Justia Labor & Employment Law Opinion Summaries

Bethany Scheer was employed by Sisters of Charity of Leavenworth Health System, Inc. (SCL) from 2014 to 2019. During her employment, Scheer faced performance issues and was placed on a performance improvement plan (PIP) that included mandatory counseling through SCL’s employee assistance program (EAP). Scheer initially agreed to the PIP but later refused to sign a form authorizing the disclosure of her counseling attendance and compliance, leading to her termination. Scheer sued SCL under the Americans with Disabilities Act Amendments Act and the Rehabilitation Act, alleging discrimination based on a perceived disability.The United States District Court for the District of Colorado granted summary judgment in favor of SCL. The court concluded that the mandatory referral to counseling did not constitute an adverse employment action because it did not cause a significant change in Scheer’s employment status, as required by precedent.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court noted that the Supreme Court’s recent decision in Muldrow v. City of St. Louis rejected the significance test previously used and established a new standard requiring plaintiffs to show they suffered "some harm respecting an identifiable term or condition of employment." The Tenth Circuit vacated the district court’s grant of summary judgment and remanded the case for reconsideration under the new standard set forth in Muldrow. The district court must now determine if Scheer suffered "some harm" as a result of SCL’s actions. View "Scheer v. Sisters of Charity" on Justia Law

Cloetta Brady, a former Walmart employee, alleged sex discrimination under Title VII of the Civil Rights Act of 1964 after being denied a promotion to a daytime support manager position. Brady had worked at Walmart since 1987 and was a claims associate when she applied for the promotion in 2007. The position required passing the Supervisory Leadership Assessment (SLA), which Brady had not passed, while the selected candidate, Mike Harms, was already serving as a nighttime support manager and thus met the qualifications.The United States District Court for the Western District of Missouri granted summary judgment in favor of Walmart, dismissing Brady's claims. Brady appealed, challenging only the summary judgment on her disparate treatment claim.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court considered whether Brady presented direct evidence of sex discrimination or could create an inference of unlawful discrimination under the McDonnell Douglas framework. The court found that the statement by the store manager, Charles Cornelison, that Harms was promoted "because he was sick" and "had a family to support," was facially and contextually neutral and did not constitute direct evidence of sex discrimination. Additionally, Brady failed to establish a prima facie case of discrimination as she did not meet the job qualifications, specifically the SLA requirement.The Eighth Circuit affirmed the district court's grant of summary judgment, concluding that Brady neither presented direct evidence of sex discrimination nor created an inference of unlawful discrimination through the McDonnell Douglas analysis. View "Brady v. Walmart Stores, Inc." on Justia Law

The Brotherhood of Maintenance of Way Employees (BMWE), representing BNSF Railway Company employees, filed a lawsuit against BNSF alleging violations of the Railway Labor Act (RLA). BMWE claimed BNSF improperly reduced the number of maintenance-of-way workers in favor of subcontractors, failed to maintain collective bargaining agreements (CBAs), and did not deal with BMWE in good faith. BNSF moved to dismiss the case, arguing it was a "minor dispute" under the RLA, requiring arbitration. The district court agreed and dismissed the case for lack of subject matter jurisdiction.The United States District Court for the District of Nebraska granted BNSF's motion to dismiss, determining the dispute was minor and thus outside the court's jurisdiction. The court explained that minor disputes, which involve interpreting specific terms of CBAs, must be resolved through arbitration. BMWE's claims were found to hinge on the interpretation of the CBAs, specifically regarding BNSF's use of subcontractors, making it a minor dispute.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court's decision. The appellate court held that BMWE's arguments required interpretation of the CBAs, classifying the dispute as minor. Consequently, the court lacked jurisdiction, as minor disputes must be resolved by the National Railroad Adjustment Board (NRAB). The court also rejected BMWE's argument that the dispute was a direct violation of § 2 First of the RLA, agreeing with other circuits that such claims still require contract interpretation and thus fall under minor disputes. The judgment of the district court dismissing BMWE’s complaint was affirmed. View "Brotherhood of Maintenance of Way Employees v. BNSF Railway Co." on Justia Law

Dr. Joseph Jimenez, a former medical officer for the Federal Bureau of Prisons (BOP), alleged race and national origin discrimination, retaliation under Title VII of the Civil Rights Act of 1964, and disability discrimination under the Rehabilitation Act. Dr. Jimenez, who identifies as Hispanic, claimed that his employer required him to work as a correctional officer while non-Hispanic doctors were exempt. He also alleged that the BOP denied him a reasonable accommodation for his mental health conditions.The district court dismissed Dr. Jimenez’s Title VII claims related to certain adverse employment actions for failure to exhaust administrative remedies. The court granted summary judgment to the BOP on the remaining Title VII claims, finding no evidence of discriminatory or retaliatory motives. The court later dismissed Dr. Jimenez’s Rehabilitation Act claim for lack of subject-matter jurisdiction, rejecting his attempt to correct a citation error in his complaint.The United States Court of Appeals for the Eleventh Circuit affirmed the district court’s decisions. The appellate court held that Dr. Jimenez failed to exhaust administrative remedies for his claims related to the denial of bonuses and failure to promote. The court also found that Dr. Jimenez did not present sufficient evidence to show that his race, national origin, or protected activity influenced the BOP’s actions. Additionally, the court upheld the dismissal of the Rehabilitation Act claim, agreeing that the citation error was not a mere scrivener’s error and that Dr. Jimenez did not demonstrate good cause to amend his complaint after the scheduling order deadline. View "Jimenez v. Acting United States Attorney General" on Justia Law

David Jenny, an employee of L3Harris Technologies, Inc., suffered from recurring cellulitis, which was aggravated by frequent international travel required by his job. He requested and was granted an accommodation to book seats with extra legroom on long flights. However, within three months of this accommodation, Jenny was denied permission to travel for routine business, removed from his leadership role, and ultimately discharged. Jenny sued L3Harris for discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Rehabilitation Act.The United States District Court for the District of Utah acknowledged that Jenny established a prima facie case of discrimination and retaliation and produced sufficient evidence that L3Harris’s explanation for his discharge was pretextual. Despite this, the district court granted summary judgment to L3Harris, citing the exception set out in Reeves v. Sanderson Plumbing Products, Inc., concluding that Jenny’s evidence did not sufficiently link his discharge to any discriminatory or retaliatory motive.The United States Court of Appeals for the Tenth Circuit reviewed the case and found that the district court improperly applied the Reeves exception. The Tenth Circuit held that Jenny had indeed met the requirements of the McDonnell Douglas burden-shifting framework and that the evidence, viewed in the light most favorable to Jenny, did not meet the requirements for invoking the Reeves exception. The Tenth Circuit reversed the district court’s order granting summary judgment to L3Harris and remanded the case for further proceedings. View "Jenny v. L3Harris Technologies, Inc." on Justia Law

Plaintiffs, consisting of several Cement and Concrete Workers District Council Funds and their fiduciary, sued Defendants Manny P. Concrete Co., Inc. and Manny P. Con Industries, Inc. for failing to make fringe benefit contributions as required by a collective bargaining agreement (CBA). The CBA mandated contributions to the Funds for work performed by employees within its jurisdiction. An audit revealed that Defendants owed significant amounts in unpaid contributions and dues checkoffs.The United States District Court for the Eastern District of New York granted summary judgment in favor of the Plaintiffs. The court deemed the matters within Plaintiffs' Requests for Admissions admitted due to Defendants' failure to respond timely. Consequently, the court found no genuine disputes of material fact and ruled that Plaintiffs were entitled to summary judgment.On appeal, the United States Court of Appeals for the Second Circuit reviewed the district court's decision. The appellate court held that the district court did not abuse its discretion in deeming the matters admitted under Federal Rule of Civil Procedure 36. The court found that the requests sought admissions of fact or the application of law to fact, which are permissible under Rule 36. The appellate court also agreed that Defendants' failure to respond timely constituted implied admissions, and the district court was correct in not allowing Defendants to withdraw or amend these admissions.The Second Circuit affirmed the district court's grant of summary judgment, concluding that there were no genuine disputes of material fact regarding the contributions owed by Defendants. The court noted that Defendants' arguments and evidence did not sufficiently counter the admissions and findings from the audit. Thus, the judgment of the district court was affirmed. View "Cement and Concrete Workers District Council Welfare Fund v. Manny" on Justia Law

Dawn Hayes was employed by Clariant Plastics & Coatings USA, Inc. for 25 years as a warehouse logistics clerk. In 2018, she was terminated as part of a workforce reduction program. Hayes contended that her termination was due to gender and age discrimination, and she also alleged unequal pay and a hostile work environment. She filed a lawsuit in federal court asserting these claims.The United States District Court for the Western District of Michigan granted summary judgment in favor of Clariant on all claims. The court found that Hayes did not establish a prima facie case of age discrimination and that her hostile work environment claim was time-barred and not administratively exhausted. The court also dismissed her state-law claims without prejudice.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court agreed with the district court that Clariant was entitled to summary judgment on the age discrimination and hostile work environment claims. However, the court found that Hayes had presented a genuine issue of material fact on her gender discrimination and unequal pay claims. The court noted that Hayes had superior qualifications compared to a similarly situated male employee who was retained, and there was evidence of a discriminatory atmosphere at Clariant.The Sixth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings on the gender discrimination and equal pay claims. The court also instructed the district court to reconsider its decision to dismiss the state-law claims in light of the reinstated federal claims. View "Hayes v. Clariant Plastics & Coatings USA, Inc." on Justia Law

Officer Jeff Smith, the oldest and longest-tenured police officer in the City of Union, Ohio, was terminated after allegedly violating several police department policies over a two-day period. An arbitrator later ordered his reinstatement, finding the termination to be an overreaction to minor and excusable mistakes. However, the City delayed his return for two months, requiring a fitness-for-duty examination and acting slowly once he passed it. During this delay, a younger officer was promoted, and raises were secured for all officers except Smith.Smith sued the City under the Age Discrimination in Employment Act (ADEA) and its Ohio counterpart, alleging age-based termination and retaliatory delay in his return for filing a charge with the Equal Employment Opportunity Commission (EEOC). The United States District Court for the Southern District of Ohio granted summary judgment to the City on both claims, leading Smith to appeal.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that a jury could view the facts and agree with Smith, particularly given the arbitrator's decision and a comment by the police chief about "younger officers." The court held that Smith presented enough circumstantial evidence to raise a triable question of whether the City terminated him due to his age. Additionally, the court found that the City's delay in reinstating Smith, which caused him to miss a promotion and a raise, could be seen as retaliatory.The Sixth Circuit reversed the district court's grant of summary judgment for the City and remanded the case for further proceedings, allowing Smith's claims of age discrimination and retaliation to proceed. View "Smith v. City of Union" on Justia Law

Jose E. Amstutz, a police officer employed by Harris County Precinct 6, was terminated after his wife filed a police report alleging domestic abuse. Amstutz was placed on leave and later terminated following an internal investigation that found he violated several policies. Amstutz claimed his wife had a history of making false allegations and had informed his supervisors about this potential. After his termination, Amstutz struggled to find other law enforcement employment, which he attributed to the General Discharge noted in his F-5 report.The United States District Court for the Southern District of Texas dismissed Amstutz’s Age Discrimination in Employment Act (ADEA) claims for failure to exhaust administrative remedies and for not responding to the timeliness challenge. The court also dismissed his 42 U.S.C. § 1983 claims, finding that he had not pleaded a protected property interest in his at-will employment.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s dismissal of the ADEA claims, agreeing that Amstutz failed to address the timeliness challenge, thus waiving opposition to that argument. The court also affirmed the dismissal of the § 1983 claims, concluding that Amstutz did not identify any independent source of law that would create a property interest in his employment. The court found that Amstutz’s employment was at-will and that he did not have a legitimate claim of entitlement to continued employment. Consequently, the court also dismissed Amstutz’s Monell claim against Harris County, as there was no underlying constitutional violation. The court affirmed the district court’s denial of leave to amend, finding no abuse of discretion. View "Amstutz v. Harris County" on Justia Law

A group of former managers of Ruby Tuesday, Inc. participated in two top-hat retirement plans administered by Regions Bank. These plans were unfunded and designed for high-level employees, meaning they were exempt from certain ERISA fiduciary duties. When Ruby Tuesday filed for bankruptcy, the managers lost their benefits and sued Regions Bank, alleging breaches of state-law fiduciary, trust, contract, and tort duties. They also sought equitable relief under ERISA to recover their lost benefits.The United States District Court for the Eastern District of Tennessee dismissed the state-law claims, ruling that ERISA preempted them. The court also granted summary judgment to Regions Bank on the ERISA claim, concluding that the requested monetary relief did not qualify as equitable relief under ERISA.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that ERISA preempted the state-law claims because they related to an ERISA-covered plan. The court emphasized that allowing state-law claims would undermine ERISA's uniform regulatory scheme. Additionally, the court held that the monetary relief sought by the plaintiffs did not qualify as equitable relief under ERISA. The court reasoned that the plaintiffs' request for an "equitable surcharge" was essentially a request for legal damages, which ERISA does not permit under its equitable relief provision.Thus, the Sixth Circuit affirmed the district court's judgment in favor of Regions Bank, concluding that the plaintiffs could not pursue their state-law claims or obtain the requested monetary relief under ERISA. View "Aldridge v. Regions Bank" on Justia Law