Justia Labor & Employment Law Opinion Summaries

An employee, Brandon Smith, was fired by Kansas City Southern Railway Company (KCSR) in 2018. His union, the International Association of Sheet Metal, Air, Rail, and Transportation Workers, Transportation Division (SMART-TD), challenged the dismissal under the collective-bargaining agreement (CBA) and the Railway Labor Act (RLA). The dispute went to arbitration, and in 2022, the National Railroad Adjustment Board (Board) overturned Smith's discharge, ordering his reinstatement with full benefits and back pay without deductions for outside earnings.The district court enforced the arbitration award, rejecting KCSR's argument that the award was ambiguous and required clarification. The court ordered KCSR to provide Smith with back pay without deductions and vacation benefits, and also awarded attorney fees to SMART-TD. KCSR appealed, arguing that the district court lacked jurisdiction and should have remanded the case to the Board for interpretation of the ambiguous award.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court found that the district court erred in enforcing the award without remanding it to the Board for clarification, particularly regarding the vacation benefits, which were not explicitly addressed in the award. The court noted that the district court overstepped by interpreting the CBA, which is outside its jurisdiction under the RLA. The court also acknowledged that the Board had since clarified the back pay issue, rendering that part of the dispute moot.The Eighth Circuit reversed and vacated the district court's judgments, including the award of attorney fees, and remanded the case for further proceedings consistent with its opinion. The court emphasized the need for the Board to interpret any ambiguities in the arbitration award. View "Assoc.of Sheet Metal Workers v. K.C. Southern Railway" on Justia Law

Carmen Wannamaker-Amos, a Black woman, worked in quality management at Purem Novi, Inc. for over thirty years. Despite receiving positive reviews from her supervisors, she faced negative treatment from Javad Hosseini, Purem’s chief quality executive. Hosseini repeatedly urged her supervisors to fire her, and in January 2020, after a problem with an automobile part, he requested her termination. Purem terminated her two days later. Wannamaker-Amos sued Purem, alleging racial and sex discrimination under Title VII of the Civil Rights Act of 1964 and the Civil Rights Act of 1866.The United States District Court for the District of South Carolina granted summary judgment to Purem, ruling that Wannamaker-Amos failed to produce sufficient evidence that the nondiscriminatory reason given for her firing was pretextual. The court found that she did not meet her employer’s legitimate expectations at the time of her termination.The United States Court of Appeals for the Fourth Circuit reviewed the case and concluded that numerous issues of material fact were in dispute. The court found that Wannamaker-Amos provided ample evidence to dispute Purem’s claims about her performance and that Hosseini’s criticisms were baseless. The court also noted that Purem’s shifting reasons for her termination and failure to follow its own disciplinary policies could indicate pretext for discrimination. The court emphasized that it is the role of the jury to decide which party’s evidence is more persuasive.The Fourth Circuit vacated the district court’s grant of summary judgment and remanded the case for further proceedings, allowing a jury to determine whether Wannamaker-Amos was subjected to intentional discrimination. View "Wannamaker-Amos v. Purem Novi, Inc." on Justia Law

Oak Reile, a delivery driver for Core Mark International, Inc., suffered a cervical spine fracture after falling off a loading ramp at work. He underwent surgery and rehabilitation, resulting in quadriplegia and other severe conditions. Reile later sought workers' compensation benefits for a psychological condition, specifically adjustment disorder with depressed mood, which he claimed was caused by his physical injury. Workforce Safety and Insurance (WSI) denied his claim, leading Reile to request reconsideration and an independent medical review.The Administrative Law Judge (ALJ) affirmed WSI's denial, concluding that while Reile's psychological condition resulted from his work injury, it did not meet the requirements of the North Dakota Administrative Code § 92-01-02-02.5. This regulation required the psychological condition to be the "physiological product" of the physical injury. The ALJ found that Reile's condition was compensable under the statute but not under the administrative rule. The district court upheld the ALJ's decision, leading to Reile's appeal.The North Dakota Supreme Court reviewed the case and determined that WSI exceeded its statutory authority in promulgating N.D. Admin. Code § 92-01-02-02.5. The court held that the regulation was invalid because it imposed additional burdens not present in the statute, such as requiring proof of a physiological nexus and excluding certain aspects of physical injuries from consideration. The court found that the ALJ's decision to deny benefits based on the invalid regulation was not in accordance with the law. Consequently, the Supreme Court reversed the district court's judgment, holding that Reile was entitled to benefits under the applicable statute. View "Reile v. WSI" on Justia Law

Michael Gifford, a beneficiary of the Operating Engineers 139 Health Benefit Fund, sought reimbursement for out-of-network medical expenses incurred during his treatment for a stroke and subsequent brain aneurysm surgery. The Fund denied the claim, stating the services were not provided in an emergency and were not medically necessary. Gifford's wife, Suzanne, appealed the decision, but the Fund upheld the denial after consulting two independent medical reviewers who concluded the surgery was not an emergency and not medically necessary.The United States District Court for the Eastern District of Wisconsin granted the Fund's motion for summary judgment, agreeing that the Fund's decision was not arbitrary and capricious. The court also granted the Fund's motion for a protective order, limiting discovery to the administrative record. The Estate of Michael Gifford, represented by Suzanne, appealed the decision, arguing that the Fund failed to conduct a full and fair review by not considering a surgical note from Dr. Ahuja, which was not included in the administrative record.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that the Fund's denial of benefits was not arbitrary and capricious, as the Fund reasonably relied on the independent medical reviewers' reports and the administrative record. The court also found that the Fund was not required to seek out additional information not provided by the claimant. Additionally, the court upheld the district court's grant of the protective order, finding no abuse of discretion in limiting discovery to the administrative record. The court concluded that the Fund provided a full and fair review of the claim, and the denial of benefits was reasonable. View "Estate of Gifford v Operating Engineers 139 Health Benefit Fund" on Justia Law

The claimant worked for the defendant when he suffered a hernia in March 2021. The defendant accepted liability for the injury. Shortly after, the claimant left his job with the defendant and began working at Meeting House Furniture Restoration. In July, he also started working at Black Back Pub, holding both jobs concurrently until he left Meeting House in September 2021. The claimant continued working at the Pub until October 8, 2021, when he underwent hernia surgery. The parties agree that the claimant was disabled from work as of the surgery date.The Commissioner of Labor reviewed the case and determined that the claimant's disability benefits should be calculated based on his "average weekly wages" as defined by 21 V.S.A. § 650(a). The claimant argued that his wages from both Meeting House and Pub should be included in this calculation. However, the Commissioner applied Workers’ Compensation and Occupational Disease Rule 8.1500, which states that only wages from employers the claimant was working for at the time of disability should be included. The Commissioner concluded that Rule 8.1500 was a valid exercise of the Department’s rulemaking authority and excluded the wages from Meeting House.The Vermont Supreme Court reviewed the case and affirmed the Commissioner’s decision. The Court held that Rule 8.1500 is consistent with 21 V.S.A. § 650(a)(4), which requires that wages from concurrent employment be included in the average weekly wage calculation only if the claimant was employed by multiple employers at the time of injury. The Court found that the rule was within the Department’s legislative grant of authority and did not compromise the intent of the Workers’ Compensation Act. Therefore, the rule was a valid exercise of the Department’s rulemaking authority. View "Hill v. Agri-Mark, Inc." on Justia Law

Adam P. Harrington was injured on February 15, 2018, while using a swing rope to transfer from an offshore gas platform to a transport vessel. Harrington, employed by Skelton's Fire Equipment, Inc., was inspecting fire-suppression equipment on Exxon's platform. Due to rough seas, Harrington mistimed his swing and fractured his leg. His medical expenses were covered by Skelton's workers' compensation insurer.Harrington sued Exxon for maritime negligence and wantonness in the Mobile Circuit Court. Before trial, the court granted Harrington's motion to exclude evidence of his medical expenses being paid by the workers' compensation insurer. The jury found Exxon liable for $1,500,000 in damages, reduced by 10% for Harrington's fault, resulting in a $1,350,000 judgment. Exxon's postjudgment motion for a new trial, arguing the exclusion of evidence was erroneous, was denied.The Supreme Court of Alabama reviewed the case. Exxon argued that the trial court erred by excluding evidence of the workers' compensation payments, citing Alabama Code § 12-21-45. However, the court held that substantive maritime law, which includes the collateral-source rule, applied. This rule prevents the reduction of damages by amounts received from third parties, such as insurance. The court found that applying § 12-21-45 would conflict with maritime law.Exxon also claimed that Harrington's expert witness opened the door to admitting evidence of the workers' compensation payments. The court disagreed, stating that the expert's testimony did not justify introducing such evidence under the doctrine of curative admissibility.The Supreme Court of Alabama affirmed the trial court's judgment in favor of Harrington and dismissed Harrington's conditional cross-appeal as moot. View "Exxon Mobil Corporation v. Harrington" on Justia Law

An employee, Matthew I. Ortega, voluntarily quit his job as an office manager at Island Towing after 17 years, citing work-related stress from interactions with law enforcement as the reason. Ortega applied for unemployment benefits, stating that the stress affected his mental health and ability to perform his job. The Nebraska Department of Labor denied his application, finding that he did not have good cause to quit.Ortega appealed to the Nebraska Department of Labor’s Appeal Tribunal, where both he and his supervisor, Chloe Aguilar, testified. Ortega described two specific incidents involving law enforcement that caused him significant stress, one of which occurred 2½ years prior to his resignation. Aguilar confirmed the ongoing negative interactions with law enforcement but stated that there was no way to alleviate the stress. The Appeal Tribunal upheld the denial, stating that Ortega did not provide sufficient evidence, such as medical documentation, to prove that his stress constituted good cause for quitting.Ortega then appealed to the district court for Hall County, which affirmed the Appeal Tribunal’s decision. The district court agreed that Ortega’s stress was a health concern requiring medical evidence and noted that Ortega had not pursued alternative solutions to preserve the employment relationship, such as seeking a leave of absence or modifying his job duties.The Nebraska Supreme Court reviewed the case and affirmed the district court’s judgment. The court held that Ortega failed to meet his burden of proof to show good cause for voluntarily leaving his employment. The court found that the evidence provided, including the details of only one specific negative interaction with law enforcement, was insufficient to establish that Ortega’s work conditions were an increasingly unreasonable burden affecting his health or sense of well-being. View "Ortega v. Albin" on Justia Law

Dennis Neal, a heating, ventilation, and air conditioning technician at Howard University Hospital, was injured on the job when a ladder gave way beneath him. He experienced pain and underwent spinal surgery. After attempting to return to work and experiencing further pain, he quit and sought reinstatement of his disability benefits and vocational rehabilitation services. The hospital terminated his benefits when he accepted new employment but quit after four days due to physical discomfort from long drives and job duties.An Administrative Law Judge (ALJ) granted Neal's claim for reinstatement of benefits and services, and the Compensation Review Board (CRB) affirmed. The hospital appealed, arguing that the CRB lacked substantial evidence to support its findings that Neal did not voluntarily limit his income and did not fail to cooperate with vocational rehabilitation. The hospital contended that the ALJ and CRB ignored critical testimony from witnesses.The District of Columbia Court of Appeals reviewed the case and found that the CRB's decision was supported by substantial evidence. The court noted that the ALJ's findings were based on credible evidence, including medical evaluations and Neal's testimony about his physical limitations and the nature of the job duties at his new employment. The court also found that Neal had cooperated with vocational rehabilitation services and had demonstrated a willingness to continue doing so.The court held that the CRB's decision flowed rationally from the facts and was supported by substantial evidence. The court affirmed the CRB's decision to reinstate Neal's temporary total disability benefits and vocational rehabilitation services. View "Howard University Hospital v. D.C. Department of Employment Services" on Justia Law

Respondents John Arvanites and Jonathon Burdette, both peace officers employed by the City of Las Vegas, were involved in a disciplinary investigation. A City employee lodged a complaint against Arvanites, and Burdette was notified as a witness. The City referred the complaint to its Human Resources Department, and a human resources analyst conducted the interviews. Respondents, including the Las Vegas Police Protective Association, sought declaratory and injunctive relief, arguing that NRS 289.060 required a ranked peace officer to conduct such investigations.The Eighth Judicial District Court of Clark County granted summary judgment in favor of the respondents. The court determined that the City violated the Nevada Peace Officer's Bill of Rights (POBR) by allowing a human resources employee to lead the investigation. The court declared that the City must ensure a peace officer conducts any interrogation or hearing in connection with such investigations and enjoined the City from using non-peace officers for these tasks.The Supreme Court of Nevada reviewed the case and affirmed the district court's decision. The court held that NRS 289.060(2)(d) requires a ranked peace officer to lead any investigation that could result in punitive action against another peace officer. The court found that the term "officer" in the statute refers to a peace officer, based on legislative history, statutory context, and public policy considerations. The court concluded that the City violated the statute by having a human resources employee lead the investigation and upheld the district court's order granting summary judgment for declaratory and injunctive relief. View "CITY OF LAS VEGAS VS. LAS VEGAS POLICE PROTECTIVE ASS'N." on Justia Law

Dr. Zahra Shahrashoob, an Iranian woman, was hired by Texas A&M University (A&M) in 2018 for a non-tenure-track position in the Department of Chemical Engineering. Initially employed as a lecturer, she was later reclassified as an instructional assistant professor. Despite her satisfactory performance, she felt discriminated against due to her workspace, salary, and teaching load, leading her to file a discrimination charge in June 2020. In August 2020, A&M offered her a shortened four-and-a-half-month contract, which ended in January 2021. She filed a second discrimination charge, alleging that Dr. Mohammad Alam, an Indian man, was hired to replace her.The United States District Court for the Southern District of Texas granted A&M’s motion for summary judgment, dismissing Dr. Shahrashoob’s claims. The court found that she failed to establish a prima facie case of discrimination as she did not show that she was treated less favorably than similarly situated employees. Additionally, the court concluded that she could not prove that A&M’s reasons for her nonrenewal were pretextual.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s decision, holding that Dr. Shahrashoob forfeited her arguments regarding Dr. Alam by not raising them sufficiently in the lower court. Even if she had not forfeited these arguments, she failed to make out a prima facie case of discrimination as she did not provide sufficient evidence that Dr. Alam was similarly situated or that he replaced her. Regarding her retaliation claim, the court found that she could not show that A&M’s reasons for her nonrenewal were pretextual, as she did not provide significant evidence beyond temporal proximity. Thus, the court affirmed the summary judgment in favor of A&M. View "Shahrashoob v. Texas A&M University" on Justia Law