Justia Labor & Employment Law Opinion Summaries

The case revolves around a workers' compensation claim filed by Christine Coray after she was injured at her workplace, Idaho Regional Hand & Upper Extremity Center. Following her injury, Coray's physician recommended back surgery. However, after an independent medical examination (IME) requested by her employer and its surety, they denied liability for the surgery and ongoing benefits, arguing that Coray had recovered from the workplace injury and that the surgery was necessitated by preexisting conditions. After undergoing surgery outside of the workers' compensation system, her employer requested a second IME by a different physician. Coray refused and sought a declaratory ruling from the Idaho Industrial Commission on whether the employer must use the same physician for multiple examinations of a single injury.The Idaho Industrial Commission ruled that the employer or surety is not required to use the same physician for multiple examinations of a single injury under Idaho Code section 72-433. However, it also held that each request for an IME is subject to a reasonableness standard, and the burden of proof for establishing reasonableness falls on the employer. Coray appealed this interpretation, while the employer cross-appealed the Commission's conclusion that it bears the burden of proving the reasonableness of a second IME.The Supreme Court of the State of Idaho affirmed the Idaho Industrial Commission's decision. It held that the plain language of Idaho Code section 72-433 does not prohibit an employer or surety from using different physicians to perform multiple examinations of a single injury. The court also affirmed the Commission's ruling that the employer bears the burden of establishing the reasonableness of its requested IME, including its choice of physician, if raised by the employee. View "Coray v. Idaho Regional Hand & Upper Extremity Center" on Justia Law

Dominique Keeton, an employee of Tesla, Inc., filed a lawsuit against her employer alleging discrimination, harassment, and retaliation. The parties agreed to resolve the dispute through arbitration as per their employment agreement. However, when Tesla failed to pay its arbitration fees within the stipulated 30-day window, Keeton moved to vacate the order submitting the dispute to arbitration. The trial court granted Keeton's motion, ruling that Tesla had materially breached the arbitration agreement, thereby allowing Keeton to proceed with her claims in court.Tesla appealed the decision, arguing that the trial court erred in granting Keeton's motion to vacate. Tesla's arguments were threefold: the arbitration agreement delegated issues of arbitrability to the arbitrator; the Federal Arbitration Act (FAA) preempts the relevant section of the California Code of Civil Procedure; and the same section of the California Code of Civil Procedure constitutes an unconstitutional impairment of the arbitration agreement.The Court of Appeal of the State of California, First Appellate District, disagreed with Tesla's arguments and affirmed the trial court's decision. The court found that the arbitration agreement did not clearly delegate issues of arbitrability to the arbitrator. It also held that the FAA did not preempt the relevant section of the California Code of Civil Procedure, and that this section did not unconstitutionally impair the arbitration agreement. The court concluded that Tesla had materially breached the arbitration agreement by failing to pay its arbitration fees within the stipulated time, and thus Keeton was entitled to proceed with her claims in court. View "Keeton v. Tesla" on Justia Law

In February 2015, Samuel Paulino was injured while working as a custodian at Diversified Coatings, Inc. Despite undergoing surgery and various treatments, Paulino continued to experience persistent pain and limited mobility. His doctors assigned him impairment ratings of 12% to his lumbar spine and 13% to his whole person. Paulino argued that he was permanently and totally disabled under South Carolina law, which presumes total and permanent disability where there is a 50% or more loss of use of the back.The South Carolina Workers' Compensation Commission awarded Paulino total and permanent disability benefits, finding that he had sustained a 50% or greater loss of use to his back. However, the Court of Appeals reversed this decision, stating that there was no medical evidence in the record to support the Commission's findings.The South Carolina Supreme Court disagreed with the Court of Appeals, stating that the lower court had misapplied the "substantial evidence" standard for reviewing decisions of the Commission. The Supreme Court noted that the Commission's decision was not solely based on medical evidence, but also considered Paulino's testimony about his pain and limitations, as well as the results of his functional capacity evaluation. The Supreme Court held that the Commission's award was supported by substantial evidence and should have been affirmed. Therefore, the Supreme Court reversed the decision of the Court of Appeals and reinstated the Commission's award. View "Paulino v. Diversified Coatings, Inc." on Justia Law

A group of medical providers sued a former employee for breach of an employment agreement. The employee counterclaimed, alleging he was owed unpaid wages and bonuses. The providers initially raised "failure to state a claim" as their sole affirmative defense. However, after nearly four years of litigation, they attempted to argue for the first time that the contract was illegal and therefore void. The lower court found that the providers had waived this affirmative defense and issued a judgment in favor of the employee. The providers appealed, and the Court of Civil Appeals reversed, concluding that the lower court had abused its discretion by refusing to consider the providers' claim of illegality.The Supreme Court of the State of Oklahoma disagreed with the Court of Civil Appeals. It held that the trial judge did not abuse her discretion in striking the providers' last-minute effort to raise a new affirmative defense. The court noted that the providers had failed to raise the illegality defense in their initial responsive pleading and did not seek to amend their answer in a timely manner. Furthermore, the providers did not raise the illegality defense until after the trial court had already awarded summary judgment to the employee on the issue of breach of contract, more than ten months after the close of discovery, more than nine months after the lower court's deadline for filing dispositive motions, and almost four years after the original lawsuit was filed. The court concluded that the record was sufficient to support a finding that the providers' delay was unjustified and prejudicial. The court vacated the opinion of the Court of Civil Appeals, affirmed the trial court's order striking the illegality affirmative defense, and remanded the case to the Court of Civil Appeals to resolve any remaining undecided issues raised in the appeal. View "Tulsa Ambulatory Procedure Center v. Olmstead" on Justia Law

The case involves Lusardi Construction Company (Lusardi), a prime contractor, and its subcontractor, Pro Works Contracting Inc. (Pro Works). Pro Works violated certain Labor Code provisions by failing to hire apprentices for a construction project. The Department of Industrial Relations and the Division of Labor Standards Enforcement (DLSE) cited Pro Works for these violations and ordered Lusardi to pay penalties. Lusardi's administrative appeal was unsuccessful, and it subsequently filed a petition for writ of administrative mandamus, which the superior court denied. Lusardi argued that the superior court erroneously concluded that it knew of Pro Works's violations and that the joint and several liability provision applied.The Superior Court of San Diego County affirmed the DLSE's decision, concluding that Lusardi had knowledge of Pro Works's violations and was liable for the penalties. The court also found that substantial evidence supported the findings relating to the amount of the penalty assessment. The court rejected Lusardi's claim of due process violations, stating that Lusardi was put on notice of the potential for being held jointly and severally liable for Pro Works’s apprentice hiring violations.The Court of Appeal, Fourth Appellate District Division One State of California affirmed the lower court's decision. The court held that the superior court did not err in interpreting the statute, which provides two inclusive and alternative ways for imposing liability on a prime contractor for penalties resulting from the subcontractor’s violations. The court also found that substantial evidence supported the penalty imposed. The court concluded that Lusardi was not denied due process when it refused to enforce its subpoena or ask for a continuance to secure the witness’s attendance. View "Lusardi Construction Co. v. Dept. of Industrial Rel." on Justia Law

Spencer Mathis and Jaden Fenstermaker, who worked as delivery drivers for Amazon in Tulsa, Oklahoma, were fired by their employer, James Kerr, after Mathis filed a workers' compensation claim. The plaintiffs alleged that Kerr had retaliated against them for pursuing the claim and filed a lawsuit against him. Kerr moved to compel arbitration based on the arbitration provisions in the plaintiffs' employment contracts. The plaintiffs objected, arguing that federal and state law exempted them from arbitration.The trial court granted Kerr's motion to compel arbitration and stayed the lawsuit until the completion of arbitration. The plaintiffs appealed this decision, but the Court of Civil Appeals affirmed the trial court's ruling.The Supreme Court of the State of Oklahoma granted certiorari to review the case. The court held that employees who deliver Amazon packages are exempt from arbitration under federal law. The court also found that the district court's exclusive jurisdiction over retaliatory discharge claims precluded arbitration of those claims under Oklahoma law. The court reversed the trial court's decision, vacated the Court of Civil Appeals' opinion, and remanded the case for further proceedings. View "MATHIS v. KERR" on Justia Law

The case involves Sherold D. Roaf, who was rear-ended by Francisco Ortiz, an employee of Medstar. Roaf sued Ortiz for negligence and Medstar for both vicarious liability for Ortiz's negligent driving and direct liability for Medstar's negligent hiring, supervision, and retention of Ortiz. Roaf sought compensatory and economic damages but did not seek punitive damages. Medstar admitted liability for the incident but did not move to dismiss the negligent hiring claim. Instead, it sought to prevent Roaf from introducing Ortiz’s personnel record and driving history, arguing that such evidence would be irrelevant and could improperly influence the jury. The trial court denied the motion, allowing Roaf to pursue both theories of liability.The Superior Court in Maricopa County allowed the case to proceed to trial, where Roaf's counsel introduced evidence of Ortiz's driving record and Medstar's hiring policy. The jury found Roaf's full damages to be $4.625 million, allocating 40% fault to Ortiz and 60% to Medstar. Medstar moved for a new trial, arguing that the negligent hiring claim was superfluous and had allowed Roaf to put prejudicial evidence before the jury. The court denied the motion, finding that the evidence of Ortiz’s driving history had no unfair influence and that the damage award was supported by other evidence.The Court of Appeals upheld the trial court's decision, agreeing that the jury’s award was appropriate based on the evidence and that Medstar failed to show that the trial court committed prejudicial error by allowing the separate claims of negligent hiring and vicarious liability to go to the jury.However, the Supreme Court of the State of Arizona reversed the lower courts' decisions. The Supreme Court held that because Medstar admitted liability, it was wholly responsible for Roaf’s damages. Therefore, evidence of liability relating to the negligent hiring claim should have been precluded. The court also found that Medstar suffered prejudice because of the erroneous admission of Ortiz’s personnel record and driving history. The case was remanded to the trial court for a new trial. View "ROAF v REBUCK CONSULTING" on Justia Law

The case involves Benjamin Stanley, who was employed by Western Michigan University (WMU) for about a month before his employment was terminated. Stanley, who has severe ADHD, claimed that WMU and certain supervisors discriminated and retaliated against him in violation of the Americans with Disabilities Act (ADA). He also brought a claim under Michigan’s Persons with Disabilities Civil Rights Act (PWDCRA), as well as a claim for intentional infliction of emotional distress. The district court dismissed Stanley’s federal claims for lack of subject-matter jurisdiction based on Eleventh Amendment immunity and dismissed his state-law claims for failure to comply with the Michigan Court of Claims Act’s notification statute.The district court's dismissal of Stanley's claims was appealed to the United States Court of Appeals for the Sixth Circuit. The appellate court affirmed the district court’s dismissal of Stanley’s federal claims and the denial of Stanley’s motion for leave to amend his complaint. However, the court vacated the judgment in part and remanded to the district court to dismiss Stanley’s federal and state-law claims without prejudice. The court found that the district court lacked subject-matter jurisdiction to adjudicate Stanley’s ADA claims because the defendants were entitled to Eleventh Amendment immunity, and Stanley lacked standing to request injunctive relief from the individual defendants. The court also found that the district court lacked jurisdiction to decide Stanley’s state-law claims because it lacked subject matter jurisdiction over any federal issues. View "Stanley v. Western Michigan University" on Justia Law

The case involves the Los Angeles County Employees Retirement Association (LACERA) and the County of Los Angeles. LACERA, a public employee retirement system, sued the County over the authority to set employment classifications and salaries for its employees. LACERA argued that under the County Employees Retirement Law of 1937 (CERL) and the California Constitution, it had the authority to create employment classifications and set salaries for its employees. The County disagreed, asserting that it had the authority to set employment classifications and salaries for all county employees, including those of LACERA.Previously, the Superior Court of Los Angeles County sided with the County, following a 2003 decision, Westly v. Board of Administration, which held that the broad authority granted to retirement boards was not broad enough to give them the power to establish employment classifications and set salaries for their employees.However, the Court of Appeal of the State of California Second Appellate District Division Seven disagreed with the lower court's decision. The appellate court found that the Westly decision was inconsistent with the language, purpose, and intent of Proposition 162, a 1992 voter initiative that gave governing boards of public employee retirement systems “plenary authority and fiduciary responsibility for investment of moneys and administration of the system.” The court concluded that this plenary authority included the power to create employment classifications and set salaries for employees of the retirement system. The court also found that section 31522.1 of the CERL imposed a ministerial duty on a county board of supervisors to include in the county’s employment classifications and salary ordinance the classifications and salaries adopted by the board of a county public employee retirement system for employees of that system. The court reversed the judgment of the lower court. View "L.A. County Employees Retirement Assn. v. County of L.A." on Justia Law

The case involves Gabrielle Barbour, who alleges that she was denied employment as a Special Agent with the Drug Enforcement Administration (DEA) in retaliation for her participation in a class action lawsuit against the Federal Bureau of Investigation (FBI) for workplace discrimination. The district court dismissed Barbour's complaint under Federal Rule of Civil Procedure 12(b)(6) for failure to state a claim upon which relief can be granted.The district court found that Barbour failed to establish a causal link between her protected activity (the lawsuit against the FBI) and the adverse employment action (non-selection by the DEA). The court also found that Barbour's complaint affirmatively pleaded legitimate nondiscriminatory reasons for her non-selection, which were not rebutted by Barbour.On appeal, the United States Court of Appeals for the Fourth Circuit reversed the district court's decision. The appellate court found that the district court erred in its analysis of the complaint's allegations and in requiring Barbour to rebut the DEA's proffered reasons for her non-selection at the motion to dismiss stage. The appellate court concluded that the complaint's allegations were sufficient to support a plausible inference of a causal link between Barbour's lawsuit against the FBI and the DEA's subsequent refusal to hire her. The case was remanded for further proceedings. View "Barbour v. Garland" on Justia Law