Justia Labor & Employment Law Opinion Summaries

A former Fire Chief of the Cincinnati Fire Department, who had worked for the department since 1993 and was promoted to Fire Chief in 2021, was terminated by the City Manager in 2023 without being given a pre-termination hearing. The City Charter provided that, after serving six months as Fire Chief, the individual could only be removed for cause. When promoted, the Fire Chief signed a memorandum stating the position was “unclassified” and subject to dismissal without cause, but the Charter’s language provided for-cause protection after the first six months. The City Manager provided the Fire Chief with a termination letter listing reasons for the firing and publicized the termination, including to the media, citing the reasons as “for cause.” The Fire Chief did not receive a pre-termination or post-termination hearing before a neutral decisionmaker.The United States District Court for the Southern District of Ohio denied summary judgment to the City Manager and the City, holding that the City Manager was not entitled to qualified immunity regarding pre-termination due process violations. The court found that, under the Charter, the Fire Chief had a property interest in continued employment after six months and that there were unresolved factual disputes regarding waiver of those rights. The district court also denied statutory immunity to the City Manager on the Fire Chief’s state law defamation claim, finding triable issues regarding whether her statements were knowingly false or made with malice.On interlocutory appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s rulings. The Sixth Circuit held that the City Charter unambiguously gave the Fire Chief for-cause removal protection after six months, creating a property interest protected by procedural due process. It found that no “clear and unmistakable” waiver of those rights was effected by the memorandum. The court also held that sufficient evidence existed for a jury to decide whether the City Manager acted with malice or bad faith in making allegedly defamatory statements. The matter was remanded for further proceedings. View "Washington v. City of Cincinnati" on Justia Law

A black factory manager worked for a biomedical company that had been placed on a corporate safety watchlist due to recurring safety issues. He became responsible for the factory’s operations and safety. The company conducted several safety audits, including a special unannounced audit after two safety incidents were reported late. The manager believed that the head of the safety department, a white executive, targeted him with excessive scrutiny and was rude, later attributing these actions to racial bias based on his own experiences and discussions with other black employees. The company investigated possible bias after concerns were raised, finding the executive had been rude and had engaged in some microaggressions or unconscious bias, but no blatant racial discrimination.After the factory manager filed a discrimination charge with the EEOC, a dispute with the interim president led him to send group messages that a recipient interpreted as threatening. The company suspended the manager with pay pending investigation. He then left the company and filed suit under Title VII, alleging racial discrimination and retaliation.The United States District Court for the Eastern District of Pennsylvania granted summary judgment to the employer. It found no evidence that the alleged actions harmed any identifiable term or condition of the manager’s employment, nor that any actions were racially motivated. The court also concluded there was no evidence of retaliation, as the suspension was due to the perceived threatening messages.The United States Court of Appeals for the Third Circuit reviewed the case de novo and affirmed the District Court’s judgment. The Third Circuit held that the manager failed to establish a prima facie case of racial discrimination or retaliation under Title VII. The court found that neither the alleged conduct nor the suspension constituted unlawful discrimination or retaliation. View "Gabriel v. DSM Biomedical Inc" on Justia Law

A special education teacher suffered two separate head injuries at work in 2013 and 2014, resulting in chronic migraines, depression, and other functional limitations. After the second injury, her physician restricted her to light-duty work, but her employer declined to accommodate these restrictions and terminated her employment. The teacher was initially awarded temporary total disability benefits and payment of related medical expenses, but the employer disputed liability for some bills, leading to debt collection efforts against the teacher, which caused her additional stress. She subsequently sued the collection agencies in federal court and received a monetary settlement. After her condition did not improve, the teacher filed a second claim for permanent total disability benefits.The Administrative Law Judge (ALJ) in the Utah Labor Commission held hearings, appointed a medical panel to distinguish the effects of the work injuries from non-work-related stressors, and ultimately awarded permanent total disability benefits, as well as past and future medical expenses. The ALJ denied the employer’s attempt to reopen the evidentiary record to introduce evidence related to the debt collection actions and a later car accident, and also denied the employer’s claim for a subrogation offset from the teacher’s federal lawsuit settlement. The Utah Labor Commission affirmed the ALJ’s findings and award.The Supreme Court of the State of Utah reviewed the case on certification from the court of appeals. The court held that the medical panel was properly instructed and its findings were supported by substantial evidence, the ALJ did not abuse its discretion by refusing to reopen the evidentiary record, and the Commission’s award of permanent total disability benefits was supported by the evidence. The court also held that the employer was not entitled to a subrogation offset, as the settlement from the federal lawsuit did not compensate for the work injuries. The Supreme Court declined to disturb the Commission’s order. View "Granite School District v. Labor Comm." on Justia Law

A sexual assault counselor employed by a nonprofit mental health organization was asked multiple times by her supervisors to disclose the location and information regarding a minor victim, whom law enforcement and county officials were seeking in connection with a probation violation. The counselor refused to provide this information without the victim’s consent, citing the statutory sexual-assault-counselor privilege. Despite her refusal, and after continued pressure, the counselor was ultimately terminated from her position. She then brought claims against her employer under the Minnesota Whistleblower Act and for common-law wrongful discharge, arguing that disclosing the information would have violated the sexual-assault-counselor privilege.The Washington County District Court granted the employer’s motion to dismiss for failure to state a claim, finding that the facts alleged did not support that the requested disclosure would violate the privilege statute. The Minnesota Court of Appeals affirmed, holding that the sexual-assault-counselor privilege is limited to disclosures made in the context of a court action or proceeding, or before someone authorized to receive evidence, and that the counselor had not alleged such circumstances.The Supreme Court of Minnesota affirmed the decision of the court of appeals. The court held that the sexual-assault-counselor privilege in Minnesota Statutes section 595.02, subdivision 1(k), applies only in an “action or proceeding, civil or criminal, in court or before any person who has authority to receive evidence.” Because the counselor did not allege she was ordered to disclose information in such a context, her claims under the Minnesota Whistleblower Act and for common-law wrongful discharge failed as a matter of law. The court declined to extend the privilege or recognize a broader common-law claim, emphasizing that any broader confidentiality protections would need to come from the legislature. View "Wredberg vs. Canvas Health, Inc." on Justia Law

A worker was severely injured while operating a piece of agricultural machinery at his place of employment. The machine’s power take-off (PTO) shaft, which should have been equipped with safety guards, lacked those guards at the time of the accident. The worker alleged that the absence of these safety guards was due to his employer’s deliberate removal, and that this action directly caused his injuries. He sued his employer for an intentional tort under Ohio law, specifically invoking a statutory provision that creates a rebuttable presumption of intent to injure when an employer deliberately removes an equipment safety guard and an injury results.The Madison County Court of Common Pleas denied the employer’s motion for summary judgment, finding a genuine dispute of material fact as to whether the employer had deliberately removed the safety guard. The case proceeded to trial, where the jury heard evidence about the condition of the machinery, the employer’s repair practices, and the employer’s responses to safety concerns. The jury found in favor of the worker, awarding significant compensatory damages for his injuries. On appeal, the Twelfth District Court of Appeals reversed, holding that the evidence did not support a finding of deliberate removal as a matter of law, and that the statutory presumption did not apply unless the employer both removed the guard and made a conscious decision not to replace it.The Supreme Court of Ohio reversed the judgment of the court of appeals. It held that when reviewing the denial of summary judgment after a trial, appellate courts must consider the full trial record, not just the pretrial record. The court further held that the statutory presumption applies when there is evidence of deliberate removal of a safety guard, and that courts may not require proof of a separate, additional decision not to replace the guard. The case was remanded for further proceedings consistent with this holding. View "Camara v. Gill Dairy, L.L.C." on Justia Law

The case concerns the estate administrators of a former employee, Juliana Rodriguez Morel, who alleged she was discriminated and retaliated against by her employer, Mammoth Tech, Inc., during her pregnancy. After initially filing an administrative complaint with the New Hampshire Commission for Human Rights and the EEOC in 2019, Rodriguez Morel obtained a right-to-sue letter from the EEOC. She then filed a lawsuit in the United States District Court for the District of New Hampshire. That court entered a default judgment against Mammoth in 2023, awarding damages and fees.Subsequently, in 2025, the estate administrators initiated a separate action in the same district court against Travelers Casualty and Surety Company of America, Mammoth’s insurer. They sought a declaratory judgment that Travelers was required to pay the losses Mammoth incurred as a result of the default judgment, arguing that the insurer’s policy provided coverage for the claims in question. Travelers moved for judgment on the pleadings, contending that the policy did not provide coverage because Mammoth had received notice of the claims prior to the policy period, thus excluding coverage under the policy’s terms. The District Court agreed with Travelers and granted judgment on the pleadings.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court held that the insurance policy’s “Related Claims” provision applied, which meant that all related claims were considered made at the time the first such claim was made. Because the first notice of the employment discrimination claims was before the policy period, the policy did not cover the judgment. The First Circuit affirmed the District Court’s decision, holding that the administrators failed to show any conflict or ambiguity in the policy that would override the Related Claims provision. View "Urena v. Travelers Casualty and Surety Co. of America" on Justia Law

A dispute arose concerning the payment rate for a surgical procedure performed at an out-of-network facility. The patient receiving the surgery was covered by an ERISA-governed health plan provided by the employer and administered by an insurance company. Prior to the surgery, the facility contacted the plan administrator to verify coverage and was told that the plan would reimburse at the usual, customary, and reasonable (“UCR”) rate, not the lower Medicare rate. Relying on this representation, the facility performed the surgery. However, the plan later paid only at the Medicare rate, far less than the full billed amount. The facility’s successor in interest, having obtained the rights to the claim, sought to recover the unpaid balance.The action was first brought in California state court, then removed to the United States District Court for the Central District of California. The plaintiff asserted both ERISA and state law claims. The district court dismissed the ERISA claim for lack of derivative standing, as the plaintiff was not properly assigned the right to sue under ERISA. The court also dismissed the state law claims for negligent misrepresentation and promissory estoppel, holding that these claims were preempted by ERISA because they related to an ERISA-covered plan.The United States Court of Appeals for the Ninth Circuit reviewed the case. It affirmed the district court’s dismissal of the promissory estoppel claim, holding that, under circuit precedent, such claims are preempted by ERISA. However, the Ninth Circuit reversed the dismissal of the negligent misrepresentation claim. The appellate court held that ERISA does not preempt a negligent misrepresentation claim by a provider’s successor in interest when the claim arises from representations made by the plan administrator during a pre-service verification call. The court concluded that such a claim does not sufficiently “relate to” an ERISA plan to trigger preemption, as it is not based on an ERISA-regulated relationship or enforceable under ERISA’s civil enforcement mechanism. The case was remanded for further proceedings on the negligent misrepresentation claim. View "HEALTHCARE ALLY MANAGEMENT OF CALIFORNIA, LLC V. WSP USA, INC." on Justia Law

The petitioner, a former project manager at a large corporation, raised internal compliance concerns in 2018. In April 2019, he was notified that he would be subject to a reduction in force and laid off, effective June 21, 2019. He subsequently filed several internal complaints alleging that his layoff and the company’s refusal to rehire him for numerous positions were retaliatory acts in response to his whistleblowing. After his layoff, he was placed on short-term disability and given a period during which he could apply for other positions within the company, but his applications were unsuccessful.Following these events, the petitioner filed a whistleblower-retaliation complaint under the Sarbanes–Oxley Act (SOX) with the Occupational Safety and Health Administration in December 2020. OSHA dismissed the complaint as untimely. The petitioner then sought review before an administrative law judge (ALJ), who held a hearing and dismissed the claims as untimely, also finding that equitable tolling was not warranted. The petitioner appealed, and the Administrative Review Board (ARB) affirmed the ALJ’s dismissal.On review, the United States Court of Appeals for the Second Circuit determined that the ARB did not err in finding the claims untimely. The court held that the SOX 180-day filing window begins when the employee is notified of the adverse action or when the refusal to rehire becomes apparent, not the last date of employment or the date of final application rejection. The court also found no basis for equitable tolling, as the petitioner knew or should have known of the alleged retaliation well before the statutory deadline. Accordingly, the Second Circuit denied the petition for review. View "Mehrotra v. U.S. Dep't of Lab." on Justia Law

The plaintiff, a former employee of a company participating in a deferred profit-sharing plan, sought to liquidate his 401(k) account in anticipation of a post-election stock market increase. He requested that the plan’s record keeper, Fidelity, complete the liquidation rapidly and in a manner advantageous for tax purposes. The plaintiff claimed that Fidelity’s communications led him to believe he would have quicker access to his funds than ultimately occurred, resulting in a missed investment opportunity. Additionally, he alleged that the plan administrator, Altria, failed to provide him with a copy of the administrative services agreement (ASA) between Altria and Fidelity, which he requested under ERISA.After the plaintiff’s formal complaint was denied by the plan administrator, he appealed to the plan’s management committee, which upheld the denial. He then filed suit in the United States District Court for the Eastern District of Virginia, raising claims for denial of benefits, breach of fiduciary duty, and failure to provide plan documents. The district court granted summary judgment to the defendants on all remaining claims, finding that the plan administrator’s denial was reasonable, that Fidelity was not acting as a fiduciary or had not breached any fiduciary duties, and that the ASA was not a document required to be disclosed under ERISA.The United States Court of Appeals for the Fourth Circuit reviewed the case. The appellate court affirmed the district court’s rulings on the denial of benefits and breach of fiduciary duty claims, concluding that the plan administrator’s decision was reasonable and that Fidelity was not a fiduciary in this context or had not breached any such duty. However, the Fourth Circuit reversed the district court’s decision regarding the ASA, holding that it was a document under which the plan was operated and remanded for consideration of statutory penalties. The court affirmed the award of attorney’s fees to the defendants. View "Kelly v. Altria Client Services, LLC" on Justia Law

A Native American woman was recruited in 2017 to work as a Clinical Research Manager at a health research institute that focuses on underserved populations, including Native Americans. She supervised a small team and was initially hired, in part, because her background was seen as beneficial for engaging Native American study participants and diversifying management. Over several years, she led or participated in research studies, experienced workplace conflicts, and alleged that she and her assistant were subject to “tokenism” and disparate treatment. In 2022, following complaints about workplace discrimination, disputes over recruitment methods, and changes in her role, the institute’s leadership eliminated her position as part of a reduction in force (RIF) to meet a 5% budget improvement mandate. Her salary was funded mostly by internal, non-grant money, unlike other managers whose salaries were grant-funded.She filed suit in the United States District Court for the District of South Dakota, alleging race discrimination in violation of Title VII and state law. The district court granted summary judgment for the employer, finding that she failed to establish a prima facie case of race discrimination and failed to show that the RIF was a pretext for unlawful discrimination.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the grant of summary judgment de novo. Applying the McDonnell Douglas burden-shifting framework, the court assumed without deciding that a prima facie case was made, but held that the employer had articulated a legitimate, non-discriminatory reason for the termination: budgetary constraints and the unique funding of her position. The appellate court further found that the plaintiff did not present sufficient evidence for a reasonable jury to conclude that this stated reason was pretextual or that racial discrimination was a determinative factor in her termination. The Eighth Circuit affirmed the district court’s judgment. View "Tobacco v. McKennan" on Justia Law