Justia Labor & Employment Law Opinion Summaries

Pablo Arredondo Padron was hired by Hugo Osoy to install two skylights in Osoy’s home. The project was expected to take 10 to 12 days, with Padron working eight hours each day. However, Padron fell from a ladder and was injured before completing 52 hours of work. Padron sued Osoy for negligence, but the trial court granted summary judgment in favor of Osoy, finding that Padron’s claims were exclusively covered by workers’ compensation.The Superior Court of Los Angeles County ruled that Padron’s employment was covered by workers’ compensation under Labor Code section 3351(d), which includes individuals employed by homeowners for duties incidental to the ownership, maintenance, or use of the dwelling. The court also found that Padron did not fall under the exclusion in section 3352(a)(8)(A), which excludes workers employed for less than 52 hours in the 90 days preceding the injury, because Padron had contracted to work for more than 52 hours.The California Court of Appeal, Second Appellate District, Division One, affirmed the trial court’s decision. The appellate court held that the exclusion in section 3352(a)(8)(A) does not apply when the employment is contracted to be for more than 52 hours, regardless of the actual hours worked before the injury. The court also rejected Padron’s arguments that he was not subject to the workers’ compensation system and that Osoy should be estopped from asserting the exclusivity defense. The court concluded that Osoy had secured workers’ compensation coverage through his homeowners’ insurance policy, which included the required coverage by operation of law. Therefore, Padron’s exclusive remedy was under the workers’ compensation system, and the summary judgment in favor of Osoy was affirmed. View "Padron v. Osoy" on Justia Law

Robert Caldwell was recruited by Champlain College's then-president Don Laackman in September 2016 and worked as Vice President of Advancement and later as Chief Advancement Officer from January 2017 to September 2019. His role was primarily as chief fundraiser. In fiscal year 2018, he missed his fundraising goal by approximately seventeen percent, and in fiscal year 2019, he missed his goal by more than 56 percent, resulting in a shortfall of over 2.2 million dollars. In May 2019, Caldwell was diagnosed with chronic kidney disease and informed President Laackman of his diagnosis. Laurie Quinn replaced Laackman as interim-president in June 2019 and discussed Caldwell's performance with him in July 2019. Caldwell mentioned he was dealing with health issues. In September 2019, Quinn fired Caldwell, citing his poor fundraising performance.Caldwell sued Champlain College in March 2021, alleging disability discrimination under the Fair Employment Practices Act (FEPA) and promissory estoppel. The Superior Court, Chittenden Unit, Civil Division granted summary judgment in favor of Champlain College on both claims. Caldwell appealed the decision.The Vermont Supreme Court reviewed the case and affirmed the lower court's decision. The court applied the McDonnell Douglas framework for assessing disability discrimination claims and found that Champlain College provided a legitimate, nondiscriminatory reason for Caldwell's termination—his failure to meet fundraising goals. Caldwell failed to provide evidence that this reason was pretextual. Additionally, the court found that Caldwell did not present any evidence of a specific and definite promise that would support his promissory estoppel claim. Therefore, the court affirmed the summary judgment in favor of Champlain College. View "Caldwell v. Champlain College Inc." on Justia Law

Scott Hampe was employed by Charles Gabus Motors, Inc. (Gabus) from 2008 until December 2019. Gabus conducted an unannounced drug test on December 5, 2019, assisted by Mid-Iowa Occupational Testing (Mid-Iowa). Hampe was selected as an alternate for testing and was ultimately tested. During the test, Hampe provided two insufficient urine samples and decided to leave the testing area to care for his sick child, despite being warned by his manager that leaving would result in termination. Hampe was subsequently fired.Hampe filed a lawsuit against Gabus and Mid-Iowa in May 2020, alleging violations of Iowa Code section 730.5, which governs employer drug testing, and asserting common law claims. The Iowa District Court for Polk County granted summary judgment in favor of Gabus and Mid-Iowa, dismissing all of Hampe’s claims. Hampe appealed, and the Iowa Court of Appeals affirmed the dismissal of claims against Mid-Iowa and most claims against Gabus but reversed the dismissal of claims related to testing pool requirements, supervisor training, and uniform disciplinary policy, finding genuine issues of material fact.The Iowa Supreme Court reviewed the case and focused on Hampe’s claim that Gabus violated section 730.5’s requirements for the composition of testing pools. The court concluded that Gabus failed to substantially comply with the statutory requirements for the testing pool, as the pool included employees who were not scheduled to work at the time of testing. The court also found that Hampe was aggrieved by this failure, as his selection for testing and subsequent termination were based on a non-compliant process. The court reversed the district court’s judgment in part, affirmed it in part, and remanded the case for further proceedings to determine the appropriate relief for Hampe. The court also deemed Hampe’s claims concerning supervisor training and uniform disciplinary policy moot in light of the resolution of the pooling claim. View "Hampe v. Charles Gabus Motors, Inc." on Justia Law

Gregory and Jeffrey Cota, employees of the Oconomowoc Area School District, were accused by a coworker of stealing money from the District. An internal investigation by the District was inconclusive, and the case was handed over to the police. The police investigation did not uncover new evidence, but the Cotas were cited for municipal theft. Approximately a year later, the assistant city attorney informed the District that he believed he could obtain a conviction. The next day, the District terminated the Cotas' employment.The Cotas filed claims of arrest-record discrimination under the Wisconsin Fair Employment Act, alleging that their termination was due to their arrest records. An administrative law judge initially found in favor of the District, but the Labor and Industry Review Commission (LIRC) reversed this decision, concluding that the District had engaged in arrest-record discrimination. The circuit court affirmed LIRC's decision, but the court of appeals reversed, holding that the Act's definition of "arrest record" did not include non-criminal offenses like municipal theft.The Wisconsin Supreme Court reviewed the case and held that the phrase "any . . . other offense" in the Act's definition of "arrest record" includes non-criminal offenses. The Court found that LIRC's conclusion that the District terminated the Cotas because of their arrest records was supported by substantial evidence. The Court rejected the District's argument that it was protected by the "Onalaska defense," which allows termination based on an internal investigation's findings, because LIRC found that the District relied on arrest-record information. The decision of the court of appeals was reversed, affirming LIRC's decision that the District violated the Act by terminating the Cotas due to their arrest records. View "Oconomowoc Area School District v. Cota" on Justia Law

Emily Johnston began teaching in the North Olmsted City School District in the 2018-2019 school year. Initially, the school board offered her a salary based on ten years of teaching experience, but before she signed the contract, they recalculated it based on six years of experience. Johnston signed the contract with the lower salary. She did not file a grievance under the collective-bargaining agreement (CBA) and later sought a writ of mandamus for the higher salary and backpay.The Eighth District Court of Appeals dismissed Johnston’s complaint, reasoning that she had an adequate remedy through the CBA’s grievance procedure. Johnston argued that the grievance procedure was inadequate because it did not allow for backpay and that she could not use it until her contract was signed. The court found that she had ample opportunity to file a grievance from her first paycheck and that her failure to do so did not make the remedy inadequate.The Supreme Court of Ohio affirmed the Eighth District’s decision. The court held that Johnston had an adequate remedy in the ordinary course of law through the CBA’s grievance procedure, which she failed to utilize. The court also rejected Johnston’s argument that her claim was purely statutory and not subject to the CBA, noting that the CBA implemented the board’s authority under relevant statutes and addressed salary-schedule placement. Therefore, Johnston’s claim was governed by the CBA, and her failure to file a grievance precluded mandamus relief. View "State ex rel. Johnston v. North Olmsted City School District Board of Education" on Justia Law

Jamilah Way, a lawyer employed by the City of Missouri City, Texas, from August 2018 to January 2021, developed anxiety and fibroids during her employment. She requested accommodations and took leave under the Family and Medical Leave Act (FMLA). Shortly after returning from her FMLA leave, she was terminated. Way sued the City under the FMLA, the Americans with Disabilities Act (ADA), and the Texas Commission on Human Rights Act (TCHRA), alleging discrimination, retaliation, and interference.The United States District Court for the Southern District of Texas granted summary judgment in favor of the City on all of Way’s claims. The court found that Way did not sufficiently inform the City about the limitations caused by her anxiety or fibroids and that the City had legitimate, non-retaliatory reasons for her termination.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the summary judgment on Way’s fibroid-related ADA and TCHRA claims, ADA and TCHRA retaliation claims, and FMLA interference claim. However, it reversed the summary judgment on Way’s anxiety-related ADA and TCHRA discrimination claims and her FMLA retaliation claim. The court found that Way provided sufficient evidence to suggest that her anxiety was a qualifying disability, that she informed her employer of her condition, and that the City failed to accommodate her reasonably. Additionally, the court found that the timing of her termination, shortly after her FMLA leave, and the City’s inconsistent explanations for her termination could support a finding of pretext for retaliation.The case was remanded for further proceedings consistent with the appellate court’s findings. View "Way v. City of Missouri City" on Justia Law

In 2019, the Rhode Island Department of Corrections (DOC) implemented changes to its Absenteeism Management Program (AMP), citing abuse of the existing sick-time policy. The changes included new discipline tracks, sanctions for absenteeism, stricter sick note requirements, and closer scrutiny of pattern sick time use. The Rhode Island Brotherhood of Correctional Officers (RIBCO) requested bargaining over these changes, which the DOC refused, leading RIBCO to file an unfair labor practice charge.The Rhode Island State Labor Relations Board (SLRB) found that the DOC had committed an unfair labor practice by making substantial changes to working conditions without bargaining. The board rejected the DOC's defenses, including the argument that the changes were within the director’s statutory authority and the management-rights clause of the collective bargaining agreement (CBA).The DOC appealed to the Superior Court, which reversed the SLRB's decision. The Superior Court found that the board's decision was not supported by substantial evidence and that the changes were within the DOC director’s statutory authority under Rhode Island law.The Rhode Island Supreme Court reviewed the case and affirmed the Superior Court's judgment. The Court held that the SLRB's decision was not supported by reliable, probative, and substantial evidence. It also agreed that the changes to the AMP were within the DOC director’s statutory authority under sections 42-56-10(2), (5), and (7) of the Rhode Island General Laws, which grant the director broad discretion in managing the department, maintaining safety and order, and disciplining employees. Thus, the DOC was not obligated to bargain over the AMP changes. View "State of Rhode Island v. Rhode Island State Labor Relations Board" on Justia Law

Jan Kuklenski was terminated by Medtronic USA, Inc. and subsequently filed a lawsuit in federal court, claiming that her termination violated the Minnesota Human Rights Act (MHRA) due to her disability. Kuklenski had worked for Medtronic since 1999 but had not resided in Minnesota. She occasionally traveled to Minnesota for work until the COVID-19 pandemic, after which she worked remotely. She went on medical leave in June 2021, and after her initial three-month leave expired, Medtronic filled her position and formally terminated her in December 2021.The United States District Court for the District of Minnesota granted summary judgment in favor of Medtronic, concluding that Kuklenski could not bring claims under the MHRA because she did not meet the statutory definition of an “employee,” which requires either residency or physical presence in Minnesota. The court found that Kuklenski had not been physically present in Minnesota for almost two years before her termination.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court’s grant of summary judgment, agreeing that the MHRA’s definition of “employee” requires some degree of physical presence in Minnesota. The court found that the statutory language was clear and unambiguous, requiring that an individual must either reside or work within the physical limits of Minnesota to be protected under the MHRA. The court also denied Kuklenski’s request to certify the question to the Minnesota Supreme Court, noting that the case did not present a close question of state law and that certification was not appropriate given the circumstances.The Eighth Circuit held that the MHRA’s definition of “employee” necessitates physical presence in Minnesota, and since Kuklenski had not been physically present in the state for nearly two years, she did not qualify as an employee under the Act. View "Kuklenski v. Medtronic USA, Inc." on Justia Law

Natasha Knox, a Black woman of Jamaican descent, worked as a customer service attendant at three Clean Rite laundromats in the Bronx from December 2018 until her termination in April 2019. She alleged that her supervisors, Cecilia Ashmeade and Kenneth Ferris, made derogatory comments about her race and national origin, and that Clean Rite failed to accommodate her disability following a thumb injury. Knox also claimed she was not paid for extra shifts worked at other locations and was wrongfully terminated after reimbursing herself for taxi fare from the cash register, which she claimed was permitted.The United States District Court for the Southern District of New York granted summary judgment in favor of Clean Rite, dismissing Knox’s claims of discriminatory and retaliatory termination, hostile work environment, refusal to accommodate her disability, and unpaid wages. The district court found that Knox had not provided sufficient evidence to support her claims. Knox’s motion to strike the defendants’ answer and request for default judgment against Ashmeade and Ferris, who had failed to appear, was denied as moot.The United States Court of Appeals for the Second Circuit reviewed the case de novo and found that Knox had presented sufficient evidence to survive summary judgment on all her claims. The court noted that evidence such as Knox’s testimony and sworn affidavit could lead a reasonable jury to find in her favor. The court vacated the district court’s judgment and remanded the case for further proceedings on each of Knox’s claims. The claims against Ashmeade and Ferris were reinstated for the district court to reconsider Knox’s motion to strike their answer and for default judgment. View "Knox v. CRC Management Co." on Justia Law

Sharon Lewis, a former employee of Louisiana State University (LSU) football department, reported sexual harassment by former head football coach Les Miles and assistant coach Frank Wilson. She claimed retaliation for these reports, including exclusion from meetings, restructuring of her position, and eventual termination in 2022. Lewis filed a lawsuit under Titles IX and VII against the LSU Board of Supervisors, alleging retaliation and hostile work environment.The United States District Court for the Middle District of Louisiana held a six-day trial, after which the jury found in favor of the Board on all claims. The district court entered judgment accordingly. Lewis filed a renewed motion for judgment as a matter of law or, alternatively, for a new trial, which the district court denied. Lewis then appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s judgment and denial of Lewis’s motions. The appellate court found that the jury had a legally sufficient evidentiary basis to conclude that Lewis’s termination was part of a broader restructuring initiative by new head coach Brian Kelly, rather than retaliation for her Title IX and Title VII complaints. The court noted that Kelly and other key decision-makers were unaware of Lewis’s prior complaints at the time of her termination. The court also found no abuse of discretion in the district court’s denial of a new trial, as the jury’s verdict was supported by the evidence presented. View "Lewis v. Board of Supervisors of Louisiana State University" on Justia Law