Justia Labor & Employment Law Opinion Summaries

John Smith, an employee of Sysco Indianapolis, LLC, did not receive a monthly benefit check he expected. His labor union, Teamsters Local 135, filed a grievance on his behalf, alleging that Sysco violated their 2018 collective bargaining agreement (CBA) by not providing a $500 Supplemental Early Retirement Benefit (SERB) to certain retirees and employees. Sysco participated in the initial grievance process but refused to proceed to arbitration, arguing that the grievance was not arbitrable under the CBA. Sysco then sought a declaratory judgment from the district court, while the Union counterclaimed for a declaration that the grievance was arbitrable.The United States District Court for the Southern District of Indiana sided with Sysco, finding that the monthly benefit was governed by terms outside the CBA and that the parties' bargaining history indicated they did not intend for the benefit to be arbitrable. The court granted Sysco's motion for summary judgment and denied the Union's counterclaims.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo and reached a different conclusion. The appellate court found that Sysco failed to present the "most forceful evidence" required to exclude the monthly benefit from the arbitration provision in the CBA. The court noted that the grievance fell within the scope of the arbitration clause on its face and that the CBA did not explicitly exclude the SERB from arbitration. The court also found that the parties' bargaining history did not clearly demonstrate an intent to exclude the benefit from arbitration. Consequently, the Seventh Circuit reversed the district court's judgment, holding that the grievance must be sent to arbitration. View "Sysco Indianapolis LLC v. Teamsters Local 135" on Justia Law

Covenant Construction Services, LLC was the prime contractor on a federal construction project for a U.S. Department of Veterans Affairs facility in Iowa City, Iowa. Covenant subcontracted with Calacci Construction Company, Inc. to supply carpentry labor and materials. Calacci had a collective bargaining agreement (CBA) with two regional unions, requiring it to pay fringe-benefit contributions to the Five Rivers Carpenters Health and Welfare Fund and Education Trust Fund (the Funds). Despite multiple demands, Calacci failed to remit the required contributions.The Funds filed a lawsuit under the Miller Act to collect the unpaid contributions, liquidated damages, interest, costs, and attorneys' fees from Covenant and its surety, North American Specialty Insurance Company. The United States District Court for the Southern District of Iowa granted summary judgment in favor of the Funds, concluding that the Funds had standing to sue and that the Miller Act notice was properly served and timely.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court's decision, holding that the Funds sufficiently complied with the Miller Act's notice requirements by sending the notice to Covenant's attorney, who confirmed receipt. The court also held that the notice was timely as it was filed within 90 days of the last day of labor on the project. Additionally, the court upheld the award of liquidated damages and attorneys' fees, finding that the CBA obligated Calacci to pay these amounts and that Covenant, as the prime contractor, was liable for the amounts due under the payment bond.The Eighth Circuit concluded that the Funds were entitled to recover the unpaid contributions, liquidated damages, and attorneys' fees from Covenant and its surety, affirming the district court's judgment. View "Five Rivers Carpenters v. Covenant Construction Services" on Justia Law

Rebecca Adeyanju, a White woman, was employed by Foot and Ankle Associates of Maine, P.A. as a medical assistant and radiology technician since 2012. In 2018, she married a Black man from Nigeria. In August 2019, Adeyanju missed three consecutive workdays to assist her husband, who was being sought by ICE agents. She informed her employer of her absences via text messages. Upon returning to work, she was terminated for "job abandonment" due to her three-day absence.The Superior Court (Cumberland County) granted summary judgment in favor of Foot and Ankle Associates, concluding that Adeyanju failed to show sufficient evidence that her termination was motivated by discriminatory animus or that the stated reason for her termination was pretextual. Adeyanju appealed the decision.The Maine Supreme Judicial Court reviewed the case de novo. The court found that the summary judgment record, viewed in the light most favorable to Adeyanju, revealed genuine issues of material fact. These included inconsistencies in the employer's enforcement of its attendance policy, differential treatment of employees with similar absences, and potential racial animus linked to the involvement of ICE. The court concluded that these issues warranted a trial to determine whether the termination was indeed motivated by discriminatory animus or if the employer's stated reason was pretextual.The Maine Supreme Judicial Court vacated the summary judgment and remanded the case for trial, allowing Adeyanju to present her claims of employment discrimination under Title VII and 42 U.S.C. § 1981. View "Adeyanju v. Foot and Ankle Associates of Maine, P.A." on Justia Law

Joel M. Guy, Jr. murdered his parents in 2016 with the intent to collect the proceeds from his mother’s insurance plans. His mother had life insurance and accidental death and dismemberment insurance through her employer, naming Guy and his father as beneficiaries. Guy was convicted of first-degree premeditated murder, felony murder, and abuse of a corpse by a Tennessee jury.The United States District Court for the Eastern District of Tennessee determined that Guy would be entitled to the insurance proceeds if not disqualified. However, the court ruled that Guy was disqualified under Tennessee’s slayer statute or federal common law, which prevents a murderer from benefiting from their crime. The court granted summary judgment in favor of Guy’s family members, who argued that Guy was not entitled to the benefits. Guy appealed, arguing that ERISA preempts Tennessee’s slayer statute and that no federal common-law slayer rule applies.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that ERISA does not explicitly address the issue of a beneficiary who murders the insured, and thus, either Tennessee law or federal common law must apply. The court found that both Tennessee’s slayer statute and federal common law would disqualify Guy from receiving the insurance proceeds. The court affirmed the district court’s decision, concluding that Guy’s actions disqualified him from benefiting from his mother’s insurance plans under both state and federal law. View "Standard Insurance Co. v. Guy" on Justia Law

The case involves Jose Ageo Luna Vanegas, a guestworker employed by Signet Builders, Inc., who alleges that Signet overworked and underpaid him in violation of the Fair Labor Standards Act (FLSA). Signet, incorporated and headquartered in Texas, hires H-2A visa holders for agricultural work, which it claims exempts them from FLSA overtime pay requirements. Luna Vanegas, who built livestock structures in multiple states including Wisconsin, filed a collective action against Signet in the Western District of Wisconsin, seeking to represent similarly situated workers.The district court initially dismissed the case, citing the FLSA’s agricultural exemption, but the United States Court of Appeals for the Seventh Circuit reversed that decision. Luna Vanegas then moved for conditional certification to notify other Signet workers nationwide about the collective action. Signet argued that the notice should be limited to workers in Wisconsin, asserting that the court only had specific jurisdiction over claims from that state. The district court allowed nationwide notice but certified the question of whether specific jurisdiction is required for each opt-in plaintiff’s claim. The district court held that such jurisdiction was not required, leading to this interlocutory appeal.The United States Court of Appeals for the Seventh Circuit reversed the district court’s decision. The court held that in FLSA collective actions, personal jurisdiction must be established for each plaintiff’s claim individually, whether representative or opt-in. The court rejected the argument that Federal Rule of Civil Procedure 4 could be used to establish nationwide personal jurisdiction in FLSA cases. The court concluded that the district court’s personal jurisdiction is limited to claims that fall within Wisconsin’s specific jurisdiction, and any expansion of jurisdiction would require new Rule 4 service. The case was reversed and remanded for further proceedings consistent with this holding. View "Ageo Luna Vanegas v. Signet Builders, Inc." on Justia Law

Patricia Wright was employed by the Public Service Commission of Yazoo City (PSC) from August 2014 until November 2018, when she was terminated for allegedly falsifying documentation regarding reconnecting a customer for non-payment. Wright appealed her termination to the PSC Board, which upheld the decision. Subsequently, Wright filed a lawsuit against the PSC and its general manager, Richie Moore, claiming her termination was in retaliation for refusing to participate in illegal activities. She sought lost wages, benefits, compensatory damages, punitive damages, and costs.The Yazoo County Circuit Court denied the PSC's motion for summary judgment, finding that there was a genuine issue of material fact regarding the reason for Wright's termination. The trial judge noted that the question of whether Wright understood what falsifying documents entailed and whether she was asked to do so was a matter for the jury to decide. The PSC then filed a petition for interlocutory appeal, arguing that Wright failed to identify any illegal activity by her supervisor that could lead to criminal penalties.The Supreme Court of Mississippi reviewed the case and reversed the trial court's denial of summary judgment. The Court held that Wright failed to provide sufficient evidence that her supervisor's actions constituted illegal activities warranting criminal penalties. Wright's deposition revealed that she did not refuse to participate in any specific illegal act as required under the public policy exception to the employment at will doctrine. Consequently, the Court rendered judgment in favor of the PSC, concluding that Wright did not meet her burden of showing a genuine issue of material fact regarding her wrongful termination claim. View "Public Service Commission of Yazoo City v. Wright" on Justia Law

The plaintiff, Lupe Stratton, worked at Bentley University from August 2016 to July 2018. She alleged that her supervisors discriminated against her based on her gender, race, disability, and Guatemalan origin. After she complained to Bentley's human resources department, she was placed on a performance improvement plan, which she claimed was retaliatory. Stratton also contended that Bentley interfered with her right to medical leave and failed to provide reasonable accommodations for her disability. She resigned, claiming her workplace had become intolerable.The United States District Court for the District of Massachusetts granted summary judgment in favor of Bentley University on all of Stratton's claims. The court found that Stratton did not suffer an adverse employment action that could support her discrimination claims and that her retaliation claims failed because she could not establish a causal connection between her complaints and the adverse actions. The court also held that Bentley had provided reasonable accommodations for Stratton's disability and had not interfered with her FMLA rights.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court agreed that Stratton did not experience an adverse employment action that could support her discrimination claims, as her working conditions were not so intolerable as to constitute a constructive discharge. The court also found that Stratton's retaliation claims failed because she could not show that her complaints were the but-for cause of the adverse actions. Additionally, the court held that Bentley had provided reasonable accommodations for Stratton's disability and had not interfered with her FMLA rights. The court clarified the relevant law governing Title VII retaliation claims in the circuit. View "Stratton v. Bentley University" on Justia Law

Next Century Rebar, LLC (NCR) worked on a project in Detroit, Michigan, within the jurisdiction of Local Union Number 25 (Local 25). Due to a shortage of Local 25 iron workers, NCR hired workers from out-of-state unions, Local 416 and Local 846. NCR made benefits contributions to the funds associated with these out-of-state unions. In 2021, Local 25 Funds conducted an audit and found that NCR had not made contributions to the Local 25 Funds for these out-of-state employees. NCR contested this, arguing that it had already made contributions to the out-of-state funds.The Local 25 Funds filed a lawsuit under 29 U.S.C. § 1145, seeking unpaid contributions. The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Local 25 Funds, awarding them $1,787,300.75 in unpaid contributions, $143,075.41 in interest, and $288,598.80 in liquidated damages. The court also awarded $18,233.15 in costs and $99,812.25 in attorney fees. NCR appealed, arguing that the district court applied the wrong summary-judgment standard, improperly granted summary judgment despite genuine disputes of material fact, and abused its discretion by not awarding a setoff for contributions made to out-of-state funds.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Local 25 CBA required contributions based on the specific employee’s gross earnings for the vacation fund and base wages for the pension fund. However, it was unclear whether the audit used the correct wage rates. The court also found that the Local 25 Funds' request for contributions violated the International Agreement’s prohibition on double payments. Consequently, the court affirmed the district court’s decision in part, reversed it in part, and remanded the case for further proceedings. View "Trustees of Iron Workers Defined Contribution Pension Fund v. Next Century Rebar, LLC" on Justia Law

Krishna P. Sharma Poudel and Binod Dhakal worked as Nepalese-English interpreters for Mid Atlantic Professionals, Inc. (MAPI), serving the U.S. Department of State in Kabul, Afghanistan. They alleged that MAPI failed to pay them all contracted-for and promised wages, including overtime, per diem allowances, and reimbursement for annual trips home. Their employment agreements, executed in Maryland, included a choice-of-law provision specifying Maryland law.The plaintiffs filed their complaint in the United States District Court for the District of Maryland, asserting violations of the Maryland Wage and Hour Law (MWHL) and the Maryland Wage Payment and Collection Law (MWPCL). MAPI moved to dismiss the complaint, arguing that Maryland’s Wage Laws do not apply extraterritorially, and since the plaintiffs performed no work in Maryland, their claims were barred. The district court granted MAPI’s motion to dismiss, holding that the Wage Laws lacked an express extraterritorial provision and that the plaintiffs did not perform any work in Maryland.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The appellate court affirmed the district court’s dismissal, agreeing that Maryland’s Wage Laws do not apply extraterritorially without some work being performed in Maryland. The court also rejected the plaintiffs’ argument that the choice-of-law provision in their employment agreements allowed them to bring claims under Maryland’s Wage Laws, noting that Maryland precedent does not support such an extension. The court concluded that the plaintiffs could not maintain their claims under the Wage Laws because they did not perform any work in Maryland. View "Poudel v. Mid Atlantic Professionals, Inc." on Justia Law

Ryan Haygood, a dentist in Louisiana, faced an investigation by the Louisiana State Board of Dentistry, which led to the revocation of his dental license in 2010. Haygood alleged that competing dentists conspired with Board members to drive him out of business by fabricating complaints and manipulating the Board's proceedings. In 2012, a Louisiana appellate court vacated the Board's revocation of Haygood's license, citing due process violations. Haygood then entered a consent decree with the Board, allowing him to keep his license.Haygood filed a civil action in state court in 2011, alleging due process violations and unfair competition. In 2013, he filed a similar federal lawsuit, claiming violations under 42 U.S.C. § 1983 and the Louisiana Unfair Trade Practices Act (LUTPA). The federal district court dismissed the federal complaint, ruling that the § 1983 claim was time-barred and the LUTPA claim was not plausible. The court also awarded attorney’s fees to the defendants, deeming both claims frivolous.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court's decision to award attorney’s fees for the frivolous § 1983 claim, agreeing that it was clearly time-barred. However, the appellate court found that the district court erred in calculating the fee amount. The district court had properly calculated $98,666.50 for the defendants' private attorneys but improperly awarded $11,594.66 for the Louisiana Attorney General’s office without using the lodestar method. Consequently, the Fifth Circuit remitted the fee award to $98,666.50 while affirming the decision to award fees. View "Haygood v. Morrison" on Justia Law