Justia Labor & Employment Law Opinion Summaries

North Mountain Foothills Apartments (NMFA), a company managing a large apartment complex in Phoenix, Arizona, hired Jasper Press as a maintenance technician during a period of increased workload due to a heatwave. Press discussed his compensation and the poor conditions at the complex with several coworkers. Management became aware that other employees knew about Press’s pay and housing benefits, leading to a meeting where Press was reprimanded for these discussions and told not to talk about pest issues with residents. The day after this meeting, Press was terminated, allegedly for failing to complete work orders. Press filed a complaint with the National Labor Relations Board (NLRB), alleging unfair labor practices.An administrative law judge held an evidentiary hearing and found that NMFA violated Section 8(a)(1) of the National Labor Relations Act by interrogating Press about his wage discussions, issuing overly broad directives restricting such discussions, threatening reprisals, and discharging Press for engaging in protected activities. The NLRB adopted these findings and ordered remedies including reinstatement and back pay for Press. NMFA appealed, raising for the first time constitutional challenges to the NLRB’s structure and process, and also contested the Board’s factual findings.The United States Court of Appeals for the Ninth Circuit held that it had jurisdiction to consider NMFA’s unexhausted constitutional claims because such structural challenges are not suited to agency resolution. The court rejected NMFA’s Article II removal protection challenge for lack of demonstrated harm, found no Seventh Amendment right to a jury trial in NLRB proceedings, and held that the combination of investigatory and adjudicatory functions within the NLRB does not violate due process. On the merits, the court found substantial evidence supported the NLRB’s finding that Press was discharged for protected activity and granted enforcement of the NLRB’s order. View "NATIONAL LABOR RELATIONS BOARD V. NORTH MOUNTAIN FOOTHILLS APARTMENTS, LLC" on Justia Law

A physician specializing in physical medicine and rehabilitation was employed by a medical practice under a three-year contract that anticipated partnership if not terminated. After patient and staff complaints about her conduct, the practice proposed a new one-year contract without a partnership track, which she refused to sign. She was then terminated with 90 days’ notice. The physician alleged that her termination was due to age and sex discrimination, as well as retaliation for stating her intent to file an EEOC complaint, and also brought a breach of contract claim.After discovery, the defendants moved for summary judgment in the United States District Court for the Eastern District of New York. A Magistrate Judge recommended granting summary judgment to the defendants on all claims. The District Judge reviewed the report and recommendation (R&R) only for clear error, concluding that the physician’s objections were improper because they repeated arguments made before the Magistrate Judge, and adopted the R&R in full. The physician appealed, arguing that her objections were timely and specific, and that the District Judge should have conducted de novo review.The United States Court of Appeals for the Second Circuit held that the District Court erred in applying only clear error review, as the physician’s objections were proper and required de novo review. However, the appellate court found this error harmless because it reviews summary judgment decisions de novo. On its own review, the Second Circuit concluded that the physician failed to establish a genuine dispute of material fact on her preserved claims of sex discrimination, aiding and abetting discrimination, and retaliation. The court also found that her age discrimination and breach of contract claims were not preserved for appellate review. The Second Circuit affirmed the District Court’s judgment granting summary judgment to the defendants. View "Nambiar v. The Central Orthopedic Group, LLP" on Justia Law

Giovanni Irizarry Sierra worked as an Attorney Advisor for the Social Security Administration (SSA) in Puerto Rico and was terminated in March 2019 for unsatisfactory performance. He subsequently filed a complaint with the SSA’s Office of Civil Rights and Equal Opportunity (OCREO), alleging that his termination was the result of discrimination and retaliation. The OCREO reorganized his allegations, dismissing one as untimely and bifurcating the remainder into pre-termination and termination discrimination claims. The termination claim was treated as a “mixed case” because it involved both discrimination and an adverse personnel action.After receiving a report of investigation, Irizarry requested a hearing before an Equal Employment Opportunity Commission (EEOC) Administrative Judge (AJ). The AJ dismissed the termination claim for lack of jurisdiction, explaining that mixed cases must proceed through the Merit Systems Protection Board (MSPB), not the EEOC. Irizarry then appealed his termination claim to the MSPB, which sustained his removal and notified him that he had thirty days from the final decision to seek judicial review in federal district court. Irizarry did not file within that period. Later, the OCREO erroneously issued a Final Agency Decision (FAD) on the termination claim, which was subsequently rescinded.Irizarry filed suit in the United States District Court for the District of Puerto Rico, relying on the rescinded FAD. The SSA moved to dismiss, arguing the complaint was untimely and the FAD was issued in error. The district court granted the motion, finding the claims time-barred and rejecting Irizarry’s arguments for equitable tolling and estoppel.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The court held that Irizarry’s claim was untimely because he failed to file within thirty days of the MSPB’s final decision, and equitable relief was not warranted. View "Irizarry Sierra v. Bisignano" on Justia Law

In 2024, Minnesota enacted a law that revised the criteria for classifying independent contractors in the construction industry, expanding a previous nine-part test to a fourteen-part test. Several construction industry organizations and a general contractor challenged the law, arguing that certain provisions were unconstitutionally vague and that the civil penalties authorized by the statute violated the Excessive Fines Clause of the Eighth Amendment. The plaintiffs specifically objected to requirements regarding written contracts, invoicing, expense responsibility, and profit or loss realization, as well as the potential for significant civil penalties for noncompliance.The United States District Court for the District of Minnesota denied the plaintiffs’ request for a preliminary injunction to prevent enforcement of the law. The court found that the plaintiffs had not demonstrated a likelihood of success on the merits of their constitutional claims. The plaintiffs then appealed this decision to the United States Court of Appeals for the Eighth Circuit.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The appellate court held that the plaintiffs had standing to challenge the law, as they alleged specific conduct targeted by the statute and faced a credible threat of enforcement. However, the court concluded that the challenged statutory terms were sufficiently clear for people of ordinary intelligence and did not encourage arbitrary or discriminatory enforcement. The court also determined that the plaintiffs’ excessive fines claim was premature, as no penalties had yet been imposed and Minnesota law requires a proportionality analysis before penalties are assessed. Because the plaintiffs failed to show a likelihood of success on the merits, the court found no basis for a preliminary injunction and affirmed the lower court’s judgment. View "MN Chapter of Assoc. Builders v. Blissenbach" on Justia Law

The plaintiff was employed as a senior director of finance at a data management software company, which later rebranded following a merger. Initially hired full time, the plaintiff’s position was later reduced to part time with a corresponding salary adjustment. Around this time, the plaintiff and the company entered into a retention bonus agreement, which provided for two bonus payments if the plaintiff remained employed and in good performance standing, with no reduction in work schedule, through two specified dates. The agreement also required the plaintiff to return the bonus if he left voluntarily or was terminated for cause before those dates. The plaintiff remained employed through both retention dates and received both bonus payments, though the second payment was made eight days after his termination due to a reduction in force.The plaintiff filed suit in the Concord Division of the District Court Department, asserting, among other claims, that the company violated the Massachusetts Wage Act by failing to pay the second retention bonus on his last day of employment. Both parties moved for summary judgment, which were denied without explanation. Upon reconsideration, a different District Court judge entered judgment for the defendants, finding that the retention bonus was not a “wage” under the Wage Act because it was contingent compensation. The Appellate Division of the District Court Department affirmed this decision, and the plaintiff sought further review.The Supreme Judicial Court of Massachusetts granted direct appellate review. It held that retention bonus payments conditioned on continued employment and other requirements are not “wages” under the Wage Act, but rather constitute additional, contingent compensation. The court affirmed the judgment in favor of the defendants, concluding that the Wage Act did not apply to the retention bonus payments at issue. View "Nunez v. Syncsort Incorporated" on Justia Law

A middle school math teacher employed by a Minneapolis public school was injured while playing basketball with students during an afterschool practice. The teacher participated in the activity to strengthen relationships with students, which was encouraged by the school’s administration and reflected in the school’s mission and teacher evaluation standards. The injury, a ruptured ACL, occurred approximately 30 minutes after the official end of the teacher’s workday, at the school gym, and required surgery and time off work. The teacher sought workers’ compensation benefits, but the self-insured school district denied liability, arguing the injury did not arise out of or in the course of employment and was excluded under a statutory provision for injuries incurred during voluntary employer-sponsored recreational programs.After an administrative hearing, a workers’ compensation judge found the injury compensable, concluding it arose out of and in the course of employment, and that the statutory exclusion for voluntary recreational programs did not apply because the activity was for the benefit of students, not employees. The school district appealed to the Workers’ Compensation Court of Appeals (WCCA), which affirmed the compensation judge’s decision, agreeing that the exclusion did not bar the claim and that the injury occurred in the course of employment.The Minnesota Supreme Court reviewed the case. It held that the teacher’s injury occurred “in the course of” employment under Minnesota Statutes section 176.021, subdivision 1, because the injury happened at the workplace, within a reasonable time after the workday, and during an employment-related activity. The Court further held that the exclusion in section 176.021, subdivision 9, applies only to voluntary employer-sponsored recreational programs that are for the benefit of employees, not students. The Supreme Court affirmed the WCCA’s decision. View "Lindsay vs. Minneapolis Public School District (SSD1)" on Justia Law

A 69-year-old employee of the Cook County Sheriff’s Office, who previously had a long career with the Chicago Police Department, was terminated from his position as Assistant Chief of the Electronic Monitoring Unit. The termination followed an internal investigation into his work performance, which included allegations that he was absent from his post without authorization, failed to communicate with his team, and used work hours and resources for personal business. The investigation, initiated after a complaint by his supervisor, involved interviews with colleagues and a review of GPS and work records, ultimately concluding that he had neglected his duties on multiple occasions.After his termination, the employee filed suit in the United States District Court for the Northern District of Illinois, Eastern Division, against his supervisor in her individual capacity and the Sheriff in his official capacity, alleging age discrimination under the Fourteenth Amendment (via 42 U.S.C. § 1983), the Age Discrimination in Employment Act (ADEA), and the Illinois Human Rights Act (IHRA). He also brought an indemnification claim against Cook County. During discovery, he presented affidavits from other older officers alleging ageist comments and discriminatory treatment by the same supervisor. The district court granted summary judgment for all defendants, finding insufficient evidence of age-based disparate treatment or causation.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment. The appellate court held that the plaintiff failed to identify similarly situated comparators who were treated more favorably, and that the evidence did not support a finding that any alleged discriminatory animus by the supervisor proximately caused the termination. The court also found that the internal investigation and the ultimate decisionmaker’s independent review provided legitimate, non-discriminatory reasons for the termination, precluding liability under the Fourteenth Amendment, ADEA, and IHRA. View "Gaines v Dart" on Justia Law

The plaintiff worked as an Admissions Coordinator at a Maryland hospital’s Center for Eating Disorders, where her duties required frequent in-person contact with medically vulnerable patients and other staff. During the COVID-19 pandemic, the hospital implemented a vaccine mandate for all employees, following state health directives and public health guidance. The hospital allowed employees to request religious or medical exemptions, evaluating each on a case-by-case basis. The plaintiff requested a religious exemption, which was denied after the hospital determined her role could not be performed remotely and that accommodating her would pose risks to patient safety. She was terminated after refusing vaccination.After her termination, the plaintiff filed a discrimination charge with the EEOC and then sued the hospital in the United States District Court for the District of Maryland, alleging a violation of Title VII for failure to accommodate her religious beliefs. The district court granted summary judgment to the hospital, finding that exempting the plaintiff from the vaccine requirement would have created an undue hardship by jeopardizing patient safety and increasing the risk of COVID-19 outbreaks in a sensitive healthcare environment.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit held that, under the standard clarified by the Supreme Court in Groff v. DeJoy, the hospital met its burden to show that granting the requested religious accommodation would have resulted in substantial increased costs and significant health and safety risks, both to patients and staff. The court also found that the hospital properly considered alternative accommodations and the aggregate impact of granting similar exemptions. The Fourth Circuit affirmed the district court’s judgment in favor of the hospital. View "Hall v. Sheppard Pratt Health System" on Justia Law

Several healthcare employees in Colorado, including those at the University of Colorado Hospital Authority and South Denver Cardiology Associates, were terminated after refusing to comply with their employers’ COVID-19 vaccination mandates. These mandates, implemented in 2021, required employees to either be vaccinated or obtain a medical or religious exemption. The plaintiffs declined vaccination and did not seek exemptions, resulting in their dismissal.Following their terminations, the plaintiffs filed separate lawsuits in the United States District Court for the District of Colorado, asserting nearly identical claims. They alleged violations of statutory, constitutional, and contractual rights, including claims under 42 U.S.C. § 1983, state-law breach of contract and tort claims, and an implied private right of action under the Food, Drug, and Cosmetic Act. The defendants moved to dismiss on grounds such as sovereign immunity, qualified immunity, and failure to state a claim. The district courts dismissed all claims, finding that the plaintiffs had not adequately pled any viable legal theory. The courts also denied the plaintiffs’ requests to amend their complaints after judgment was entered.On appeal, the United States Court of Appeals for the Tenth Circuit reviewed the dismissals de novo. The court held that none of the statutes cited by the plaintiffs—including the Emergency Use Authorization statute, the PREP Act, and 10 U.S.C. § 980—unambiguously conferred individual rights enforceable under § 1983. The court also found that the constitutional claims, including those based on due process and equal protection, were not adequately pled and that the breach of contract claim was waived for lack of argument. The Tenth Circuit affirmed the district courts’ judgments, holding that the plaintiffs failed to state any claim upon which relief could be granted and that the lower courts did not abuse their discretion in denying leave to amend. View "Timken v. South Denver Cardiology Associates" on Justia Law

A group of building engineers and craftsmen represented by a union worked at several stores operated by a large retail company. After the company and the union failed to reach agreement on a new collective bargaining agreement, the union members voted to reject the company’s final offer and began a strike. The company’s final offer expired, and after three months on strike, the union ended the strike and made an unconditional offer for its members to return to work. The company then locked out the union members who reported for work, stating it would not reinstate them until a new agreement was in place. The union filed a charge with the National Labor Relations Board (NLRB), alleging that the lockout was an unfair labor practice.An Administrative Law Judge (ALJ) held a hearing and found that the company violated Sections 8(a)(1) and (3) of the National Labor Relations Act by locking out employees without providing a timely, clear, and complete offer setting forth the conditions necessary to avoid the lockout. The ALJ recommended reinstatement and make-whole relief for affected employees. The NLRB adopted the ALJ’s findings, modifying the remedy to include compensation for any direct or foreseeable pecuniary harms resulting from the lockout.The United States Court of Appeals for the Ninth Circuit reviewed petitions from both the union and the company, as well as the NLRB’s application for enforcement. The court held that it had jurisdiction, found substantial evidence supporting the NLRB’s conclusion that the lockout was unlawful, and determined that the NLRB did not abuse its discretion in fashioning remedies. The court enforced the NLRB’s order, holding that the company’s lockout violated the Act because employees were not clearly and fully informed of the conditions for reinstatement, and that the NLRB’s make-whole relief, as ordered, was within its authority. The court denied both the union’s and the company’s petitions for review and granted enforcement of the NLRB’s order. View "MACY'S INC. V. NATIONAL LABOR RELATIONS BOARD" on Justia Law