Justia Labor & Employment Law Opinion Summaries

Marlean Ames, a heterosexual woman, worked for the Ohio Department of Youth Services since 2004. In 2019, she applied for a management position but was passed over in favor of a lesbian woman. Subsequently, Ames was demoted from her role as a program administrator, and a gay man was hired to fill her previous position. Ames filed a lawsuit under Title VII, alleging discrimination based on her sexual orientation.The District Court granted summary judgment to the agency, applying the McDonnell Douglas framework for evaluating disparate-treatment claims. The court held that Ames failed to make a prima facie case of discrimination because she did not show "background circumstances" suggesting the agency discriminated against majority-group members. The Sixth Circuit affirmed, requiring Ames to meet this additional burden as a straight woman.The Supreme Court of the United States reviewed the case. The Court held that the Sixth Circuit's "background circumstances" rule, which imposes a heightened evidentiary standard on majority-group plaintiffs, is inconsistent with Title VII's text and precedents. Title VII prohibits discrimination against any individual based on protected characteristics without distinguishing between majority and minority groups. The Court vacated the judgment and remanded the case for application of the proper prima facie standard under Title VII. View "Ames v. Ohio Department of Youth Services" on Justia Law

Peter Schuman and William Coplin, former employees of Atmel Corporation, were terminated without cause after Microchip Technology Inc. acquired Atmel. They were offered severance benefits significantly lower than those promised under Atmel's Employee Retirement Income Security Act (ERISA)-governed benefits plan, in exchange for signing a release of all potential claims. Schuman and Coplin signed the releases but later filed a class-action lawsuit on behalf of approximately 200 similarly situated former Atmel employees, alleging ERISA violations, including breach of fiduciary duty and denial of benefits, and challenging the enforceability of the releases.The United States District Court for the Northern District of California granted summary judgment in favor of Microchip against Schuman and Coplin, applying a six-part test to determine that the releases were signed knowingly and voluntarily. The court did not consider evidence of Microchip's alleged breach of fiduciary duties in its analysis. The district court denied summary judgment for the non-named plaintiffs, finding material disputes of fact regarding Microchip's knowledge of the Plan's intended interpretation. The court entered final judgment under Federal Rule of Civil Procedure 54(b) for Schuman and Coplin, certifying the question of the appropriate legal test for determining the enforceability of the releases.The United States Court of Appeals for the Ninth Circuit reversed the district court's summary judgment against Schuman and Coplin, holding that courts must evaluate the enforceability of ERISA releases by considering the totality of the circumstances, including any alleged improper conduct by the fiduciary. The court enumerated nine non-exhaustive factors for this evaluation. The case was remanded to the district court for further proceedings consistent with this opinion. The Ninth Circuit dismissed Microchip's cross-appeal for lack of jurisdiction, as the issue raised was not inextricably intertwined with the primary appeal. View "Schuman v. Microchip Technology Inc." on Justia Law

Petra Brokken sued her employer, Hennepin County, alleging religious discrimination under Title VII of the Civil Rights Act of 1964 and the Minnesota Human Rights Act (MHRA), and wrongful discharge under Minnesota’s Refusal of Treatment statute. Brokken claimed that the County's Covid-19 vaccine and testing policy conflicted with her religious beliefs. After initially granting her a religious exemption, the County revised its policy, threatening termination and loss of accrued benefits if she did not comply. Brokken retired under duress and subsequently filed her lawsuit.The United States District Court for the District of Minnesota dismissed Brokken's claims. The court ruled that she failed to plead an adverse employment action, did not plausibly plead religious beliefs conflicting with the County’s policy, and that the MHRA does not provide a cause of action for failure to accommodate religious beliefs. Additionally, the court found that Minnesota’s Refusal of Treatment statute does not create a private right of action.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court affirmed the district court’s dismissal of the wrongful discharge claim under Minnesota’s Refusal of Treatment statute, agreeing that it does not create a private right of action. However, the court reversed the dismissal of Brokken’s Title VII and MHRA claims. The appellate court held that Brokken plausibly pled an adverse employment action and sufficiently alleged that her religious beliefs conflicted with the County’s policy. The court also recognized that the MHRA provides protection against failures to accommodate religious beliefs. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Brokken v. Hennepin County" on Justia Law

Matthew Kale sued his employer, Aero Simulation, Inc. (ASI), alleging religious and disability discrimination under Title VII of the Civil Rights Act, the Americans with Disabilities Act (ADA), the Religious Freedom Restoration Act (RFRA), the Constitution, and state law. ASI required all employees to receive the Covid-19 vaccine, with non-compliance resulting in disciplinary action, including termination. Kale requested a religious exemption, citing his belief that his body is a temple of the Holy Spirit and should not be subjected to unwanted intrusions. ASI denied his request, and Kale was terminated. He filed a charge with the EEOC, which issued a right to sue letter.The United States District Court for the District of South Dakota dismissed Kale’s claims, ruling that he failed to plausibly plead religious beliefs conflicting with ASI’s Covid-19 policy, did not allege that ASI regarded him as disabled due to his unvaccinated status, and that his proposed amended complaint was futile. Kale appealed the dismissal of his federal law claims.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court’s dismissal, holding that Kale failed to allege facts showing that ASI’s testing requirement conflicted with his bona fide religious beliefs. The court noted that Kale’s complaint did not adequately connect his objection to testing with specific religious principles. Additionally, the court found that Kale did not exhaust his administrative remedies for his ADA claim, as he only asserted religious discrimination in his EEOC charge. The court also upheld the denial of Kale’s motion to amend his complaint, deeming it futile as it contained the same deficiencies as the original complaint. The judgment was affirmed. View "Kale v. Aero Simulation, Inc." on Justia Law

Matthew Bare sued his former employer, Rainforest Alliance, Inc., in the Superior Court of the District of Columbia, alleging that the company failed to pay him a redundancy settlement after his position was made redundant due to a reorganization. Bare claimed that he had agreed to resign in exchange for the settlement, which was contingent upon his execution of a release-of-claims agreement. However, after Bare made critical comments about the company, Rainforest Alliance terminated him and refused to pay the settlement, leading to claims of breach of contract and violation of the District of Columbia Wage Payment and Collection Law.The Superior Court dismissed Bare's complaint with prejudice, agreeing with Rainforest Alliance that Bare had failed to allege the occurrence of a condition precedent—specifically, the execution of a release agreement. The court found that without alleging this, Bare could not claim he had earned the redundancy payment under the contract or the wage law. Bare had argued that the issue of the condition precedent was a factual matter for summary judgment or trial and that Rainforest Alliance had waived the condition by not providing a release agreement. He also requested leave to amend his complaint if the motion to dismiss was granted.The District of Columbia Court of Appeals reviewed the case and held that the trial court should have granted Bare's request to amend his complaint. The appellate court found that Bare's request to amend was his first, the case had been pending for a short time, there was no evidence of bad faith or dilatory motives, and there was no prejudice to Rainforest Alliance. The court also determined that Bare's proposed amendment, which would include allegations that Rainforest Alliance waived the condition precedent by not providing a release agreement, was not futile. Consequently, the appellate court reversed the dismissal and remanded the case for further proceedings. View "Bare v. Rainforest Alliance, Inc." on Justia Law

The U.S. Department of Education announced a reduction in force (RIF) on March 13, 2025, affecting about half of its employees. Subsequently, twenty-one states and several labor organizations and school districts filed lawsuits against the Secretary of Education, the Department, and the President, claiming that the RIF violated the U.S. Constitution and the Administrative Procedure Act (APA). They also sought an injunction against the transfer of certain functions out of the Department, announced by the President on March 21, 2025.The U.S. District Court for the District of Massachusetts consolidated the cases and granted the plaintiffs' motions for a preliminary injunction. The court found that the plaintiffs were likely to succeed on the merits of their claims, determining that the RIF and the transfer of functions were likely ultra vires and violated the APA. The court concluded that the actions were arbitrary and capricious, lacking a reasoned explanation and failing to consider the substantial harms to stakeholders.The United States Court of Appeals for the First Circuit reviewed the case. The court denied the appellants' motion for a stay pending appeal. The court found that the appellants did not make a strong showing that they were likely to succeed on the merits, particularly regarding the APA claims. The court also determined that the plaintiffs would suffer substantial injury without the injunction, as the RIF made it effectively impossible for the Department to carry out its statutory functions. The court concluded that the public interest favored maintaining the injunction to ensure the Department could fulfill its legal obligations. View "New York v. McMahon" on Justia Law

Anna Palova, a flight attendant for United Airlines since 1992, was terminated in February 2020 for allegedly engaging in "parking," a prohibited scheduling tactic. United Airlines claimed that Palova manipulated flight assignments, violating the collective bargaining agreement (CBA). Palova, however, argued that her termination was due to age discrimination, as she and two other older flight attendants were fired while younger attendants who committed similar infractions were not.The United States District Court for the Southern District of Texas granted summary judgment in favor of United Airlines. The court concluded that the Railway Labor Act (RLA) precluded Palova's Age Discrimination in Employment Act (ADEA) claim and preempted her Texas Commission on Human Rights Act (TCHRA) claim. The court reasoned that resolving Palova's claims would require interpreting the CBA, which falls outside the court's jurisdiction under the RLA.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court held that the RLA does not preclude or preempt Palova's age discrimination claims. The court found that Palova's claims of age discrimination were independent of the CBA and did not require its interpretation. The court noted that while the CBA might be referenced, it was not dispositive of the discrimination claims. Consequently, the Fifth Circuit vacated the district court's summary judgment order and remanded the case for further proceedings consistent with its opinion. View "Palova v. United Airlines" on Justia Law

In 1996, Katherine Stovall, while employed at New England Telephone Company, experienced pain in her hands and wrists due to a work-related injury. By 1998, the pain had spread, leading her to take a leave of absence. She returned to work in 1999 but ultimately stopped working in June 2001 due to increased pain. Stovall notified her employer of a new injury/aggravation in August 2001. In 2004, she filed petitions for benefits for both the 1996 and 2001 injuries. In 2006, a hearing officer awarded her benefits for the 2001 injury but not for the 1996 injury, which she had withdrawn.The Workers’ Compensation Board hearing officer found that the 2001 injury was a significant aggravation of the 1996 injury. In 2011, New England Telephone filed a petition to review the benefits, asserting that the 520-week limit on compensation payments had been reached. The hearing officer granted the petition, finding that Stovall had achieved maximum medical improvement and had no permanent impairment from the 2001 injury.Stovall filed a petition for restoration of benefits for the 1996 injury in 2017, nearly eleven years after payments for the 1996 injury had ceased. An ALJ denied the petition as time-barred, concluding that Stovall had not shown that New England Telephone was on notice that its payments for the 2001 injury were related to the 1996 injury. The Appellate Division vacated this decision, ruling that the payments for the 2001 injury tolled the statute of limitations for the 1996 injury.The Maine Supreme Judicial Court vacated the Appellate Division's decision, holding that Stovall failed to prove that New England Telephone was on notice that its payments for the 2001 injury were related to the 1996 injury. The case was remanded for the Appellate Division to affirm the denial of Stovall’s petition as time-barred. View "Stovall v. New England Telephone Company" on Justia Law

In August 2022, a bin full of phosphate rock collapsed at the Lee Creek Mine in Beaufort, North Carolina, injuring three miners. Industrial TurnAround Corporation (ITAC), the independent contractor responsible for checking the structural integrity of the bin's support columns, was cited by the Mine Safety and Health Administration (MSHA) for failing to take defective equipment out of service. MSHA sent a notice of proposed penalty to ITAC's outdated address of record, and ITAC did not contest the penalty, which became final 30 days later. ITAC subsequently filed a motion to reopen the penalty, claiming it had inadvertently failed to update its address of record.The Federal Mine Safety and Health Review Commission granted ITAC's motion to reopen the penalty, citing excusable neglect under Federal Rule of Civil Procedure 60(b). The Commission noted that ITAC had not occupied the address since 2009 and had only discovered the MSHA notice when an employee checked for missing packages. The Secretary of Labor, representing MSHA, opposed the motion, arguing that ITAC's failure to update its address could not be excused under FRCP 60(b).The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court held that the Commission’s order to reopen the penalty was not an appealable collateral order and dismissed the Secretary’s petition for lack of jurisdiction. The court emphasized that the order did not impose an obligation, deny a right, or fix a legal relationship, and that the interest in immediate review did not meet the high threshold required under the collateral order doctrine. The court concluded that the Commission’s decision to reopen the penalty did not involve a substantial public interest or a particular value of a high order that justified immediate appeal. View "Secretary of Labor v. Industrial TurnAround Corporation" on Justia Law

Garten Trucking LC, a company specializing in the transportation of paper products, faced a union organizing campaign by the Association of Western Pulp and Paper Workers (AWPPW) in mid-2021. After losing a union representation election, AWPPW filed multiple unfair labor practice charges against Garten Trucking, alleging various violations of the National Labor Relations Act (NLRA). An Administrative Law Judge (ALJ) found Garten Trucking guilty of several violations, including unlawful interrogation and threats, and ordered a new election. The National Labor Relations Board (NLRB) affirmed the ALJ's findings and mandated bargaining with AWPPW.While the initial case was pending, AWPPW continued its organizing efforts, distributing a flyer claiming that Garten Trucking was required to bargain with the union and that the union's presence led to employee raises. In response, Garten Trucking's owner, Robert Garten, posted a message on the company's internal board, refuting the union's claims and suggesting that employees would have already received raises if not for the union's actions. The union filed another unfair labor practice charge, and the ALJ ruled that Garten's message violated Section 8(a)(1) of the NLRA by implying that union activities negatively impacted wage increases.The United States Court of Appeals for the Fourth Circuit reviewed the case, focusing on whether Garten's message constituted a coercive threat. The court upheld the NLRB's decision, finding substantial evidence that Garten's statement linking wage increases to union activities was coercive and violated the NLRA. The court emphasized that while employers are entitled to express their opinions on union activities, they cannot make statements that imply threats or promises of benefits based on union support. The court denied Garten Trucking's petition and granted the NLRB's cross-petition for enforcement. View "Garten Trucking LC v. National Labor Relations Board" on Justia Law