Justia Labor & Employment Law Opinion Summaries

The case involves the interpretation of Section 3 of the Federal Arbitration Act (FAA), which outlines procedures for enforcing arbitration agreements in federal court. The petitioners, current and former delivery drivers for an on-demand delivery service operated by the respondents, filed a lawsuit alleging violations of federal and state employment laws. The respondents moved to compel arbitration and dismiss the suit. The petitioners agreed that their claims were arbitrable but argued that Section 3 of the FAA required the District Court to stay the action pending arbitration rather than dismissing it entirely. The District Court issued an order compelling arbitration and dismissed the case without prejudice. The Ninth Circuit affirmed the decision.The Supreme Court of the United States reversed the Ninth Circuit's decision. The Supreme Court held that when a district court finds that a lawsuit involves an arbitrable dispute and a party has requested a stay of the court proceeding pending arbitration, Section 3 of the FAA compels the court to issue a stay, and the court lacks discretion to dismiss the suit. The Court reasoned that the statutory text, structure, and purpose all point to this conclusion. The Court further explained that the FAA's structure and purpose confirm that a stay is required. The Court concluded that staying rather than dismissing a suit comports with the supervisory role that the FAA envisions for the courts. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Smith v. Spizzirri" on Justia Law

Matthew Meinen, a white male, filed a lawsuit against his former employer, Bi-State Development Agency, alleging racial and gender discrimination, hostile work environment, and retaliation. Meinen claimed that he was harassed by an unidentified female African American co-worker, who made inappropriate comments and physical contact. He reported these incidents to his and her supervisors. In March 2021, during an unrelated investigation, Meinen informed a Bi-State human resources employee about his concerns. He was advised to write a disciplinary warning, which he did and delivered to the female co-worker. Meinen was terminated in May 2021 and subsequently filed a claim with the Equal Employment Opportunity Commission (EEOC). He then commenced an action in Missouri state court, which Bi-State removed to federal court.The United States District Court for the Eastern District of Missouri dismissed Meinen's claims for failure to state a claim. The court applied the McDonnell Douglas framework to evaluate Meinen’s allegations of discrimination. It found that Meinen failed to show that he was a member of a protected class, was qualified to perform the job, experienced an adverse employment action, and that similarly situated employees outside of the protected class were treated differently. The court also found that the allegations of harassment were not sufficiently severe or pervasive to create an abusive working environment.Upon appeal, the United States Court of Appeals for the Eighth Circuit affirmed the district court's decision. The appellate court agreed that Meinen failed to plead sufficient facts to give rise to an inference of causation beyond mere speculation for his retaliation claim. It also concurred with the lower court's application of the McDonnell Douglas framework and its conclusion that Meinen's allegations were insufficient to give rise to an inference of discrimination. Finally, the court agreed that the alleged harassment was not severe or pervasive enough to create a hostile work environment. View "Meinen v. Bi-State Development Agency" on Justia Law

The case involves plaintiffs Christopher Maia and Sean Howarth, who were employed as laborers for defendant IEW Construction Group. The company required them to perform “pre-shift” and “post-shift” work, for which they were not paid. Both Maia and Howarth were laid off in November 2021. In April 2022, they filed a class action complaint alleging that IEW violated the Wage Payment Law (WPL) and the Wage and Hour Law (WHL).The trial judge held that Chapter 212, which amended the WPL and WHL, does not apply retroactively and thus dismissed plaintiffs’ claims for conduct that arose prior to Chapter 212’s effective date of August 6, 2019. The Appellate Division reversed this decision.The Supreme Court of New Jersey granted leave to appeal. The court held that Chapter 212 is to be applied prospectively to conduct that occurred on or after August 6, 2019, not retroactively to conduct that occurred before that date. The trial judge properly dismissed the portions of the complaint relying on Chapter 212 but arising from conduct prior to its effective date. The court reversed the Appellate Division’s judgment, reinstated the trial judge’s order partially dismissing plaintiffs’ complaint, and remanded for further proceedings. View "Maia v. IEW Construction Group" on Justia Law

The case involves Nancy Anaya-Smith, the next of kin of Michael Brian Smith, who was killed in a single-car accident while he was a passenger in a company vehicle owned by Fixtures & Drywall Company of Oklahoma (FADCO). The vehicle was being driven by Smith's coworker, Duane Clark. Anaya-Smith alleges that Clark's negligence caused the fatal accident. At the time of the accident, FADCO maintained an insurance policy with Federated Mutual Insurance Company (Federated). The policy provided up to $1,000,000 of liability coverage per accident and an additional $6,000,000 of liability coverage per accident under an umbrella policy. However, FADCO had rejected uninsured motorist (UM) coverage for all employees, except for its directors, officers, partners, owners, and their family members.The United States District Court for the Western District of Oklahoma granted summary judgment in favor of Federated, concluding that the vehicle was an uninsured vehicle at the time of the accident because Clark is immune from tort liability under the workers' compensation exclusive remedy provision, and that FADCO's policy providing UM coverage for some individuals who qualify as insureds but rejecting UM coverage for other insureds does not violate Oklahoma law. Anaya-Smith appealed from the summary judgment order.The Supreme Court of the State of Oklahoma answered the first certified question in the affirmative, holding that the vehicle qualifies as an uninsured motor vehicle within the meaning of Oklahoma law. The court answered the second certified question in the negative, concluding that the plain language of Oklahoma law requires a named insured to either elect or reject uninsured/underinsured motorist coverage for all insureds under the policy, treating every insured in the same manner. The court declined to answer the third certified question as the record was undeveloped and the parties did not submit legal arguments pertaining to it. View "Anaya-Smith v. Federated Mutual Insurance Co." on Justia Law

The case revolves around an employment discrimination suit filed by Dr. Tara Loux against her former employers, BayCare Medical Group and St. Joseph’s Hospital. Dr. Loux sought to discover BayCare’s internal documents about the performance of other doctors who were not fired despite also committing errors. BayCare objected to disclosing certain documents, such as its “quality files” and “referral logs,” arguing that they were privileged under the Patient Safety and Quality Improvement Act of 2005. The Act creates a statutory privilege for work product prepared for or reported to patient safety organizations.The district court ordered BayCare to produce the disputed documents, concluding that the Act does not privilege documents if they have a “dual purpose,” only one of which relates to making reports to a patient safety organization. The court held that these documents were not privileged because BayCare used information in the documents for other purposes, such as internal safety analysis and peer review.The United States Court of Appeals for the Eleventh Circuit disagreed with the district court's interpretation of the Act. The appellate court found that the district court had applied an incorrect "sole purpose" standard to assess whether BayCare’s quality files and referral logs fell under the privilege. The court held that the Act does not require that privileged information be kept solely for provision to a Patient Safety Organization. The court granted BayCare's petition for a writ of mandamus, directing the district court to vacate its orders compelling the disclosure of the privileged documents and reconsider BayCare’s assertion of privilege consistent with the appellate court's opinion. View "In re: Baycare Medical Group, Inc." on Justia Law

The case involves Anthony Perry, a former employee of the Census Bureau, who retired under a settlement agreement after the Bureau initiated procedures to terminate him. Perry filed a "mixed case" appeal before the Merit Systems Protection Board (MSPB), alleging violations of the Civil Service Reform Act (CSRA) and various federal anti-discrimination laws. The MSPB dismissed the case, stating it lacked jurisdiction over voluntary retirement decisions. Perry appealed to the district court, which upheld the MSPB's decision and granted summary judgment in favor of the government.Perry then appealed to the United States Court of Appeals for the District of Columbia Circuit, arguing that the district court erred by not considering his discrimination claims de novo and by affirming the MSPB's dismissal of his case for lack of jurisdiction. The Court of Appeals partially reversed the district court's decision, ruling that the district court should have allowed Perry to litigate the merits of his discrimination claims as required by statute. However, the Court of Appeals affirmed the district court's conclusion that the MSPB correctly dismissed Perry's mixed case for lack of jurisdiction. View "Perry v. Raimondo" on Justia Law

The case revolves around a dispute between a real estate salesperson, James Kennedy II, and a real estate broker, Weichert Co. Kennedy worked for Weichert from 2012 to 2018 under two written agreements that identified him as an independent contractor. After his affiliation with Weichert ended, Kennedy filed a class action lawsuit alleging that Weichert violated the Wage Payment Law (WPL) by misclassifying him and other real estate salespersons as independent contractors and unlawfully deducting fees and expenses from their commissions.The trial court denied Weichert's motion to dismiss Kennedy's complaint, ruling that the question of Kennedy's status was not determined by the parties' agreement, but by the legal standard that generally governs employee classification issues under the WPL, known as the "ABC" test. The Appellate Division affirmed this decision, but noted that the 2018 amendments to the New Jersey Real Estate License Act, or the Brokers Act, authorized real estate brokers and salespersons to enter into independent contractor relationships. However, it held that these amendments applied prospectively and thus governed only a brief portion of Kennedy's claim.The Supreme Court of New Jersey reversed the lower courts' decisions. It held that the parties' agreement to enter into an independent contractor business affiliation is enforceable under N.J.S.A. 45:15-3.2, and Kennedy, as an independent contractor, was not subject to the WPL pursuant to N.J.S.A. 34:11-4.1(b). Therefore, the trial court erred when it denied Weichert’s motion to dismiss the complaint. The case was remanded for the dismissal of Kennedy’s complaint. View "Kennedy v. Weichert Co." on Justia Law

Two employees, Richard Miller and Brent Whitman, filed a lawsuit against the Michigan Department of Corrections (MDOC), alleging they were terminated in retaliation for their close friendship with Cedric Griffey, a deputy warden who was targeted by the MDOC after his wife, Lisa Griffey, filed a complaint and lawsuit against the MDOC for racial harassment. The plaintiffs claimed their termination was a violation of the Elliott-Larsen Civil Rights Act (ELCRA).The Genesee Circuit Court denied the MDOC's motion for summary disposition, which argued that the plaintiffs had failed to state a claim under the ELCRA because they had not personally engaged in any protected conduct. The MDOC appealed this decision, and the Court of Appeals reversed the lower court's ruling, concluding that the ELCRA did not authorize the plaintiffs' claims.The Michigan Supreme Court, however, disagreed with the Court of Appeals. The Supreme Court held that the ELCRA does provide a cause of action for associational or "third party" retaliation claims. The court found that the plaintiffs had sufficiently alleged such a claim, stating that they had a close relationship with Cedric Griffey and that the MDOC took adverse action against them in response to Griffey's protected acts. The court concluded that the plaintiffs' firings were part of the effort to retaliate against Griffey, and thus, they had stated a cause of action under the ELCRA. The Supreme Court reversed the judgment of the Court of Appeals and remanded the case back to the circuit court for further proceedings. View "Miller v. Michigan Department Of Corrections" on Justia Law

Jennifer D. Aldea-Tirado, an employee of PricewaterhouseCoopers LLP (PWC), filed a lawsuit against her employer alleging violations of Title VII of the Civil Rights Act, the Pregnancy Discrimination Act of 1978, and Puerto Rico law. Aldea-Tirado claimed she was subjected to adverse employment action due to her gender and pregnancy and was retaliated against for filing a complaint with the United States Equal Employment Opportunity Commission. PWC, however, argued that Aldea-Tirado's employment contract contained an arbitration clause and moved to compel arbitration.The United States District Court for the District of Puerto Rico granted PWC's motion to compel arbitration. The court determined that PWC had established the existence of a valid agreement between PWC and Aldea-Tirado to arbitrate her claims. The court also found that Aldea-Tirado had tacitly consented to the Agreement by continuing to work for PWC after having received the Agreement through both regular mail and email. Aldea-Tirado appealed this decision.The United States Court of Appeals for the First Circuit affirmed the lower court's decision. The appellate court found no merit in Aldea-Tirado's arguments that she did not receive the Agreement or that it was unconscionable to hold her to it. The court also rejected Aldea-Tirado's contention that she was not given "some minimal level of notice" that her continued employment would effect a waiver of her right to pursue her claims in a judicial forum. The court concluded that Aldea-Tirado failed to show that there was any non-speculative basis in the record from which a reasonable factfinder could determine that she did not receive the email to which the Agreement was attached. View "Aldea-Tirado v. PricewaterhouseCoopers, LLP" on Justia Law

The case involves an employee, Braden Nanez, who was injured in an auto accident while off work and away from his job at a remote fire base camp. His employer, 3 Stonedeggs, Inc., expected employees not to leave the job site and to notify a manager if they did. Nanez did not notify a manager he was leaving camp. The Workers’ Compensation Appeals Board (the Board) determined that under the commercial traveler rule, workers’ compensation coverage applied to Nanez's injuries. The Board found that Nanez’s use of his own car while off work to drive approximately 70 miles away from camp purportedly to obtain cellular service was conduct reasonably expected by his employer to be incident to its requirement that Nanez spend time away from home where cellular service was not adequately provided at the camp.The employer, 3 Stonedeggs, Inc., and its insurer, Technology Insurance Company, Inc., administered by Amtrust North America, petitioned for a writ of review, arguing that the Board acted in excess of its authority and that substantial evidence does not support the Board’s findings. They argued that Nanez was injured during a material deviation from his employment; he left the camp without employer approval on a personal activity that, under the unique circumstances of working at this remote fire camp, was not contemplated by the employer.The Court of Appeal of the State of California Third Appellate District denied the petition, finding that substantial evidence supports the Board’s findings. The court concluded that under the circumstances of Nanez’s age, his having his personal vehicle with him, the structure of his shifts, the remoteness of the camp, and his not being prohibited from using his vehicle during his off hours, it was reasonable for the employer to expect that Nanez would leave camp in his car during his off time as incident to being employed away from home. View "3 Stonedeggs, Inc. v. Workers' Compensation Appeals Board" on Justia Law