Justia Labor & Employment Law Opinion Summaries

Dezmon Moore, a police officer with the Louisville Metro Police Department (LMPD), was terminated after the Chief of Police found he had committed three violations of the department's Standard Operating Procedures (SOPs). These violations stemmed from incidents involving domestic altercations with his wife, Bethel Moore, which led to multiple arrests and charges, including assault and violation of a no-contact order. Moore's criminal charges related to these incidents were eventually dismissed or expunged.Moore appealed his termination to the Louisville Metro Police Merit Board, which upheld the termination after finding he had committed two of the three SOP violations. The Jefferson Circuit Court affirmed the Merit Board's decision, and the Court of Appeals also affirmed, though it noted errors in the Merit Board's consideration of expunged materials and transcribed witness statements without cross-examination. However, the Court of Appeals deemed these errors harmless.The Supreme Court of Kentucky reviewed the case. The Court held that the Merit Board did not violate Moore's statutory or constitutional due process rights by considering transcribed witness statements without live testimony and cross-examination. The Court found that the statutes governing the Merit Board provided sufficient procedural safeguards, including the opportunity for Moore to subpoena witnesses. The Court also determined that the expungement statutes did not apply to the internal employment records of the LMPD's Professional Standards Unit (PSU), and thus, the Merit Board did not err in considering those materials.Finally, the Court held that Moore's termination was not arbitrary, even though it was based on arrests and charges rather than convictions. The Chief's decision was supported by proper evidence, and the Merit Board's affirmation of the termination was justified. The Supreme Court of Kentucky affirmed the decision of the Court of Appeals. View "LOUISVILLE/JEFFERSON COUNTY METROPOLITAN GOVERNMENT V. MOORE" on Justia Law

Sara Caruso, a flight attendant for Delta Air Lines, failed a breathalyzer test on August 4, 2018, after a layover in Dallas, Texas. Caruso claimed she was drugged and sexually assaulted by Delta First Officer James Lucas the night before. The Dallas Police Department found insufficient evidence to support her claim, and Delta also took no action against Lucas after its investigation. Caruso completed an alcohol rehabilitation program and sought accommodations from Delta for PTSD related to the alleged assault. Although Delta and Caruso initially agreed on accommodations, Caruso resigned after a month back at work.Caruso sued Delta in Massachusetts state court, alleging violations of Massachusetts General Laws chapter 151B, Title VII of the Civil Rights Act of 1964, and the Americans with Disabilities Act (ADA). The case was removed to the U.S. District Court for the District of Massachusetts, which granted summary judgment for Delta on all counts. The court found no causal connection between Delta's actions and the alleged harassment and determined that Delta responded reasonably to the allegations. Additionally, Caruso's disability discrimination claims failed because she did not engage in an interactive process in good faith with Delta to develop reasonable accommodations.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The court held that Caruso failed to show a causal connection between Delta's actions and the alleged harassment, and that Delta's investigation and response were reasonable. The court also found that Caruso did not cooperate in the interactive process for her disability accommodations, and her retaliation claims were either waived or undeveloped. Thus, the summary judgment for Delta was affirmed on all counts. View "Caruso v. Delta Air Lines, Inc." on Justia Law

Aimee Sturgill, a registered nurse and devout Christian, objected to the American Red Cross's COVID-19 vaccination mandate, citing her religious beliefs. She requested a religious exemption, explaining that her faith required her to treat her body as a temple and avoid defiling it with the vaccine, which she believed could cause harm due to her blood clotting disorder. The Red Cross denied her request, stating that her objections were medically, not religiously, based and terminated her employment.The United States District Court for the Eastern District of Michigan dismissed Sturgill's complaint under Federal Rule of Civil Procedure 12(b)(6). The court held that she did not plausibly allege a prima facie case for a failure-to-accommodate claim under Title VII of the Civil Rights Act of 1964. The court also concluded that Sturgill did not set forth a separate disparate-treatment claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court erred by requiring Sturgill to establish a prima facie case at the pleading stage, which is not necessary under the plausibility standard set by Twombly and Iqbal. The appellate court found that Sturgill's complaint plausibly alleged that her refusal to take the COVID-19 vaccine was an aspect of her religious observance or belief. However, the court agreed with the district court that Sturgill's complaint did not set forth a standalone disparate-treatment claim. Consequently, the Sixth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. View "Sturgill v. American Red Cross" on Justia Law

Paul Carnes, an employee of Consolidated Grain and Barge Co., was diagnosed with degenerative disc disease in 2019 and received medical treatment for it. HMO Louisiana, Inc., the administrator of Consolidated Grain’s employer-sponsored health plan governed by ERISA, paid for some of Carnes’s treatments but not all. Carnes filed a workers’ compensation claim against his employer, which was settled without the employer accepting responsibility for his medical claims. With an outstanding medical balance of around $190,000, Carnes sued HMO Louisiana, alleging it violated Illinois state insurance law by not paying his medical bills and sought penalties for its alleged "vexatious and unreasonable" conduct.The United States District Court for the Central District of Illinois dismissed Carnes’s complaint on the grounds that his state law insurance claim was preempted by ERISA. The court allowed Carnes to amend his complaint to plead an ERISA claim, but instead, Carnes moved to reconsider the dismissal. The district court denied his motion and ordered the case closed. Carnes then appealed the final order.The United States Court of Appeals for the Seventh Circuit reviewed the case de novo. The court affirmed the district court’s decision, agreeing that Carnes’s state law claim was preempted by ERISA. The court noted that ERISA’s broad preemption clause supersedes any state laws relating to employee benefit plans, and Carnes’s claim fell within this scope. The court also found that ERISA’s saving clause did not apply because the health plan in question was self-funded, making it exempt from state regulation. The court concluded that Carnes’s attempt to frame his suit as a "coordination of benefits dispute" was an impermissible effort to avoid ERISA preemption. Consequently, the court affirmed the dismissal of Carnes’s case. View "Carnes v. HMO Louisiana, Inc." on Justia Law

Two employees, Tanika Parker and Andrew Farrier, participated in 401(k) plans managed by subsidiaries of Tenneco Inc. The plans were amended to include mandatory individual arbitration provisions, which required participants to arbitrate disputes individually and barred representative, class, or collective actions. Parker and Farrier alleged that the fiduciaries of their plans breached their fiduciary duties under ERISA by failing to prudently manage the plans, resulting in higher costs and reduced retirement savings. They sought plan-wide remedies, including restitution of losses and disgorgement of profits.The United States District Court for the Eastern District of Michigan denied the fiduciaries' motion to compel individual arbitration. The court found that the arbitration provisions limited participants' substantive rights under ERISA by eliminating their ability to bring representative actions and seek plan-wide remedies, which are guaranteed by ERISA.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit held that the individual arbitration provisions were unenforceable because they acted as a prospective waiver of the participants' statutory rights and remedies under ERISA. The court emphasized that ERISA allows participants to sue on behalf of a plan and obtain plan-wide relief, and the arbitration provisions' restrictions on representative actions and plan-wide remedies violated these statutory rights. Consequently, the arbitration provisions were invalid, and the district court's judgment was affirmed. View "Parker v. Tenneco, Inc." on Justia Law

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