Justia Labor & Employment Law Opinion Summaries

The case involves Carl Fowler, an employee at Perdue, Inc., who contracted COVID-19 and sought compensation from his employer. Fowler worked at Perdue from January 2020 until late March 2020. In March 2020, Fowler developed COVID-19 symptoms and was later diagnosed with the virus. He was hospitalized for over two months and suffered severe health complications. Fowler claimed that he contracted the virus at work, specifically in the company's cafeteria, which he described as crowded and likened to a "sardine can."The Industrial Accident Board of the State of Delaware initially denied Fowler's claim, finding that he failed to present sufficient evidence that COVID-19 was a compensable occupational disease. The Superior Court affirmed this decision. Fowler then appealed to the Supreme Court of the State of Delaware.The Supreme Court affirmed the lower court's decision. The court found that while Fowler had established that the cafeteria at Perdue presented a hazard greater than that attending employment in general, he failed to show that the cafeteria was a hazard "distinct from" that attending employment in general. The court concluded that Fowler failed to establish the necessary relationship between his work environment at Perdue and COVID-19 as a "natural incident to" that employment. Therefore, the court held that Fowler's COVID-19 infection was not an occupational disease under these circumstances. View "Fowler v. Perdue, Inc." on Justia Law

The case involves the United States Department of Labor (DOL) and Ascent Construction, Inc., its CEO Bradley Knowlton, and the Ascent Construction, Inc. Employee Stock Ownership Plan (the Plan). The DOL investigated Ascent and Knowlton for potential breaches of their fiduciary duties under the Employee Retirement Income Security Act (ERISA). The DOL found that Knowlton had deposited over $311,000 of the Plan’s cash into Ascent’s checking accounts and used it to pay Ascent’s business expenses. The DOL also discovered that a former Ascent employee had requested a distribution from his retirement account but never received it, even though the Plan’s custodian had issued a distribution check at Knowlton’s request.The DOL filed a lawsuit alleging that Knowlton and Ascent had violated ERISA’s fiduciary-duty standard and prohibited-transaction rules. The DOL sought a preliminary injunction to remove Knowlton and Ascent as Plan fiduciaries and appoint an independent fiduciary to prevent further ERISA violations and dissipation of the Plan’s assets. The district court granted the DOL’s motion, and the defendants filed an interlocutory appeal.While the appeal was pending, the case proceeded in the lower court. The DOL filed an amended complaint and discovery commenced. The district court later entered a default judgment against the defendants due to their willful failure to engage in the litigation process and comply with the court’s orders. The court also issued a permanent injunction that superseded the preliminary injunction, permanently barring Knowlton and Ascent from serving as trustee and administrator of the Plan.The United States Court of Appeals for the Tenth Circuit dismissed the defendants' appeal as moot. The court reasoned that the preliminary injunction dissolved automatically with the entry of the final judgment, regardless of whether the final judgment was issued on the merits or by way of default judgment. The court concluded that granting the defendants’ requested relief—vacatur of the preliminary injunction—would have no “effect in the real world.” View "Su v. Ascent Construction" on Justia Law

Robert Wayne Goosen, an employee of the Minnesota Department of Transportation (MNDOT), suffered an on-the-job injury in 2018 that required multiple surgeries and physical therapy. In 2021, after reaching his maximum medical improvement, Goosen's doctor determined that he could return to work with certain physical restrictions. However, MNDOT concluded that Goosen could not perform the essential functions of his job due to these restrictions and could not be reasonably accommodated. Goosen subsequently filed a lawsuit alleging that MNDOT violated the Americans with Disabilities Act (ADA) by failing to provide a reasonable accommodation.The district court granted MNDOT's motion for summary judgment. The court found that no reasonable jury could conclude that Goosen was qualified to perform the essential functions of his former position or that a reasonable accommodation was possible. Goosen appealed this decision.The United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed with the lower court's determination that Goosen could not perform the essential functions of his job, even with reasonable accommodation. The court also found that Goosen failed to make a facial showing that reassignment to a different position within MNDOT was a reasonable accommodation. The court concluded that Goosen did not provide sufficient evidence to support his claim that MNDOT violated the ADA. View "Robert Goosen v. Minn. Dept. of Transportation" on Justia Law

This case is a class action involving commercial truck drivers who claimed they were not paid properly by Werner Enterprises, Inc., and Drivers Management, LLC. The drivers alleged that they were not adequately compensated for off-duty time spent on short rest breaks and time spent resting in their trucks’ sleeper-berths. The case has been appealed multiple times, with the court previously vacating a jury verdict in favor of the drivers because the district court improperly allowed the drivers to submit an expert report after the deadline. On remand, the district court entered judgment in favor of the defendants. The drivers appealed again, and the court vacated the judgment and remanded the case back to the district court to conduct an analysis regarding whether the expert report should be excluded as a discovery sanction and whether the district court should appoint an independent expert.On remand, the district court concluded that exclusion of the drivers’ expert report was the appropriate sanction for its late disclosure and that appointment of an independent expert was not appropriate. It then entered judgment in favor of the defendants. The drivers appealed this decision, asserting that the district court erred in its analysis. The defendants cross-appealed, asserting that the drivers’ notice of appeal was untimely, requiring dismissal of the appeal.The United States Court of Appeals for the Eighth Circuit rejected the defendants’ contention on cross-appeal and affirmed the judgment of the district court. The court found that the district court did not abuse its discretion in excluding the expert report and denying the drivers’ motion for a new trial. The court also found that the district court did not err in declining to appoint an expert and in entering judgment in favor of the defendants. View "Petrone v. Werner Enterprises, Inc." on Justia Law

The case involves Ryan Owen Frayo, a former employee of A&A Organic Farms Corporation (A&A), who was terminated for refusing to take a COVID-19 test. Frayo sued A&A and its owners, Andrew D. Martin and Aimee M. Raphael-Martin, alleging they violated the Confidentiality of Medical Information Act (CMIA). Frayo claimed that his termination was a result of his refusal to provide a COVID-19 test result, which he argued was equivalent to refusing to sign an authorization for the release of his medical information under the CMIA. He also claimed that A&A used his description of his symptoms, which he considered as medical information, to terminate his employment.The trial court sustained A&A’s demurrer to Frayo’s first amended complaint, finding that Frayo failed to state a claim under the CMIA. The court concluded that Frayo failed to state a claim under section 56.20(b) of the CMIA because the statute prohibits employer discrimination based on an employee’s refusal to sign an authorization to release his medical information, not refusal to take a COVID-19 test. The court also sustained the demurrer to Frayo’s second cause of action under section 56.20(c) because Frayo failed to allege A&A had possession of his medical information, as defined by the statute.The Court of Appeal of the State of California Sixth Appellate District affirmed the trial court's decision. The appellate court agreed with the trial court that Frayo did not state a cognizable CMIA claim under either section 56.20(b) or (c). The court found that Frayo's refusal to take and provide the results of a COVID-19 test was not equivalent to an "employee’s refusal to sign an authorization" under the CMIA. Furthermore, the court concluded that Frayo failed to allege that A&A was in possession of his medical information as defined under the CMIA. Therefore, the court affirmed the judgment of dismissal. View "Frayo v. Martin" on Justia Law

The case involves Tanya Mills, who sued her former employer, Anadolu Agency NA, Inc., under the D.C. Wage Payment and Collection Law. Mills alleges that she worked as an Executive Producer in Anadolu’s D.C. news bureau until she was terminated in July 2019. She claims that Anadolu unlawfully delayed the payment of her final month’s wages and that it continues unlawfully to withhold the value of her accrued but unused leave. Anadolu moved to dismiss Mills’s suit for lack of personal jurisdiction, arguing that none of its contacts with the D.C. forum related to Mills’s wage-payment claims. The district court agreed and dismissed the case.The United States Court of Appeals for the District of Columbia Circuit reversed the district court's decision. The court held that Mills only needed to allege facts sufficient to show Anadolu’s purposeful contacts with the District of Columbia and a nexus between those contacts and her claim under D.C.’s Wage Payment and Collection Law. The court found that Mills had adequately pled a joint-employment relationship with Anadolu sufficient to survive its motion to dismiss for failure to state a legal viable claim. The court also rejected Anadolu’s alternative ground for dismissal based on a forum-selection clause in an agreement Mills signed with Anadolu’s Turkish parent company. The court remanded the case to the district court for further proceedings. View "Mills v. Anadolu Agency NA, Inc." on Justia Law

David McGilvray, a former investigator for the Alabama Board of Medical Examiners (the Medical Board), was terminated for sending a sexually explicit email to his coworkers. Following his termination, the Medical Board requested the Local Government Health Insurance Board (the Insurance Board) to cancel McGilvray's health-insurance benefits. McGilvray, claiming he had retired before the Medical Board ratified his termination, sought retiree-health-insurance benefits. His request was denied by the Insurance Board on the grounds that he had been fired for cause and had not retired.McGilvray filed two lawsuits in an attempt to obtain retiree-health-insurance benefits. The first lawsuit was against the executive director of the Medical Board and the CEO of the Insurance Board. The Montgomery Circuit Court entered summary judgment against him, ruling that his claims were time-barred. In the second lawsuit, which is the subject of this appeal, McGilvray sued the executive director of the Medical Board and the members of the Medical Board in both their official and individual capacities. The Montgomery Circuit Court dismissed this suit based on the doctrines of State immunity and res judicata.The Supreme Court of Alabama affirmed the lower court's decision. The court found that McGilvray's breach-of-contract claim, seeking damages from the Medical Board defendants in their official capacities, was barred by State immunity. Furthermore, the court ruled that all of his other claims were barred by res judicata, as they arose from the same set of facts as his claims in the prior action: the termination of his employment and the Insurance Board's denial of his request for retiree-health-insurance benefits. View "McGilvray v. Perkins" on Justia Law

The case revolves around William Spears, a front desk clerk at hotels operated by Rick Patel Sr. and his son, Rick “Sunny” Patel Jr. Spears was compensated with monthly paychecks and onsite lodging. He sued the Patels and the hotel entities under the Fair Labor Standards Act for wages owed and unpaid overtime. The district court ruled that Sunny was an employer individually liable for the violations. In calculating Spears’s damages, the court considered the stipulated value of Spears’s lodging for unpaid overtime but declined to include it in the minimum-wage calculation.The case went to a bench trial before a magistrate judge. The judge found that Spears was not paid the legally required minimum wage or overtime. The judge ruled that Rick and Sunny were employers under the Act individually liable for those violations. The judge also found that Spears was entitled to damages for unpaid overtime and minimum wages. The judge included the stipulated $630 lodging value to determine Spears’s overtime pay rate but did not give the Patels credit for the value of Spears’s lodging when calculating Spears’s unpaid minimum wages.The United States Court of Appeals for the Eleventh Circuit affirmed the ruling that Sunny was an employer under the Act due to his involvement in the day-to-day operation of the hotels and some financial control. However, the court vacated and remanded for recalculation of damages. The court held that the magistrate judge erred in excluding the stipulated value of Spears’s lodging from the calculation of his unpaid minimum wages but including it for the calculation of Spears’s overtime damages. The court reasoned that the stipulation to the value of Spears’s lodging relieved the Patels of the burden to prove at trial the reasonable cost of lodging. View "Spears v. Patel" on Justia Law

The case involves Tristan Tanner, an employee of Stryker Corporation of Michigan, who appealed against the district court's decision granting summary judgment in favor of Stryker. Tanner had filed claims for interference with his rights under the Family and Medical Leave Act (FMLA) and for retaliation for his exercise of those rights. Tanner had requested paternity leave for the birth of his child and had taken time off work before the birth of his child, during which he accrued "occurrence points" under Stryker's attendance policy. He was terminated after accruing more than the allowed number of points.The district court had granted summary judgment in favor of Stryker, finding that Tanner was not entitled to FMLA leave for his absences before his child's birth. The court also found that Stryker had legitimate, non-discriminatory reasons for terminating Tanner, namely his accrual of eight occurrence points due to repeated unexcused absences.In the United States Court of Appeals for the Eleventh Circuit, the court affirmed the district court's decision. The court held that the days Tanner spent in Connecticut waiting for his child to be born were not covered under FMLA. The court also found that Tanner had not provided evidence to create a genuine issue of material fact as to whether Stryker's reason for his termination was pretextual. Therefore, the court concluded that summary judgment in Stryker's favor was appropriate for both Tanner's FMLA retaliation and interference claims. View "Tanner v. Stryker Corporation of Michigan" on Justia Law

The case involves Dr. Deborah A. Perlick, who was employed by the Department of Veterans Affairs (VA) as a Research Health Science Specialist. During her tenure, she discovered approximately $78,000 missing from a study's funding and reported this to VA officials. Subsequently, she was terminated from her position. Perlick filed a complaint under the Whistleblower Protection Act (WPA), and the Merit Systems Protection Board (the Board) granted her request for corrective action, awarding her back pay through March 31, 2020. However, Perlick also sought consequential and compensatory damages, including future lost earnings, which the Board denied.The Board found that Perlick had established her claim of protected whistleblowing disclosures. However, it denied her request for consequential damages, stating that such damages are limited to out-of-pocket costs and do not include non-pecuniary damages. The Board also denied Perlick's request for future lost earnings, arguing that she had no guarantees of future employment beyond the completion date of her final project with the VA.The United States Court of Appeals for the Federal Circuit vacated the Board's decision and remanded the case for further proceedings. The court held that future lost earnings are recoverable as compensatory damages under the Whistleblower Protection Enhancement Act of 2012. The court found that the Board erred by improperly raising the burden for Perlick to establish these damages, requiring her to "guarantee" future employment to recover future lost earnings. The court instructed the Board to determine under the preponderance of the evidence standard whether Perlick met her burden to prove entitlement to pecuniary compensatory damages in the form of future lost earnings. View "PERLICK v. DVA " on Justia Law