Justia Labor & Employment Law Opinion Summaries

Christy Bunker sued Dow Chemical Company in Texas state court, alleging age discrimination and retaliation. Dow removed the case to federal court and filed a motion to dismiss, arguing that Bunker failed to exhaust her administrative remedies before filing suit. The district court granted Dow’s motion, finding that Bunker did not properly request that the Equal Employment Opportunity Commission (EEOC) file her charge with the appropriate state agency, the Texas Workforce Commission (TWC).The United States District Court for the Southern District of Texas dismissed Bunker’s claims under Federal Rule of Civil Procedure 12(b)(6). The court found that Bunker had filed a charge with the EEOC but did not indicate that the charge should also be filed with the TWC. Consequently, the court held that Bunker failed to exhaust her administrative remedies as required under the Texas Commission on Human Rights Act (TCHRA).The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision de novo. The appellate court affirmed the district court’s ruling, holding that Bunker’s failure to indicate on her EEOC charge that it should be filed with the TWC meant she did not meet the TCHRA’s filing requirements. The court noted that both Texas state and federal courts have consistently held that a charge filed with the EEOC must at least indicate that it is to be filed with the TWC to satisfy the TCHRA’s requirements. Therefore, Bunker’s claims were rightfully dismissed with prejudice for failing to exhaust her administrative remedies. View "Bunker v. Dow Chemical" on Justia Law

Five former participants in the Salvation Army's residential rehabilitation program filed a lawsuit alleging that the organization subjected them to forced labor. The plaintiffs, who participated in the program to address issues such as homelessness and substance abuse, were required to work approximately forty hours per week in exchange for food, clothing, and housing. They claimed that the work was not therapeutic but rather a coercive labor arrangement benefiting the Salvation Army financially. The plaintiffs included both individuals who voluntarily enrolled in the program and those referred by courts or parole/probation departments.The United States District Court for the Northern District of Illinois dismissed the plaintiffs' claims. The court found that the justice-referred plaintiffs' claims were barred by the Rooker-Feldman doctrine, as they were allegedly compelled to participate by state court orders. For the walk-in plaintiffs, the court concluded that the threats of losing food, clothing, and shelter were not sufficiently serious to constitute forced labor under federal law. The court also found that the plaintiffs failed to allege that the Salvation Army acted with the requisite intent to compel labor through threats of serious harm. The district court denied the plaintiffs' request to amend their complaint, leading to an immediate entry of judgment for the Salvation Army.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The appellate court held that the Rooker-Feldman doctrine did not bar the justice-referred plaintiffs' claims, as their participation was not compelled by state court orders but by parole or probation officers. However, the court found that the plaintiffs' allegations did not plausibly indicate that the Salvation Army violated the forced labor provisions. The walk-in plaintiffs were free to leave the program at any time, and the justice-referred plaintiffs did not adequately demonstrate how the conditions of their participation constituted forced labor. The court also agreed that the proposed second amended complaint would not cure the deficiencies of the original complaint. View "Taylor v. The Salvation Army National Corporation" on Justia Law

A group of drivers sued their employer, Owl, Inc., for breach of contract and violations of the Fair Labor Standards Act (FLSA). They claimed they were not paid the correct hourly rate under their employment contract or overtime wages under the FLSA. The district court granted summary judgment for Owl on the breach of contract claim and limited the damages available to the drivers for the FLSA claim. The parties then settled the FLSA claim for $350,000, and the drivers appealed the district court’s rulings.The district court for the Middle District of Florida granted summary judgment on the breach of contract claim, reasoning that the drivers had agreed to a specific hourly rate, and enforcing a higher rate under the Service Contract Act (SCA) would create a private right of action under the SCA, which does not exist. The court also granted Owl’s motion in limine, limiting the FLSA damages to one-and-a-half times the rate the drivers were actually paid. The drivers settled the FLSA claim but reserved the right to appeal the district court’s rulings.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that it had jurisdiction under 28 U.S.C. § 1291 because the district court entered a final judgment on all claims. The court also held that the drivers had standing to challenge the district court’s rulings despite the settlement. On the merits, the Eleventh Circuit affirmed the district court’s summary judgment on the breach of contract claim, holding that the SCA wage was not incorporated into the employment contracts. However, it reversed the district court’s ruling on the FLSA claim, holding that the “regular rate” under the FLSA should include the prevailing wage required by the SCA. The case was remanded for further proceedings consistent with this opinion. View "Perez v. Owl, Inc." on Justia Law

Brent Electric Company (Brent) and the International Brotherhood of Electrical Workers Local Union No. 584 (the Union) have had a long-standing relationship since 1996. In 2018, they entered into a collective bargaining agreement (CBA) that included an interest-arbitration clause allowing either party to unilaterally submit unresolved issues to arbitration if negotiations for a new CBA failed. In 2020, Brent terminated its authorization for the National Electrical Contractors Association (NECA) to negotiate on its behalf and later stopped contributing to the Union pension fund. The Union filed a grievance, and the Labor Management Committee ruled in favor of the Union. In 2021, Brent and the Union failed to negotiate a new CBA, leading the Union to unilaterally submit the dispute to arbitration. The arbitrator imposed a new CBA, which included both mandatory and permissive subjects of bargaining.The United States District Court for the Northern District of Oklahoma dismissed Brent’s complaint to vacate the arbitration award and granted the Union’s motion for summary judgment to enforce the award. The district court found that the interest-arbitration clause in the 2018 CBA was broad and unambiguous, covering all unresolved issues, including permissive subjects of bargaining. The court also rejected Brent’s argument that the arbitration award violated public policy or the Federal Arbitration Act.The United States Court of Appeals for the Tenth Circuit affirmed the district court’s decision. The Tenth Circuit held that the presumption of arbitrability applied because the interest-arbitration clause was validly formed and unambiguously covered both mandatory and permissive subjects of bargaining. The court rejected Brent’s argument that it had a statutory right to refuse the imposition of permissive subjects, noting that Brent had contractually agreed to the interest-arbitration clause. The court also found no violation of public policy, as the arbitration award did not include a self-perpetuating interest-arbitration clause. Finally, the court concluded that the arbitrator did not exceed its powers under the Federal Arbitration Act. View "Brent Electric Company v. International Brotherhood of Electrical Workers" on Justia Law

Henry Searcy, Jr. sought certification as an agent under the NFLPA’s 2012 Regulations Governing Contract Advisors but failed the required exam twice. After an arbitrator sided with the NFLPA, Searcy sued the NFLPA, its Executive Director, Prometric LLC, and Prometric’s Vice President and General Counsel. He alleged breach of contract, negligence, negligent misrepresentation, intentional infliction of emotional distress, and tortious interference with a contractual relationship, and sought vacatur of the arbitration award under the FAA.The United States District Court for the District of Columbia dismissed the claims against Prometric Defendants for lack of subject matter jurisdiction and against the NFLPA Defendants for failure to state a claim. On appeal, the United States Court of Appeals for the District of Columbia Circuit affirmed the dismissal of claims against Prometric Defendants and instructed the District Court to reconsider its dismissal of claims against the NFLPA Defendants, specifically examining whether Section 301 of the LMRA preempted Searcy’s state law claims.Upon further review, the District Court concluded it had jurisdiction and dismissed the claims under Rule 12(b)(6). Searcy appealed again. The United States Court of Appeals for the District of Columbia Circuit held that the District Court erred in finding subject matter jurisdiction over the claims against the NFLPA Defendants. The court determined that Section 301 of the LMRA does not completely preempt Searcy’s state law claims, as these claims do not require interpretation of the NFL-NFLPA Collective Bargaining Agreement. Consequently, the appellate court affirmed the dismissal on different grounds and remanded the case with instructions to dismiss for lack of subject matter jurisdiction under Rule 12(b)(1). View "Searcy v. Smith" on Justia Law

Robert Nelson, a car salesman, sustained a back injury on March 29, 2018, while working for Dependable Auto Sales. He experienced significant back pain the following day, leading to a diagnosis of acute back pain with left radiculopathy. Nelson filed a worker’s compensation claim and underwent various treatments and evaluations. Medical opinions varied, with some attributing his back issues to preexisting conditions and obesity, while others recognized a work-related aggravation. Nelson also had a history of preexisting injuries, including knee surgeries and osteoarthritis.Nelson settled his worker’s compensation claim with his employer in September 2019 and subsequently filed a claim against the Idaho Industrial Special Indemnity Fund (ISIF) for total and permanent disability benefits. The Idaho Industrial Commission denied his claim, finding that Nelson failed to prove he was totally and permanently disabled or that he suffered a permanent impairment due to the work-related accident. The Commission’s decision was influenced by its determination that Nelson was not a credible witness, citing inconsistencies in his testimony and a prior conviction for insurance fraud.The Supreme Court of Idaho reviewed the case and affirmed the Commission’s decision. The Court found that substantial and competent evidence supported the Commission’s credibility determination, despite some errors in the Commission’s findings. The Court upheld the Commission’s conclusion that Nelson was not totally and permanently disabled, as the evidence indicated that there was still a labor market for him, even under the most restrictive limitations. The Court did not address the alternative finding regarding permanent impairment. View "Nelson v. State of Idaho, Industrial Special Indemnity Fund" on Justia Law

Jeffrey Harmon and David Beasley, longtime employees of the City of Cincinnati and members of a city-employees union, were placed on leave under a Temporary Emergency Leave (TEL) program implemented in April 2020 in response to the COVID-19 pandemic. They used accrued paid leave during this period and appealed the city's decision to the Cincinnati Civil Service Commission, arguing that the city had not followed proper layoff procedures. The commission determined that the TEL program was not a layoff and denied their request for a hearing, instead holding an "appearance."Harmon and Beasley appealed the commission's decision to the Hamilton County Court of Common Pleas, which reversed the commission's determination and remanded the matter for a hearing. The city appealed to the First District Court of Appeals, arguing that the common pleas court lacked jurisdiction because the matter was governed by the collective-bargaining agreement (CBA) and the commission's decision was not the result of a quasi-judicial proceeding. The First District held that the common pleas court had jurisdiction under the CBA and R.C. 2506.01, as the commission's decision was an adjudication from a quasi-judicial proceeding.The Supreme Court of Ohio reviewed the case and affirmed the First District's judgment. The court held that Harmon and Beasley had a right to appeal the commission’s decision under R.C. 2506.01 and were not precluded by R.C. 4117.10. The court determined that the commission was required to hold a hearing under the Cincinnati Civil Service Rules, and its failure to do so did not divest the common pleas court of jurisdiction. The court concluded that the commission's decision was the result of a quasi-judicial proceeding, thus allowing the appeal to the common pleas court. View "Harmon v. Cincinnati" on Justia Law

Lanlan Li, a 51-year-old woman of Chinese descent, worked as a senior scientist at Fresenius Kabi USA, LLC. In 2019, she developed back pain and eye strain, which led her to take various types of leave. Despite accommodations, her back injury persisted, and she could not return to her position. Consequently, Fresenius terminated her employment. Li sued the company for disability discrimination, retaliation, and failure to accommodate under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA), as well as for national origin and age discrimination under Title VII and the Age Discrimination in Employment Act (ADEA).The United States District Court for the Northern District of Illinois granted summary judgment in favor of Fresenius on all claims. The court found that Li failed to exhaust her administrative remedies for her age and national origin claims, as she did not include a right-to-sue letter from the Equal Employment Opportunity Commission (EEOC) or the Illinois Department of Human Rights (IDHR). The court also held that her disability and retaliation claims failed on the merits, noting that Li was not a qualified individual under the ADA because she could not perform the essential functions of her job, including bench work.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court agreed that Li was not a qualified individual under the ADA and that Fresenius had provided reasonable accommodations. The court also found that Li failed to present evidence of age or national origin discrimination and that her retaliation claim lacked a causal connection between her EEOC charges and her termination. Therefore, the court upheld the summary judgment in favor of Fresenius. View "Li v. Fresenius Kabi USA, LLC" on Justia Law

Angela Midthun-Hensen and Tony Hensen sought insurance coverage for therapies for their daughter K.H.'s autism from Group Health Cooperative between 2017 and 2019. The insurer denied coverage, citing a lack of evidence supporting the effectiveness of speech therapy for a child K.H.'s age and sensory-integration therapy for autism at any age. The family's employer-sponsored plan only covered "evidence-based" treatments. After several medical reviews and appeals upheld the insurer's decision, the parents sued, alleging violations of the Employee Retirement Income Security Act (ERISA) and state law regarding autism coverage.The United States District Court for the Western District of Wisconsin ruled in favor of the insurer, finding no violations of state law or ERISA. The plaintiffs then focused on their claim that the insurer's actions violated the Mental Health Parity and Addiction Equity Act (MHPAEA), which mandates equal treatment limitations for mental and physical health benefits. They argued that the insurer applied the "evidence-based" requirement more stringently to autism therapies than to chiropractic care, which they claimed lacked scientific support.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court's decision. The appellate court found that the insurer's reliance on medical literature, which varied in its recommendations based on patient age, was permissible under the Parity Act. The court also noted that the plaintiffs failed to demonstrate that the insurer's treatment limitations for mental health benefits were more restrictive than those applied to "substantially all" medical and surgical benefits, as required by the statute. The court concluded that the plaintiffs' focus on a single medical benefit was insufficient to prove a violation of the Parity Act. View "Midthun-Hensen v. Group Health Cooperative of South Central, Inc.," on Justia Law

Eniola Famuyide filed a lawsuit against Chipotle Mexican Grill and its subsidiary, alleging sexual assault and harassment in the workplace. Famuyide claimed that a co-worker began harassing her shortly after she started working in May 2021 and sexually assaulted her in November 2021. She reported the incident to her manager, took a leave of absence, and later faced issues accessing the company’s online portal, leading her to believe she had been terminated. Chipotle later informed her that the termination was an error. Famuyide's complaint included claims of hostile work environment, retaliation, and other related charges under Minnesota law.The United States District Court for the District of Minnesota reviewed the case and denied Chipotle's motion to compel arbitration. The court determined that the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 applied, as the dispute arose after the Act's enactment date of March 3, 2022. Chipotle argued that the dispute arose before this date, pointing to the initial harassment and assault in 2021 and letters from Famuyide’s counsel in February 2022. However, the court found that no formal dispute existed between the parties until after the Act's enactment.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court held that a "dispute" under the Act did not arise until after March 3, 2022, as there was no conflict or controversy between Famuyide and Chipotle before that date. The court rejected Chipotle's arguments that the dispute arose either at the time of the assault or upon receipt of the February 2022 letters from Famuyide’s counsel. The court also declined to consider a March 1, 2022, letter from Chipotle’s counsel, as it was not part of the record. The district court's order was affirmed. View "Famuyide v. Chipotle Mexican Grill, Inc." on Justia Law