Justia Labor & Employment Law Opinion Summaries

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

Plaintiffs, employees of a hospital operated by Alameda Health System (AHS), alleged that AHS violated California labor laws by denying meal and rest breaks, failing to keep accurate payroll records, and not paying full wages. They sought civil penalties under the Labor Code Private Attorneys General Act of 2004 (PAGA).The Alameda County Superior Court sustained AHS’s demurrer without leave to amend, concluding that AHS, as a public entity, was not subject to the Labor Code provisions cited by plaintiffs. The court also dismissed the PAGA claim, reasoning that public entities are not “persons” subject to PAGA penalties.The California Court of Appeal reversed in part, holding that AHS was not exempt from the meal and rest break requirements or the wage payment statutes. It distinguished AHS from state agencies, noting that the enabling statute indicated AHS was not an agency, division, or department of the county. However, the court agreed that AHS was exempt from the wage statement requirements and that it was not a “person” subject to default PAGA penalties.The California Supreme Court reversed the Court of Appeal’s judgment. It held that the Legislature intended to exempt public employers, including hospital authorities like AHS, from the Labor Code provisions governing meal and rest breaks and related wage payment statutes. The Court also concluded that public entities are not subject to PAGA penalties for the violations alleged. The case was remanded to the trial court to reinstate its ruling on the demurrer and conduct any further proceedings as appropriate. View "Stone v. Alameda Health System" on Justia Law

The case involves an unfair labor practice dispute between Rieth-Riley Construction Co., a highway construction contractor in Michigan, and Local 324, International Union of Operating Engineers, AFL-CIO. The dispute centers on subcontracting and employee wages. The last collective-bargaining agreement expired on May 31, 2018, and despite multiple bargaining sessions, no successor agreement has been reached. The Union went on strike on July 31, 2019, and picketing incidents ensued, including an altercation where a striking union member, Michael Feighner, assaulted a truck driver, Karl Grinstern.The National Labor Relations Board (NLRB) General Counsel issued complaints against both parties: against the Union for picketing misconduct and against Rieth-Riley for failing to provide requested subcontracting and employee information. An Administrative Law Judge (ALJ) found that Rieth-Riley violated the National Labor Relations Act (NLRA) by not providing the requested information and that the Union violated the NLRA when Feighner assaulted Grinstern. The ALJ ordered Rieth-Riley to provide the requested information and the Union to cease and desist from such misconduct. The NLRB affirmed the ALJ’s decision with a slight modification.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that President Biden lawfully removed the NLRB General Counsel, and the General Counsel had unreviewable prosecutorial discretion. The court found substantial evidence supporting the ALJ’s conclusions that the requested information was relevant to the Union’s bargaining responsibilities and that Rieth-Riley’s refusal to provide it violated the NLRA. The court also upheld the finding that the Union’s assault on Grinstern was an unfair labor practice. The court denied Rieth-Riley’s petition for review and granted the NLRB’s cross-application for enforcement of its order in full. View "Rieth-Riley Construction Co. v. National Labor Relations Board" on Justia Law

Three licensed substance use disorder professionals, referred to as the Counselors, were employed by NCG Acquisition, LLC and NCG CARE, Inc. They allege that they were wrongfully terminated after attempting to ensure a client received appropriate care. The Counselors had recommended that a client in severe distress be moved to inpatient treatment, but their supervisor, Jessica Tewell, altered their recommendation, preventing the client from receiving the necessary care. The client subsequently died of a drug overdose. The Counselors reported their concerns internally and were terminated shortly thereafter.The Counselors filed a lawsuit in the Western District of North Carolina, claiming wrongful termination in violation of public policy under the North Carolina Substance Use Disorder Professional Practice Act (SUDPPA) and its regulations. The district court dismissed their complaint, concluding that while SUDPPA constitutes an expression of public policy, the Counselors failed to allege a plausible claim that their termination contravened specific SUDPPA regulations.The United States Court of Appeals for the Fourth Circuit reviewed the case. The court found that SUDPPA and its regulations indeed represent the public policy of North Carolina. The Counselors plausibly alleged that their termination was in retaliation for actions taken in compliance with their professional obligations under SUDPPA, such as protecting client welfare and maintaining accurate records. The court concluded that the Counselors' actions were consistent with their professional duties and that their termination violated the public policy of North Carolina. Consequently, the Fourth Circuit reversed the district court's dismissal and remanded the case for further proceedings. View "Shook v. NCG Acquisition, LLC" on Justia Law

Samuel Hickman was electrocuted while working on a construction site when a boom crane contacted overhead power lines. Hickman and his wife filed a personal injury lawsuit against Boomers, LLC, its owner Michael Landon, and employee Colter James Johnson, alleging negligence and recklessness. Boomers moved for summary judgment, claiming immunity under Idaho’s Worker’s Compensation Law. Hickman argued that the accident fell under the “willful or unprovoked physical aggression” exception to the exclusive remedy rule. The district court granted summary judgment for Boomers and denied Hickman’s motion for reconsideration.The district court applied the 2020 amended version of Idaho Code section 72-209(3), which clarified the “willful or unprovoked physical aggression” exception, and concluded that Boomers did not intend to harm Hickman or have actual knowledge that injury was substantially likely. Hickman appealed, arguing that the district court should have applied the pre-amendment version of the statute and the standard from Gomez v. Crookham Co., which interpreted the exception to include conscious disregard of knowledge that an injury would result.The Supreme Court of Idaho reversed the district court’s decision, holding that the pre-amendment version of section 72-209(3) and the Gomez standard should apply. The court found that the additional evidence submitted by Hickman in his motion for reconsideration created a genuine issue of material fact regarding whether Johnson consciously disregarded the known risk of injury from the power lines. The case was remanded for further proceedings consistent with this opinion. View "Hickman v. Boomers, LLC" on Justia Law

In two separate cases, employees Terry J. Leal and Dustin Kopp sought workers' compensation benefits for injuries they claimed were work-related. Ms. Leal's claim involved a right shoulder injury, while Mr. Kopp's claim involved an abdominal hernia. Both claims were initially denied by the Wyoming Department of Workforce Services, Workers’ Compensation Division, which concluded that the injuries were not caused by their work activities. The employees contested these decisions, leading to hearings before the Office of Administrative Hearings (OAH).In both cases, the OAH appointed attorneys to represent the employees. These attorneys hired medical experts to testify on the causation of the injuries. Ms. Leal's attorney hired Dr. Gregory Reichhardt, and Mr. Kopp's attorney hired Dr. Douglas Adler. The OAH found in favor of the employees, awarding them workers' compensation benefits. However, when the attorneys sought reimbursement for the medical expert fees, the OAH denied these requests, citing a lack of statutory authority under the Wyoming Worker’s Compensation Act to order such reimbursements.The employees appealed to the District Court of Laramie County, which certified the cases to the Wyoming Supreme Court. The Wyoming Supreme Court reviewed whether the OAH had the authority to order reimbursement of medical expert fees. The Court concluded that the OAH does have such authority. It reasoned that the Wyoming Worker’s Compensation Act, when read as a whole, provides for the payment of costs, including expert witness fees, to ensure the quick and efficient delivery of benefits to injured workers at a reasonable cost to employers. The Court found that the OAH's decision to deny reimbursement was not in accordance with the law and reversed the OAH's decision. View "Leal v. State of Wyoming, ex rel. Department of Workforce Services" on Justia Law