Justia Labor & Employment Law Opinion Summaries

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

Mychal Byrd was injured in an automobile accident caused by an unknown motorist and subsequently died from his injuries. Byrd's medical expenses, totaling $474,218.24, were covered by the Gilster-Mary Lee Corporation Group Health Benefit Plan, a self-funded plan subject to ERISA. Byrd had an automobile insurance policy with Nationwide Insurance Company, which provided $50,000 in uninsured-motorist coverage. After Byrd's death, his family sued Nationwide in state court to collect the insurance proceeds. The Plan intervened, removed the case to federal court, and claimed an equitable right to the insurance proceeds.The United States District Court for the Eastern District of Missouri granted summary judgment in favor of the Plan, determining that the Plan was entitled to the insurance proceeds under the plan document. The plaintiffs, initially proceeding pro se, did not respond to the motion for summary judgment. After obtaining counsel, they moved for reconsideration, which the district court denied. The plaintiffs then appealed the decision.The United States Court of Appeals for the Eighth Circuit reviewed the case and concluded that the district court lacked subject-matter jurisdiction. The appellate court determined that the plaintiffs' claim did not fall within the scope of ERISA's civil enforcement provisions because the plaintiffs were neither plan participants nor beneficiaries. Consequently, the claim was not completely preempted by ERISA, and the federal court did not have jurisdiction. The Eighth Circuit vacated the district court's judgment and remanded the case with instructions to return it to Missouri state court. View "Kellum v. Gilster-Mary Lee Corporation Group Health Benefit" on Justia Law

The case involves the Restaurant Law Center and the Texas Restaurant Association challenging a final rule by the Department of Labor (DOL) that restricts when employers can claim a "tip credit" for "tipped employees" under the Fair Labor Standards Act (FLSA). The tip credit allows employers to pay tipped employees a lower hourly wage, assuming tips will make up the difference to meet the minimum wage. The DOL's final rule imposes limits on the amount of non-tip-producing work a tipped employee can perform while still allowing the employer to claim the tip credit.The United States District Court for the Western District of Texas initially denied the plaintiffs' motion for a preliminary injunction, stating they would not suffer irreparable harm. The Fifth Circuit Court of Appeals reversed this decision, finding that the plaintiffs had shown irreparable harm and remanded the case for further consideration. On remand, the district court evaluated the merits and granted summary judgment in favor of the DOL, holding that the final rule was a permissible interpretation of the FLSA under Chevron deference and was neither arbitrary nor capricious.The United States Court of Appeals for the Fifth Circuit reviewed the case and found that the final rule was contrary to the clear statutory text of the FLSA and was arbitrary and capricious. The court held that the FLSA's definition of a "tipped employee" does not support the DOL's restrictions on non-tip-producing work. The court concluded that the final rule improperly focused on the pursuit of tips rather than the duties of the occupation itself. Consequently, the Fifth Circuit reversed the district court's summary judgment in favor of the DOL, rendered summary judgment for the plaintiffs, and vacated the final rule. View "Restaurant Law Center v. Department of Labor" on Justia Law

The petitioner worked part-time as a bus fueler and washer at Marble Valley Regional Transit (MVRT) for approximately four years. He passed a preemployment drug screen and signed an acknowledgment of MVRT’s drug and alcohol policy, which included random drug testing and termination for a positive drug test. In December 2022, he tested positive for marijuana during a random drug test and was terminated in January 2023 for violating U.S. Department of Transportation and Federal Transit Administration (FTA) regulations. The petitioner had a medical marijuana card issued in early 2020.The petitioner applied for unemployment benefits, which were denied by a claims adjudicator on the grounds of misconduct. He appealed to an administrative law judge (ALJ), who affirmed the denial but reduced the disqualification period to six weeks, recognizing the medical use of cannabis. The petitioner then filed a document with the Employment Security Board, seeking a declaratory ruling on the applicability of the misconduct disqualification provision to off-duty medical cannabis use. The Board treated this as an appeal and affirmed the ALJ’s decision, stating that the petitioner’s actions constituted misconduct under MVRT’s drug policy.The Vermont Supreme Court reviewed the case and affirmed the Board’s decision. The Court held that the Board properly declined to issue a declaratory ruling because the petitioner had an available remedy through a direct appeal. The Court emphasized that declaratory rulings are not a substitute for timely appeals of agency decisions. The petitioner’s appeal of the Board’s decision was dismissed as untimely, and the Court affirmed the Board’s order declining to issue a declaratory ruling. View "Skoric v. Department of Labor" on Justia Law

Amy Rae, a school nurse employed by Woburn Public Schools (WPS), alleged that she faced retaliatory harassment due to her advocacy for students with disabilities and complaints about her own mistreatment. Rae claimed that the harassment, primarily by Kennedy Middle School Principal Carl Nelson, began in 2011 and continued for over a decade. She filed a lawsuit in November 2022, asserting claims under Section 504 of the Rehabilitation Act, Title II of the Americans with Disabilities Act (ADA), Massachusetts's antidiscrimination statute (Chapter 151B), and for intentional infliction of emotional distress.The United States District Court for the District of Massachusetts dismissed Rae's complaint on May 5, 2023, ruling that she failed to state any claims for which relief could be granted. The court found that Rae could not rely on the continuing violations doctrine to save her untimely discrimination claims and dismissed her timely state and federal discrimination claims on other grounds.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court's dismissal de novo. The appellate court agreed that Rae could not invoke the continuing violations doctrine to rescue her time-barred claims, as her allegations included discrete acts of retaliation that accrued separately. The court also affirmed the district court's dismissal of Rae's timely ADA, Section 504, and Chapter 151B claims, concluding that Rae did not plausibly allege severe or pervasive harassment necessary to sustain a retaliatory harassment claim. The court noted that Rae's allegations of two incidents within the actionable period were insufficient to meet the standard for severe or pervasive harassment. Thus, the appellate court affirmed the district court's decision to dismiss Rae's complaint. View "Rae v. Woburn Public Schools" on Justia Law

Alvin Moore, a Black man, worked at Coca-Cola Bottling Company (CCBC) from 2015 to 2018. In March 2017, after a workplace accident, Moore tested positive for marijuana at a level below the company's threshold. Despite this, he signed a Second Chance Agreement (SCA) requiring random drug testing for 24 months. In June 2017, Moore was fired for insubordination but was reinstated under a Last Chance Agreement (LCA), which he signed under pressure. In 2018, Moore tested positive for marijuana again and was terminated. He sued CCBC for racial discrimination and retaliation under Title VII and Ohio law.The United States District Court for the Southern District of Ohio granted summary judgment in favor of CCBC, finding that Moore had waived his pre-LCA claims by signing the LCA and failed to establish that CCBC's reasons for his termination were pretextual. The court presumed Moore had made a prima facie case for racial discrimination and retaliation but concluded that Moore did not show that CCBC's reasons for his termination were a pretext for discrimination.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court found that there was a genuine dispute of material fact regarding whether Moore voluntarily waived his pre-LCA claims by signing the LCA. The court noted that Moore's union representative had advised him to sign the LCA, suggesting he could still pursue his claims. The court also found that Moore had shown enough evidence to suggest that CCBC's reasons for his termination could be pretextual, particularly in light of the different treatment of similarly situated white employees.The Sixth Circuit reversed the district court's summary judgment and remanded the case for further proceedings, allowing Moore to pursue his claims of racial discrimination and retaliation. View "Moore v. Coca-Cola Consolidated, Inc." on Justia Law

The plaintiff, Jose Emilio Ronderos, applied for a job with USF Reddaway, Inc. and Yellow Corporation (collectively, "Reddaway") and was required to sign an arbitration agreement as part of the application process. Ronderos later filed employment-related claims against Reddaway, alleging age and disability discrimination, retaliation, and other violations under California law. Ronderos claimed that the arbitration agreement was procedurally and substantively unconscionable and therefore unenforceable.The United States District Court for the Central District of California denied Reddaway's motion to compel arbitration. The court found that the arbitration agreement was procedurally unconscionable because it was a contract of adhesion presented on a take-it-or-leave-it basis, involved significant oppression, and contained a substantively opaque cost-splitting provision. The court also found that the agreement was substantively unconscionable due to its one-sided filing provision and preliminary injunction carve-out, which unfairly favored Reddaway. The district court declined to sever the unconscionable provisions and enforce the remainder of the agreement.The United States Court of Appeals for the Ninth Circuit affirmed the district court's decision. The appellate court agreed that the arbitration agreement was both procedurally and substantively unconscionable. It held that the agreement involved significant oppression and some surprise, making it procedurally unconscionable. The court also found that the one-sided filing provision and preliminary injunction carve-out were substantively unconscionable. The Ninth Circuit concluded that the district court did not abuse its discretion by declining to sever the unconscionable provisions and affirmed the denial of Reddaway's motion to compel arbitration. View "Ronderos v. USF Reddaway, Inc." on Justia Law

Hunter Smith, a phlebotomist employed by Laboratory Corp of America (Labcorp), sustained a work-related back injury on January 27, 2021, when a shelving unit fell on his head. This incident led to acute lower back injuries requiring surgery. Despite the surgery, Smith continued to experience significant pain and other symptoms. Medical evaluations by Dr. Gregory Lanford and Dr. Jules Barefoot assessed a 24% permanent impairment rating, attributing 19% to the work injury and 5% to pre-existing conditions. Dr. Michael Best, however, disagreed, attributing all of Smith's back issues to pre-existing conditions and assessing a 10% impairment rating.The Administrative Law Judge (ALJ) awarded Smith permanent partial disability (PPD) benefits, accepting Dr. Best's 10% impairment rating but attributing 5% to the work injury. The ALJ also awarded benefits for Smith's psychological condition based on a 20% impairment rating by Dr. Robert Sivley, despite Labcorp's contention that this rating was improperly based on a conditional impairment rating.Labcorp appealed to the Workers’ Compensation Board, arguing that the ALJ improperly relied on Dr. Sivley's rating and should have accepted Dr. Trivette's 0% rating. Smith cross-appealed, arguing that the ALJ misapplied the AMA Guides and should not have admitted Dr. Best's report. The Board affirmed the ALJ's decision, and both parties appealed to the Kentucky Court of Appeals, which also affirmed the Board's decision.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals' decision. The Court held that the ALJ's reliance on Dr. Sivley's impairment rating was justified and that the ALJ's decision was supported by substantial evidence. The Court found no compelling reason to disturb the ALJ's findings, as they were not clearly erroneous. View "LABORATORY CORP. OF AMERICA V. HUNTER SMITH" on Justia Law

Jonathan Hardin, a former Louisville Metro Police Department (LMPD) officer, was terminated after the Chief of Police found he violated four Standard Operating Procedures (SOPs). These violations stemmed from two incidents at a school where Hardin was a resource officer: one involving excessive force against a student and another where he failed to read Miranda rights to a juvenile. Hardin appealed his termination to the Louisville Metro Police Merit Board, which upheld the termination after finding he committed three of the four SOP violations.Hardin then appealed to the Jefferson Circuit Court, arguing that the Merit Board improperly considered expunged materials, violated his due process rights by admitting transcribed witness statements without cross-examination, and wrongfully relied on his arrest and criminal charges without a conviction. The Circuit Court affirmed the Merit Board's decision. Hardin further appealed to the Kentucky Court of Appeals, which also affirmed the Circuit Court's ruling.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals' decision. The Court held that the expungement statute did not apply to the internal employment records of the LMPD's Professional Standards Unit (PSU). It also found that Hardin's due process rights were not violated by the Merit Board's consideration of sworn, transcribed witness statements, as the statutes allowed for such evidence and provided sufficient procedural safeguards, including the right to subpoena witnesses. Lastly, the Court ruled that the Chief's termination of Hardin was not arbitrary, even though it partially relied on his arrest and criminal charges, as there were other independent bases for the termination. View "HARDIN V. LOUISVILLE/JEFFERSON COUNTY METROPOLITAN GOVERNMENT" on Justia Law