmed. View "Yates v. Spring Independent School District" on Justia Law