Justia Labor & Employment Law Opinion Summaries

A married couple, both employees of UT-Battelle, objected to their employer’s COVID-19 vaccine mandate on religious grounds, specifically because of their belief that the vaccines’ development involved the use of fetal cell lines from abortions, which conflicted with their Christian faith. UT-Battelle required employees seeking religious exemptions to undergo a panel interview and read a “fact sheet” presenting religious leaders’ support for vaccination. Employees granted religious accommodations were placed on unpaid leave, while those with medical accommodations were not. Mrs. Bilyeu ultimately received a medical exemption before the policy took effect and did not lose pay or work time. Mr. Bilyeu, however, was placed on unpaid leave after exhausting his vacation days, returning to work only after the policy was rescinded.The United States District Court for the Eastern District of Tennessee granted summary judgment to UT-Battelle on all claims except Mrs. Bilyeu’s retaliation claim, which was later settled. The court found that Mrs. Bilyeu lacked standing and that Mr. Bilyeu had not suffered a materially adverse employment action under Title VII.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment as to Mrs. Bilyeu, holding she lacked Article III standing because she suffered no cognizable injury after receiving her medical accommodation. For Mr. Bilyeu, the Sixth Circuit vacated the summary judgment on his disparate treatment and failure-to-accommodate claims, instructing the district court to reconsider them in light of the Supreme Court’s decision in Muldrow v. City of St. Louis, which eliminated the “materially adverse” requirement for adverse employment actions under Title VII. The court reversed the summary judgment on Mr. Bilyeu’s retaliation claim, finding sufficient evidence for a reasonable jury to conclude that the interview process could dissuade a reasonable worker from seeking a religious accommodation, and remanded for further proceedings. View "Bilyeu v. UT-Battelle, LLC" on Justia Law

The appellant was injured while inspecting an underground fiber optics project when he slipped and fell into a manhole, sustaining injuries to his right shoulder, left knee, and lower back. Initially, he did not report or seek compensation for a cervical spine (neck) injury. Several weeks later, he sought coverage for cervical spine surgery, claiming the work accident aggravated a preexisting condition. The Division denied coverage, concluding there was no causal relationship between the work accident and the cervical spine injury.After the denial, the appellant requested review, and the Wyoming Department of Workforce Services, Workers’ Compensation Division referred the matter to the Office of Administrative Hearings (OAH) for a contested case hearing. The OAH found that the cervical spine injury was not caused by the work accident. The appellant appealed to the District Court of Natrona County, which affirmed the OAH’s decision. The appellant then appealed to the Wyoming Supreme Court.The Supreme Court of Wyoming held that the Division erred by referring the case to the OAH instead of the Medical Commission. The Court found that the primary issue—whether the cervical spine injury was caused by the work accident—required the application of medical judgment to complex medical facts and conflicting medical diagnoses. Under Wyoming law, such “medically contested cases” must be referred to the Medical Commission. The Court reversed the lower courts’ decisions and remanded the case for further proceedings before the Medical Commission, holding that the Division was required to refer the matter to the Medical Commission because it involved a medically contested issue. View "Polzer v. State ex rel. Department of Workforce Services, Workers' Compensation Division" on Justia Law

A prospective employee applied for a position as an occupational therapist with a rehabilitation company, which required COVID-19 vaccination as a condition of employment. The applicant requested a religious exemption, submitting a written statement and a supporting letter from a friend citing religious objections to vaccines developed with fetal cell lines. The company questioned the applicant about her vaccination history and, finding her responses insufficiently sincere, denied the exemption and rescinded the job offer. The applicant filed a complaint with the Kansas Department of Labor, which found the company had violated Kansas law by inquiring into the sincerity of her religious beliefs.The company sought judicial review in the Johnson District Court, which reversed the agency’s decision. The district court held that the relevant Kansas statute, which prohibits employers from inquiring into the sincerity of an employee’s religious beliefs when considering COVID-19 vaccine exemptions, was preempted by federal law—specifically, the federal Vaccine Mandate for Medicare and Medicaid providers and Title VII of the Civil Rights Act. The district court also found the Kansas statute violated due process because it lacked a rational basis.On appeal, the Supreme Court of the State of Kansas reviewed the case de novo. The court held that the federal Vaccine Mandate and Title VII do not expressly or impliedly preempt the Kansas statute, because federal law permits but does not require employers to inquire into religious sincerity. The court further held that the Kansas law does not violate due process, as it is rationally related to the legitimate state interest of protecting religious liberty and provides adequate procedural protections. The Supreme Court of Kansas reversed the district court’s judgment and remanded the case for further proceedings. View "Powerback Rehabilitation v. Dept. of Labor" on Justia Law

Two African American truck drivers employed by a large transportation company in Nashville alleged that their supervisors subjected them to a racially hostile work environment. The plaintiffs claimed they were assigned longer routes and more hours than their non-African American colleagues for the same pay, denied certain benefits, and given older or more damaged trucks. They also testified that their supervisors, one of whom was also African American, repeatedly called them “monkey” and “monkey ass,” used demeaning language, and threatened or criticized them in ways not directed at white coworkers. The plaintiffs reported this conduct to company liaisons and managers, but the alleged harassment continued. One plaintiff resigned due to the conditions, while the other was terminated for alleged performance issues, which he disputed.The United States District Court for the Middle District of Tennessee granted summary judgment to the employer, finding that the plaintiffs had not provided sufficient evidence of race-based harassment to support a hostile work environment claim. The court reasoned that the terms used by the supervisors were not inherently racist, that the plaintiffs had not shown the terms were used only against African Americans, and that the plaintiffs’ comparative evidence was insufficient because it did not establish the race of the relevant comparators with the required specificity.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the grant of summary judgment de novo. The appellate court held that the plaintiffs’ testimony regarding the use of “monkey” and “monkey ass” by supervisors constituted evidence of race-based harassment, given the well-established history of those terms as racial slurs against African Americans. The court also found that the plaintiffs’ comparative and other evidence was admissible and sufficient to raise genuine issues of material fact regarding the severity and pervasiveness of the harassment and the employer’s liability. The Sixth Circuit reversed the district court’s judgment and remanded the case for further proceedings. View "Smith v. P.A.M. Transport, Inc." on Justia Law

A worker alleged that he suffered a back injury while employed at a meat processing company. The employer’s workers’ compensation insurer investigated the claim and issued a written denial, stating that the injury was not work-related. The worker requested a hearing to challenge the denial. After this request, the insurer required the worker to undergo an independent medical examination (IME) by a physician of its choosing. The IME report supported the insurer’s denial, concluding that the worker’s preexisting condition, not a work injury, was the major cause of his disability. The worker’s own physician disagreed with the IME’s findings. The worker then requested authorization for a worker requested medical examination (WRME), citing the conflict between the IME and his physician’s opinion.The Workers’ Compensation Division’s Medical Resolution Team denied the WRME request, reasoning that the IME had been conducted after the insurer’s initial written denial. An Administrative Law Judge (ALJ) upheld both the denial of compensability and the denial of the WRME request, relying on the IME report as persuasive evidence. The Workers’ Compensation Board affirmed the ALJ’s decisions. The worker’s estate, after his death, pursued judicial review in the Oregon Court of Appeals, which reversed the Board’s denial of the WRME request and remanded for further proceedings, holding that the insurer’s denial was “based on” the IME report.The Supreme Court of the State of Oregon reviewed the statutory interpretation of ORS 656.325(1)(e). The court held that whether a denial of compensability “is based on” an IME report should be determined at the time the WRME request is decided, not at the time of the initial hearing request. Because the insurer relied on the IME report to defend its ongoing denial, the worker was entitled to a WRME. The Supreme Court affirmed the Court of Appeals, reversed the Workers’ Compensation Board, and remanded the case for further proceedings. View "Teitelman v. SAIF" on Justia Law

Brandon King worked as a driver for United Parcel Service, Inc. (UPS) and believed he was hired for a Monday-to-Friday schedule. However, UPS assigned him to a Tuesday-through-Saturday schedule, which included weekend work he sought to avoid through various means, such as maximizing weekday hours, trading shifts, and calling in sick. UPS disciplined him for these actions, including written warnings and supervisor ride-alongs, and fired him multiple times, though the union secured his reinstatement. King alleged that UPS discriminated against him based on race and age, created a hostile work environment, and retaliated against him, claiming that younger, white employees were allowed to avoid Saturday shifts and were disciplined less harshly for similar conduct.King filed suit in Iowa state court under the Iowa Civil Rights Act. UPS removed the case to the United States District Court for the Southern District of Iowa, arguing that the Labor Management Relations Act (LMRA) completely preempted King’s state law claims because resolving them would require interpretation of the collective-bargaining agreement. The district court denied King’s motion to remand the case to state court and granted UPS’s motion for judgment on the pleadings, finding that King’s claims were preempted and that he failed to state a claim under federal law.The United States Court of Appeals for the Eighth Circuit reviewed both the refusal to remand and the judgment on the pleadings de novo. The court held that King’s discrimination and hostile work environment claims were substantially dependent on analysis of the collective-bargaining agreement and thus completely preempted by the LMRA, requiring dismissal. The retaliation claim failed because King did not plausibly allege a causal connection between protected activity and adverse employment action. The court also found no abuse of discretion in denying leave to amend. The judgment of the district court was affirmed. View "King v. United Parcel Service, Inc." on Justia Law

An educator employed by the New York City Department of Education (DOE) was appointed Executive Director of the “AP for All” program, where she supervised a diverse team and was credited with expanding access to Advanced Placement courses. Early in her tenure, she experienced racial tensions with subordinates, including accusations of “microaggressions” and being labeled as exhibiting “white fragility.” These tensions escalated after a new Chancellor implemented an “equity agenda” that included mandatory implicit bias trainings. The plaintiff, who is Caucasian, alleged that these trainings and subsequent workplace interactions fostered a racially hostile environment, with repeated negative generalizations about white employees and a lack of intervention by supervisors when she complained.The plaintiff initially filed suit in the Supreme Court of New York, later amending her complaint to assert claims under 42 U.S.C. § 1983 for race discrimination, hostile work environment, and constructive discharge. The case was removed to the United States District Court for the Southern District of New York, where the plaintiff voluntarily dismissed her state law claims. The district court granted summary judgment to the defendants, finding that the plaintiff failed to demonstrate a municipal policy or custom that caused her demotion, the alleged hostile work environment, or her constructive discharge.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court’s decision de novo. The Second Circuit affirmed the grant of summary judgment on the demotion and constructive discharge claims, holding that the plaintiff did not provide sufficient evidence that these actions were motivated by racial discrimination or that the employer intentionally created intolerable working conditions. However, the court vacated the summary judgment on the hostile work environment claim, finding that genuine disputes of material fact existed as to whether the DOE’s actions and inaction amounted to a municipal policy or custom that created a racially hostile environment. The case was remanded for further proceedings on that claim. View "Chislett v. New York City Department of Education" on Justia Law

An athletic trainer employed by a rehabilitation services provider was assigned to work at a local high school under a contract between her employer and the school. Over several years, she reported concerns about the conduct and performance of other athletic trainers at the school, which led to personnel changes. In 2020, after a new head football coach was hired, the trainer was briefly given additional responsibilities but was soon told to return to her original role. Shortly thereafter, the school’s principal requested her removal, citing workplace issues unrelated to her sex. The trainer was then removed from her assignment at the school and offered several alternative positions by her employer, some with reduced pay or less desirable conditions. She ultimately accepted a new assignment but later resigned, alleging that her removal and reassignment were due to sex discrimination and retaliation for her complaints.The United States District Court for the Northern District of Alabama granted summary judgment in favor of the employer, finding that although there was a factual dispute about the employer’s control over the removal, the trainer failed to show that the employer discriminated or retaliated against her in violation of Title VII. The court concluded there was insufficient evidence that the employer knew or should have known the school’s removal request was based on sex, or that the reassignment options were offered for discriminatory reasons.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decision. The appellate court held that the trainer’s discrimination claim failed because there was no evidence the employer knew or should have known the school’s request was sex-based, and no evidence that the reassignment was motivated by sex. The retaliation claim also failed, as there was no evidence the employer removed or reassigned her because she engaged in protected activity. The court affirmed summary judgment for the employer. View "Vincent v. ATI Holdings LLC" on Justia Law

A hospital employee in Oregon, who identified as a practicing Christian, requested a religious exemption from her employer’s COVID-19 vaccine mandate, citing her belief that her body is a temple of the Holy Spirit and that she must avoid substances that could harm her body. The employer granted her exemption from vaccination but required her to wear personal protective equipment and undergo weekly antigen testing using a nasal swab treated with ethylene oxide. The employee objected to the testing, claiming her research showed the swab was carcinogenic and that using it would violate her religious duty to protect her body. She requested alternative accommodations, such as saliva testing or full-time remote work, but the employer denied these requests and ultimately terminated her employment when she refused to comply.The United States District Court for the District of Oregon dismissed her complaint for failure to state a claim, finding that her objection to the testing was based on secular, medical concerns rather than a bona fide religious belief. The court concluded that while her general belief in protecting her body as a temple was religious, her specific objection to the nasal swab was rooted in her personal interpretation of medical research.On appeal, the United States Court of Appeals for the Ninth Circuit affirmed the district court’s dismissal. The Ninth Circuit held that to state a claim for religious discrimination under Title VII and Oregon law, a plaintiff must plausibly allege that the specific accommodation request is rooted in a bona fide religious belief, not merely a secular or personal preference. The court found that the employee’s complaint did not sufficiently connect her religious beliefs to her objection to antigen testing, as her concerns were based on her own medical judgment rather than religious doctrine. The court declined to adopt a more lenient pleading standard and affirmed the dismissal with prejudice. View "DETWILER V. MID-COLUMBIA MEDICAL CENTER" on Justia Law

An employee of an airline company in Puerto Rico suffered a work-related injury when an airplane door struck his head. After the incident, he sought medical treatment and eventually reported to Puerto Rico’s State Insurance Fund (the Fund) for workers’ compensation. The employer did not initially provide the necessary incident report for the Fund, nor did it file a Work Accident Report with the Fund until nearly two years later. The employee was placed on leave under the Family and Medical Leave Act (FMLA) and continued to receive treatment, including surgery and physical therapy. While still under medical care and unable to return to work, he was terminated by the employer, who cited his failure to keep them informed of his status.The employee filed suit in the United States District Court for the District of Puerto Rico, alleging several claims under federal and Puerto Rico law, including a retaliation claim under Puerto Rico’s Whistle-Blower Act (Law 115). The district court dismissed some claims at the motion to dismiss stage and granted summary judgment on the remaining claims, including the Law 115 retaliation claim. The district court found that the five-month gap between the employee’s report to the Fund and his termination was too long to establish causation, and also concluded that the employer’s stated reasons for termination were not pretextual.On appeal, the United States Court of Appeals for the First Circuit reviewed the summary judgment ruling de novo. The court held that the district court erred by treating close temporal proximity as a necessary condition for causation and by failing to consider the employer’s shifting explanations for the termination as evidence of pretext. The First Circuit vacated the district court’s summary judgment on the Law 115 claim and remanded for further proceedings, holding that genuine issues of material fact remained regarding causation and pretext. View "Mercado v. Hyannis Air Service, Inc." on Justia Law