Justia Labor & Employment Law Opinion Summaries

The case involves tanker-truck drivers employed by Ace Gathering, Inc., who transport crude oil solely within Texas. The drivers, known as Crude Haulers, collect crude oil from oil fields and deliver it to pipeline injection points. Although their routes are entirely within Texas, a significant portion of the crude oil they transport is ultimately destined for out-of-state refineries or export markets. The drivers claim they worked over forty hours a week without receiving overtime pay, alleging they were misclassified as exempt from the Fair Labor Standards Act (FLSA) overtime provisions.The United States District Court for the Southern District of Texas initially denied Ace's motion for summary judgment, which argued that the Motor Carrier Act (MCA) exempted the Crude Haulers from FLSA overtime pay. The district court found that Ace had no vested interest in the crude oil once it crossed state lines and that the volunteer-based interstate driving assignments created a genuine dispute of material fact regarding the drivers' reasonable expectation of interstate travel. Upon reconsideration, the district court certified three questions for interlocutory appellate review.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that the Crude Haulers' transportation of crude oil within Texas constitutes transportation in "interstate or foreign commerce" under the MCA because the oil is ultimately bound for out-of-state destinations. The court noted that the intrastate transport of goods destined for out-of-state locations falls under the MCA's definition of interstate commerce. Consequently, the court reversed the district court's denial of summary judgment and remanded the case with instructions to dismiss the plaintiffs' claims with prejudice. View "Escobedo v. Ace Gathering" on Justia Law

The case involves a dispute over the constitutionality of "release time" provisions in a memorandum of understanding (MOU) between the City of Phoenix and the American Federation of State, County, and Municipal Employees, Local 2384. These provisions allow certain employees to be released from their regular duties, while still being paid by the City, to perform union activities. The plaintiffs, who are non-union employees, argued that these provisions violate their free-speech, free-association, and right-to-work rights, as well as the Gift Clause of the Arizona Constitution.The Superior Court in Maricopa County granted summary judgment in favor of the City and the Union, finding that the release time provisions did not violate the plaintiffs' constitutional rights because the City, not the employees, paid for the release time. The court also found that the provisions did not violate the Gift Clause, as they served a public purpose and were supported by adequate consideration. The plaintiffs appealed, and the Court of Appeals affirmed the lower court's decision, agreeing that the provisions did not violate the plaintiffs' rights and were supported by adequate consideration.The Arizona Supreme Court reviewed the case and concluded that the release time provisions do not violate the free-speech, free-association, or right-to-work rights of the plaintiffs because the City pays for the release time. However, the Court found that the provisions violate the Gift Clause of the Arizona Constitution. The Court determined that the release time provisions do not provide adequate consideration to the City, as the benefits to the City are negligible compared to the substantial costs. Consequently, the Court vacated the Court of Appeals' opinion, reversed the Superior Court's decision, and remanded the case for the entry of judgment in favor of the plaintiffs on the Gift Clause claim. View "GILMORE v. GALLEGO" on Justia Law

Gena Cain Davis, a correctional officer, filed a workers' compensation claim in July 2016, alleging injuries from a slip-and-fall accident. She later requested a hearing, which she withdrew, leading to the South Carolina Department of Corrections (SCDC) suspending her temporary disability compensation and filing a request to stop payments. Davis filed another hearing request, which was also withdrawn. The single commissioner allowed the withdrawal without prejudice and dismissed SCDC's stop-payment request.The South Carolina Workers' Compensation Commission's Appellate Panel upheld the dismissal of the stop-payment request but reversed the withdrawal without prejudice, claiming the single commissioner lacked jurisdiction. The court of appeals vacated the Appellate Panel's decision, stating the single commissioner's ruling was interlocutory and not immediately reviewable, and remanded the case to the Commission.The South Carolina Supreme Court reviewed the case and affirmed the court of appeals' decision as modified. The Supreme Court held that the single commissioner's order was interlocutory and not an "award" subject to immediate review by the Appellate Panel under section 42-17-50. The court clarified that the single commissioner had jurisdiction to rule on the issue of prejudice and reinstated the single commissioner's ruling. The case was remanded to the Commission for further proceedings, urging an expeditious resolution of the claim's merits. View "Davis v. SCDC" on Justia Law

The United States Capitol Police (USCP) faced allegations of unfair labor practices after it suspended its collective bargaining agreement (CBA) with the Fraternal Order of Police due to the COVID-19 pandemic. The USCP argued that the suspension was necessary to quickly implement changes to protect its workforce. The Union contended that the USCP failed to provide proper notice and did not negotiate the changes, violating the Federal Service Labor-Management Relations Statute (FSLMRS).The Office of Congressional Workplace Rights (OCWR) General Counsel filed a complaint against the USCP, and a hearing officer granted summary judgment in favor of the General Counsel and the Union. The hearing officer found that the USCP committed unfair labor practices by suspending the CBA, failing to reinstate non-interfering provisions, and not bargaining over changes to employment conditions. The USCP appealed to the OCWR Board of Directors, which affirmed the hearing officer's decision in part, concluding that the USCP did not provide the Union with specific and definitive notice of the changes.The United States Court of Appeals for the Federal Circuit reviewed the case and found that genuine issues of material fact precluded the grant of summary judgment. The court noted that it was unclear which changes listed in the Hoyer Letter were subject to bargaining and whether the Union had adequate notice of these changes. The court emphasized that not all changes mentioned in the letter necessarily constituted changes in conditions of employment. Additionally, there was evidence suggesting that the USCP and the Union communicated regularly about the COVID-19 response, which could indicate that the Union had sufficient notice.The Federal Circuit reversed the Board's decision to grant summary judgment and remanded the case for further proceedings to determine the specific changes that required bargaining and whether the Union received adequate notice. View "UNITED STATES CAPITOL POLICE v. OCWR " on Justia Law

The defendant, Benjamin Sargent, was the chief of the Litchfield Police Department (LPD) and was convicted of official oppression for violating the sexual harassment policies of LPD and the Town of Litchfield. The conviction stemmed from his communications with a probationary police officer on December 31, 2021, and January 1, 2022, during which he made suggestive comments, expressed romantic interest, and implied that she could advance in her career if she "stuck with him."The Circuit Court (Derby, J.) found Sargent guilty, concluding that he sought to benefit himself by obtaining emotional support and validation from the complainant. The court also denied Sargent's motion to dismiss, which argued that the statute was void for vagueness and overbreadth.The Supreme Court of New Hampshire reviewed the case and determined that the trial court had interpreted the phrase "to benefit himself" too broadly. The Supreme Court concluded that the term should be understood to mean seeking a specific advantage or gain, rather than a momentary personal, emotional, or psychological benefit. The court found that the evidence was insufficient to prove beyond a reasonable doubt that Sargent sought such a specific benefit in his communications with the complainant.As a result, the Supreme Court of New Hampshire reversed the conviction, holding that the trial court's interpretation of "to benefit himself" was incorrect and that the evidence did not support the conclusion that Sargent acted with the purpose of obtaining a specific benefit as required by RSA 643:1. View "State v. Sargent" on Justia Law

The case involves a dispute between Judge Kerry L. Burman, the Glendive City Judge, and Mayor Deb Dion of Glendive, Montana. Judge Burman petitioned for a writ of mandamus to reinstate Mary York to her position as Clerk of Glendive City Court after Mayor Dion terminated York's employment. The termination occurred following a disagreement over the justification for York's attendance at a training conference. York was terminated without notice and escorted out of the court, leaving unfinished work and causing operational disruptions.The District Court initially ordered York's interim reinstatement pending further review. Judge Burman argued that Mayor Dion's actions violated state statute, the court's holding in Carlson v. City of Bozeman, and the constitutional doctrine of separation of powers. Respondents contended that Mayor Dion had the statutory authority to terminate York, who was still in her probationary period, and that the court's operations were not significantly impaired.The Supreme Court of the State of Montana reviewed the case. The court determined that the matter was more appropriately characterized as an application for a writ of prohibition rather than mandamus. The court found that Mayor Dion's actions disrupted the court's operations and violated § 3-1-111, MCA, which grants courts the authority to control their ministerial officers. The court held that the executive's authority to hire or fire employees must be exercised in a manner that does not impair the court's ability to conduct its business.The Supreme Court of Montana granted the petition for a writ of prohibition, arresting Mayor Dion's action of terminating York's employment. The court emphasized the need for coordination between branches of government to avoid such disruptions. View "Burman v. City of Glendive" on Justia Law

Jason Beckner, employed by Commercial Air, Inc., was injured while working on a construction site in Zionsville, Indiana. Commercial Air had rented a crane and operator from Maxim Crane Works, L.P. for a day to lift roof trusses. Beckner claimed that the crane operator, Emmitt Pugh, caused his injury through negligent operation. Beckner and his wife sued Maxim Crane for negligence, asserting vicarious liability.The case was initially filed in Indiana state court but was removed to the United States District Court for the Southern District of Indiana based on diversity jurisdiction. Maxim Crane moved to dismiss the case, arguing that Indiana’s Worker’s Compensation Act barred the suit because Pugh was a co-employee of Beckner. The district court denied the motion to dismiss but later granted summary judgment in favor of Maxim Crane, ruling that Pugh was also employed by Commercial Air, making the Worker’s Compensation Act Beckner’s exclusive remedy.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that genuine issues of material fact existed regarding whether Pugh was an employee of Commercial Air. The court noted conflicting evidence about who controlled Pugh’s work and whether Commercial Air believed it employed Pugh. The court applied both the seven-factor test from Hale v. Kemp and the ten-factor test from Moberly v. Day, concluding that factual disputes precluded summary judgment.The Seventh Circuit vacated the district court’s judgment and remanded the case for further proceedings to resolve these factual issues. View "Beckner v. Maxim Crane Works, L.P." on Justia Law

Karl Von Derhaar, an employee at the New Orleans Crime Lab, raised concerns about safety breaches and inaccuracies in a drug-testing method. Instead of addressing these concerns, the Lab mandated that all employees, including Von Derhaar, be tested using the disputed method. Von Derhaar requested unpaid leave, and his supervisor, Sergeant Michael Stalbert, attempted to contact him at home. After initially going to the wrong apartment, Stalbert returned with two armed officers. Von Derhaar, standing in his doorway, declined to speak with Stalbert, who then forcibly entered the apartment, claiming it was a wellness check. Despite no visible signs of distress, Stalbert ordered Von Derhaar out of his home, where another supervisor, Lieutenant Kim Williams, awaited. Von Derhaar was then taken to the Police Integrity Bureau (PIB) headquarters against his will.The United States District Court for the Eastern District of Louisiana reviewed the case. The court granted summary judgment to the City of New Orleans and its police superintendent on all claims, finding no municipal liability. On the search claim, the court granted summary judgment to Williams and Officer Khalid Watson but denied it to Stalbert. On the seizure claim, the court denied summary judgment to Stalbert, Williams, and Khalid Watson. These decisions led to the current appeals and cross-appeals.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court dismissed the appeals regarding the denial of summary judgment to Stalbert on punitive damages, the summary judgment to Khalid Watson on the search claim, and the summary judgment to the City and superintendent. The court affirmed the denial of summary judgment to Stalbert on the search and seizure claims, finding material fact disputes. However, it reversed the denial of summary judgment to Williams and Khalid Watson on the seizure claim, concluding that they acted under orders and did not violate clearly established law. The case was remanded for further proceedings. View "Von Derhaar v. Watson" on Justia Law

Irma Leibas, a correctional officer at the Cook County Department of Corrections (DOC), has pre-existing medical conditions requiring workplace accommodations, including up to three additional breaks per shift. After the DOC denied her request for these accommodations, Leibas sued, alleging violations of the Americans with Disabilities Act (ADA).The United States District Court for the Northern District of Illinois initially denied the defendants' motion for summary judgment on Leibas’s accommodation and discrimination claims. However, upon reconsideration and after both parties supplemented the record, the district court granted summary judgment in favor of the defendants, concluding that Leibas was not a qualified individual under the ADA.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision de novo. The appellate court examined whether Leibas could perform the essential functions of her position with or without reasonable accommodation. The court found that maintaining the safety and security of the DOC is an essential function of a correctional officer. Leibas’s requested accommodation of additional breaks, including rest periods, was deemed unreasonable given the unpredictable and violent environment of the DOC, which requires officers to be able to stand for long periods and respond to emergencies without delay. The court also noted that the DOC’s staffing shortages and the need for continuous coverage further complicated the feasibility of Leibas’s requested accommodations.The Seventh Circuit affirmed the district court’s judgment, holding that Leibas did not provide sufficient evidence to create a genuine dispute of material fact that she could perform the essential functions of her position with the requested accommodations. View "Leibas v. Dart" on Justia Law

Timothy Mullins, a coal miner, suffered an ankle stress fracture in 2015 while working as a Section Supervisor at a coal mine owned by CONSOL Energy, Inc. He initially received long-term disability benefits under CONSOL's ERISA-governed Long-Term Disability Plan, administered by Lincoln Financial Group. However, his benefits were terminated in 2020 after Lincoln determined, based on medical evaluations and a vocational assessment, that Mullins did not demonstrate "total disability" as required under the Plan. Lincoln's decision was based on a vocational report that incorrectly listed Mullins's job as "Mine Superintendent" rather than Section Supervisor.The United States District Court for the Western District of Pennsylvania upheld Lincoln's decision to terminate Mullins's benefits, granting summary judgment in favor of the Plan. The District Court found that Lincoln's decision was supported by substantial medical and vocational evidence and was not arbitrary and capricious. Mullins appealed the decision, arguing that Lincoln's reliance on the incorrect job title in the vocational report led to an erroneous termination of his benefits.The United States Court of Appeals for the Third Circuit reviewed the case and found that Lincoln's reliance on the incorrect vocational report was arbitrary and capricious. The court noted that the error in the job title led to an incorrect assessment of Mullins's qualifications and experience, which in turn resulted in the wrongful termination of his benefits. The Third Circuit vacated the District Court's judgment and remanded the case for reinstatement of Mullins's long-term disability benefits. The court also instructed the District Court to consider Mullins's claim regarding the improper offset of benefits due to Social Security disability benefits. View "Mullins v. Consol Energy Inc Long Term Disability Plan" on Justia Law