Justia Labor & Employment Law Opinion Summaries

An employer engaged in the cybersecurity industry hired an employee for a marketing and sales position after recruiting him away from a competitor. The parties signed a written employment agreement that described a specific role and compensation structure. The employee alleged that the promised position did not actually exist and that he was instead given an entry-level sales role. Although the employee changed employers, he remained at his existing residence in Las Vegas throughout his employment.The employee sued the employer, claiming a violation of Nevada's employment-luring statute, NRS 613.010, which prohibits employers from inducing workers to change locations under false pretenses regarding employment terms. The employer moved for summary judgment in the Eighth Judicial District Court, arguing that the statute did not apply because the employee had not physically relocated his residence. The employee countered that the statute applies when an employee changes their place of employment, not necessarily their residence. The district court denied the employer’s motion for summary judgment, finding that the statute’s civil cause of action provision supports the employee’s interpretation. The court also denied the employer’s later motion to strike the employee’s jury demand, ruling the employer had waived the argument by waiting too long to raise it.The Supreme Court of the State of Nevada reviewed the case and held that NRS 613.010 authorizes a civil cause of action when an employee changes their place of employment in response to false or deceptive representations by an employer, even if the employee does not change their place of residence. The court further found that the district court did not abuse its discretion in denying the motion to strike the jury demand. Accordingly, the Supreme Court denied the employer’s petition for a writ of mandamus. View "Field Effect Security, Inc. v. District Court" on Justia Law

These consolidated cases concern the constitutionality of statutory limits on the President’s authority to remove members of the National Labor Relations Board (NLRB) and the Merit Systems Protection Board (MSPB). Both agencies are composed of members appointed by the President with Senate confirmation, and statutes prohibit the President from removing members except for cause. The NLRB oversees labor relations and union elections, with powers including rulemaking, adjudication, and the issuance of affirmative remedies. The MSPB administers federal employment disputes and can issue final orders, award a range of remedies, and promulgate certain regulations.After the President removed Gwynne Wilcox from the NLRB and Cathy Harris from the MSPB—without alleging the statutory grounds for removal—Wilcox and Harris challenged their removals in the United States District Court for the District of Columbia. The District Court held that the statutory protections against removal were constitutional under the precedent of Humphrey’s Executor v. United States, declared Wilcox and Harris remained in office, and enjoined the government from interfering with their roles. The government appealed, and the Supreme Court stayed the district court’s orders pending appeal, signaling skepticism about the constitutionality of the removal restrictions.The United States Court of Appeals for the District of Columbia Circuit reversed the district courts’ judgments. The court held that, under Seila Law LLC v. Consumer Financial Protection Bureau, Congress may not restrict the President’s ability to remove principal officers who wield substantial executive power. The court found that both the NLRB and MSPB exercise powers that are executive in nature and go beyond the quasi-legislative or quasi-judicial functions contemplated in Humphrey’s Executor. Consequently, statutory restrictions on the President’s removal authority for members of these boards are unconstitutional. The court ordered that the removal protections for NLRB and MSPB members be disregarded. View "Harris v. Bessent" on Justia Law

A company that provides temporary labor to various industries offers daily work opportunities to individuals at its labor halls. Workers can choose whether to accept job assignments, and once they do, they are responsible for arriving at the jobsite on time. The company offers several transportation options—including vans, carpools, and public transit—with a nominal fee deducted from paychecks for those who use company-arranged transportation. Workers can also bring their own tools or use company-provided equipment, with deductions only made for unreturned items.A group of workers filed a class action in the United States District Court for the Southern District of Florida, alleging violations of the Fair Labor Standards Act (FLSA) and the Florida Minimum Wage Act. They claimed that transportation deductions reduced their pay below the minimum wage and that the company failed to pay for travel time, time spent collecting tools, and waiting time. The plaintiffs also raised a claim under the Florida Labor Pool Act regarding excessive transportation charges. The district court granted summary judgment to the company on the FLSA and minimum wage claims, denied the plaintiffs’ summary judgment motion, and declined to certify the subclass related to excessive transportation charges.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that the transportation deductions were lawful because the transportation was optional and for the benefit of employees, not the employer. The court further held that time spent traveling, collecting tools, and waiting was not integral and indispensable to the workers’ principal activities and was thus noncompensable under the FLSA. Finally, the court affirmed the district court’s denial of class certification for the excessive-transportation-charge subclass, finding that individual inquiries would predominate. The judgment of the district court was affirmed. View "Villarino v. Pacesetter Personnel Service, Inc." on Justia Law

A deputy sheriff of Arabic descent, employed by the Richmond County Sheriff’s Office, was assigned to an off-duty security position at a local business. During his assignment, he alleged that his supervisor subjected him to repeated racial harassment, including derogatory remarks about his ethnicity. Witnesses at the business supported these allegations, noting that the supervisor frequently made such comments. The deputy was also interested in joining the SWAT team, which the supervisor led, but after failing the SWAT entrance exam, the deputy filed a formal internal complaint about the harassment.Shortly thereafter, the deputy was investigated and ultimately terminated for allegedly violating departmental policy by making personal use of his patrol vehicle, specifically for visiting another county’s sheriff’s office to inquire about job opportunities. The deputy provided evidence that other officers regularly made similar personal use of patrol vehicles without being disciplined, and argued that his termination was in retaliation for his internal complaint. He filed suit under 42 U.S.C. § 1981, claiming retaliatory discharge.The United States District Court for the Southern District of Georgia granted summary judgment for the defendants, finding that the deputy had not shown that the employer’s stated reason for termination was a pretext for retaliation.On appeal, the United States Court of Appeals for the Eleventh Circuit concluded that the District Court erred by conflating the McDonnell Douglas pretext analysis with the “convincing mosaic” standard. The Eleventh Circuit held that a plaintiff may survive summary judgment by presenting circumstantial evidence that creates a triable issue regarding retaliatory intent, even if pretext is not conclusively shown. The court reversed and remanded for the District Court to apply the correct summary judgment standard. View "Ismael v. Roundtree" on Justia Law

In 2015, a firefighter suffered a compensable back injury while working part-time for a fire company. He settled his workers’ compensation claim related to that incident in 2018 by accepting a lump sum and releasing the insurer from future liability. Years later, in 2023, while working for a different fire department, he experienced another back injury while carrying heavy equipment up stairs during a call. Medical evaluations indicated the new injury involved the same area of his spine as the 2015 incident. The firefighter sought workers’ compensation from his current employer, but the claim was denied.The Industrial Accident Board (IAB) held an evidentiary hearing, receiving testimony from the claimant, his treating physician, and an orthopedic surgeon retained by the employer. The Board concluded that the 2023 incident was a recurrence of the 2015 injury—not an aggravation or a new injury—based primarily on the orthopedic surgeon’s opinion and a comparison of medical imaging. Under Delaware law, liability for a recurrence rests with the insurer on the risk for the original injury, while an aggravation caused by a new workplace incident would be covered by the current employer’s insurer. Because the firefighter had already settled and released all claims relating to the 2015 injury, no compensation was available for the 2023 event. The Superior Court of the State of Delaware affirmed the Board’s decision, finding that the correct legal standard had been applied and that the decision was supported by substantial evidence.On appeal, the Supreme Court of the State of Delaware affirmed the Superior Court’s judgment. The Supreme Court held that the IAB and the Superior Court properly applied the standard from Standard Distributing Co. v. Nally for distinguishing between recurrence and aggravation in successive injury cases, and that substantial evidence supported the Board’s finding that the 2023 incident was a recurrence rather than an aggravation or a new injury. View "Corey Ferrell v. City of Wilmington IAB" on Justia Law

The plaintiff was an employee of the Puerto Rico Aqueduct and Sewer Authority and a former member of the relevant labor union. In 2016, he attempted to resign from the union and objected to the continued deduction of union dues from his wages, arguing that compelled dues for non-bargaining activities violated his First Amendment rights. The employer and union, acting under Puerto Rican law and the terms of a collective bargaining agreement, denied his requests, continued to deduct dues, and the plaintiff filed suit seeking declaratory, injunctive, and monetary relief.The United States District Court for the District of Puerto Rico presided over the initial proceedings. After the Supreme Court’s decision in Janus v. American Federation of State, County, and Municipal Employees overruled Abood v. Detroit Board of Education and invalidated mandatory union payments by nonmembers in the public sector, the employer and union ceased deducting dues from the plaintiff. The union then sought to deposit the amount withheld after his resignation, plus interest and nominal damages, with the court. The District Court ultimately granted the union’s request to deposit funds and dismissed the plaintiff’s claims as moot, reasoning that he had received all requested relief. The plaintiff’s subsequent motion to alter or amend the judgment was denied, with the court stating he was entitled to the deposited funds.The United States Court of Appeals for the First Circuit reviewed the appeal. The First Circuit found that the plaintiff was entitled to the funds deposited by the union, rejecting the argument that there was no judgment awarding him monetary relief. However, the court determined that the issue of whether the plaintiff could seek prevailing party attorneys’ fees—potentially affecting mootness—had not been fully addressed below. The First Circuit remanded the case to the District Court for further proceedings on that issue, while retaining jurisdiction over the appeal. View "Cruz v. UIA" on Justia Law

Spring Creek Rehabilitation and Nursing Center purchased a skilled nursing facility previously operated by Amboy Nursing and Rehabilitation Center. Amboy had a longstanding collective bargaining relationship with a union representing its employees, and a dispute arose when Amboy sold the facility to Spring Creek without ensuring that Spring Creek would assume certain monetary obligations to employees under the expired collective bargaining agreement. The union filed unfair labor practice charges with the National Labor Relations Board (NLRB) against both Amboy and, later, Spring Creek, alleging Spring Creek refused to bargain collectively and in good faith.After the NLRB issued a complaint and scheduled a hearing before an administrative law judge (ALJ), Spring Creek filed suit in the United States District Court for the District of New Jersey. Spring Creek sought to enjoin the NLRB proceedings, arguing that NLRB ALJs are unconstitutionally insulated from presidential removal. The District Court denied Spring Creek’s motion for a preliminary injunction, concluding that Spring Creek had not shown it would suffer irreparable harm without the relief. The NLRB administrative hearing subsequently took place, though no decision had been issued at the time of appeal.On appeal, the United States Court of Appeals for the Third Circuit reviewed the District Court’s denial of injunctive relief. The Third Circuit determined that, because the action sought by Spring Creek arose from a labor dispute between Spring Creek and its employees, the Norris-LaGuardia Act deprived the District Court of jurisdiction to issue the requested injunction against the NLRB. The court held that the Act’s anti-injunction provisions broadly apply to cases involving or growing out of labor disputes and that no statutory or judicial exception to the Act applied in this instance. Accordingly, the Third Circuit vacated the District Court’s order and remanded the case for further proceedings consistent with its opinion. View "Spring Creek Rehabilitation and Nursing Center LLC v. NLRB" on Justia Law

A former high school principal alleged that, during her tenure at a small New York school district, she was subjected to gender-based hostility and was ultimately fired because of her sex. The principal, who began her role in 2014, reported to the district superintendent. She claimed the superintendent behaved in a demeaning and discriminatory manner towards her and other women, while treating male employees more favorably. In 2016, she was placed on administrative leave and then terminated. She filed complaints with state and federal agencies and then brought suit against the school district, the board of education, and the superintendent, alleging violations of Title VII and New York State Human Rights Law for discriminatory discharge and hostile work environment.The U.S. District Court for the Northern District of New York granted summary judgment to defendants on the principal’s equal protection claim but allowed her Title VII and state law claims to proceed to trial. After a six-day trial, a jury found in her favor, concluding her gender was a motivating factor in her termination and that she was subjected to a hostile work environment. The jury awarded her nearly half a million dollars in damages, including lost income. The district court denied defendants’ post-trial motions for judgment as a matter of law, a new trial, and reduction of damages.On appeal, the United States Court of Appeals for the Second Circuit reviewed whether the verdict was supported by sufficient evidence, whether lost-income damages were proper, and whether alleged trial errors—including a confusing comment by the district judge about New York law—necessitated a new trial. The Second Circuit held that the jury’s verdict was supported by substantial evidence, the damages award was proper, and any errors during trial did not render it unfair. The court affirmed the judgment of the district court. View "Krause v. Kelahan" on Justia Law

Several current and former employees of the City of Chicago, including police officers and an emergency management officer, challenged the City’s COVID-19 vaccination policy. The policy, issued in October 2021, required city employees to either be vaccinated against COVID-19 or undergo regular testing and report their status through an employee portal. Religious exemptions from vaccination were available and granted to these plaintiffs, but the plaintiffs objected to having to submit their vaccination status and test results in the portal, arguing that this reporting requirement violated their constitutional and statutory rights.The plaintiffs filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, raising claims under Title VII of the Civil Rights Act of 1964, the First and Fourteenth Amendments via 42 U.S.C. § 1983, and the Illinois Religious Freedom Restoration Act (IRFRA). The district court dismissed the Third Amended Complaint for failure to state a claim. It found the Title VII claims factually implausible and concluded that the plaintiffs did not allege a religious practice conflicting with the reporting requirements. The court also held that, since the plaintiffs were granted their requested exemptions from vaccination, they could not succeed on claims based on their refusal to comply with reporting requirements.On appeal, the United States Court of Appeals for the Seventh Circuit reviewed the dismissal de novo. The Seventh Circuit held that the policy’s reporting requirements were neutral and generally applicable, subject only to rational-basis review, which the policy satisfied. The court determined that the reporting and disciplinary provisions were rationally related to the City’s legitimate interest in public health and workplace safety. The court affirmed the district court’s dismissal of all constitutional, statutory, and state-law claims, finding the plaintiffs’ arguments insufficient to state a plausible claim for relief. View "Kondilis v City of Chicago" on Justia Law

An individual received health insurance through his employer, with the plan administered by a third-party insurer. After being injured in a car accident, he recovered damages from the other driver’s employer and, based on communications from his insurer and its agent, paid $25,000 in reimbursement to the plan. He later learned that the full plan document did not contain a reimbursement obligation, contrary to what was represented in the summary plan description. A similar situation occurred when his wife was injured in a separate accident; litigation in state court ultimately resulted in a declaratory judgment that the plan did not provide for reimbursement, and this was affirmed on appeal.The individual then sued the insurer, its agent, and his employer in federal court under the Employee Retirement Income Security Act of 1974 (ERISA), alleging he was defrauded into paying reimbursement. The United States District Court for the Northern District of Ohio dismissed most claims, but allowed one ERISA claim under § 1132(a)(3) to proceed. While his federal appeal was pending, the plaintiff filed state law claims in state court, which were removed to federal court. The district court held that these state law claims were completely preempted by ERISA and dismissed the action, reasoning that the claims were duplicative of the pending federal lawsuit and arose from the same events.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s dismissal. The appellate court held that the plaintiff’s state law claims were completely preempted by ERISA under the standard articulated in Aetna Health Inc. v. Davila, because the claims sought relief for benefits allegedly due under the terms of an ERISA-governed plan and did not rely on a legal duty independent of ERISA or the plan. The court further concluded that dismissal, rather than remand or amendment, was appropriate due to the duplicative nature of the proceedings. View "Patterson v. UnitedHealth Group, Inc." on Justia Law