Justia Labor & Employment Law Opinion Summaries

The case involves Qing Qin, a Chinese software architect who alleges that he was denied a promotion and wrongfully terminated from his position at Vertex, Inc. based on his race and national origin. He also claims that he was retaliated against for complaining about the alleged discrimination and that he was subjected to a hostile work environment. The District Court granted summary judgment in favor of Vertex on all claims.The case was reviewed by the United States Court of Appeals for the Third Circuit. The court agreed with the District Court that Qin did not present evidence to demonstrate a sufficiently severe and pervasive hostile work environment. However, the court found that Qin presented evidence that would give rise to an inference of discrimination and presented comparator evidence that would allow a reasonable jury to determine Vertex’s reasons for denying promotion and termination were pretextual. The court also found that the evidence and timeline of his protected activity are sufficient to find causation on his retaliation claims under their precedent.Therefore, the court affirmed the District Court’s grant of summary judgment in favor of Vertex on Qin’s hostile work environment claim but vacated the District Court’s order on his discrimination and retaliation claims. The case was remanded for further proceedings consistent with the opinion of the Court of Appeals. View "Qing Qin v. Vertex Inc" on Justia Law

This case involves a dispute between Union Pacific Railroad Company and its employee, Randy G. Franklin. Franklin, a long-time employee of Union Pacific, brought a gun to work and stored it in his locked vehicle, which was parked in Union Pacific's parking lot. This action was in compliance with Arkansas law, but violated Union Pacific's company policy that bans employees from carrying firearms onto its property. As a result, Union Pacific terminated Franklin's employment, which was later reduced to a lengthy suspension by an arbitration panel.Union Pacific filed a declaratory-judgment action in federal court, seeking a declaration that Arkansas Code Annotated section 11-5-117, which allows employees to store firearms in their vehicles on their employer's property, is preempted by the Federal Employers’ Liability Act (FELA) when applied to Union Pacific parking lots in Arkansas. Franklin counterclaimed, seeking a declaratory judgment that Union Pacific must allow him to bring his firearm onto railroad property, as long as the firearm is legally possessed for a lawful purpose and stored out of sight in his locked car.The United States District Court for the Eastern District of Arkansas certified a question to the Supreme Court of Arkansas: whether the prohibitions in Arkansas Code Annotated section 11-5-117 are severable from the liability-immunity provisions in section 16-120-802(a) such that section 11-5-117 would still apply when the liability-immunity provisions of section 16-120-802(a) cannot apply.The Supreme Court of Arkansas answered the certified question in the affirmative. The court found that section 11-5-117, which protects the rights of employees to store firearms in their vehicles on their employer's property, is not dependent on the liability-immunity provisions of section 16-120-802. Therefore, even if the latter is preempted by FELA, section 11-5-117 is not likewise preempted. The court concluded that regardless of whether FELA preempts section 16-120-802(a), section 11-5-117 still applies. View "UNION PACIFIC RAILROAD COMPANY V. FRANKLIN" on Justia Law

The case revolves around a workers' compensation claim filed by Billy J. Ottinger, who suffered a severe injury while working for B&B Wrecking & Excavating, Inc. Ottinger fell from a roof and landed on his legs, resulting in significant weakness and immobility. The Bureau of Workers’ Compensation awarded Ottinger compensation for the loss of use of both legs. However, the Industrial Commission of Ohio later vacated this decision, denying Ottinger's request for loss-of-use compensation.The Bureau's decision was initially challenged by the Industrial Commission, which argued that there was a lack of medical evidence to support the award for loss-of-use compensation. The Commission exercised its continuing jurisdiction and vacated the Bureau's decision, citing a clear mistake of fact and law. The Commission found that the Bureau's decision was based on an incorrect diagnosis of paraplegia, leading to the incorrect conclusion that Ottinger was completely paralyzed.Ottinger appealed to the Tenth District Court of Appeals, seeking a writ of mandamus to reinstate the Bureau's decision. However, the court of appeals denied the request, concluding that the Commission's decision was supported by some evidence and that awarding Ottinger loss-of-use compensation based on that evidence was a clear mistake of law.The Supreme Court of Ohio affirmed the Tenth District's judgment. The court found that the Commission did not abuse its discretion by exercising its continuing jurisdiction to vacate the Bureau's order awarding Ottinger loss-of-use compensation based on a clear mistake of fact. The court also concluded that the Commission did not abuse its discretion by denying Ottinger's motion for loss-of-use compensation, as the decision was supported by some evidence. View "State ex rel. Ottinger v. B&B Wrecking & Excavating, Inc." on Justia Law

Angela Poer, a white woman, was employed as an Administrative Services Manager by the Jefferson County Commission. She alleged that her supervisor, a black woman, discriminated against her based on her race. Poer claimed that her request for a lateral transfer or reassignment was denied and that she was ultimately terminated due to her race. She sought damages including reinstatement and back pay.The district court granted summary judgment in favor of the Commission, finding that Poer failed to present any evidence showing that she was terminated or discriminated against because of her race. The court also declined to consider Poer’s argument that the Commission’s employment decisions were forms of retaliation in response to her grievances, as this argument was raised for the first time at summary judgment.On appeal, the United States Court of Appeals for the Eleventh Circuit affirmed the district court’s judgment. The court found that Poer had not presented a convincing mosaic of circumstantial evidence that would support even an inference at summary judgment, let alone a jury finding at trial, that the Commission terminated her because of her race. The court also agreed with the district court that Poer could not raise a retaliation claim for the first time at summary judgment. View "Poer v. Jefferson County Commission" on Justia Law

The case involves Dr. Gopal Balakrishnan, a former tenured professor at the University of California, Santa Cruz (UCSC), who was dismissed and denied emeritus status for sexually abusing a fellow academic at an off-campus academic conference and a UCSC student whom he volunteered to walk home from an off-campus graduation party. Balakrishnan appealed the decision, arguing that the university lacked jurisdiction to discipline him because the victims were not university students, the university misinterpreted and misapplied its own regulations and policies, he did not receive notice of all charges, and the sanctions were excessive.In the lower courts, Balakrishnan filed a petition for a writ of administrative mandate to set aside the findings and decision of the Regents of the University of California to terminate his employment and deny him emeritus status. The trial court denied his petition, upholding the university's decision.In the Court of Appeal of the State of California, the court rejected Balakrishnan's contentions and affirmed the trial court’s judgment. The court found that the university had the authority to discipline Balakrishnan for his off-campus behavior based on its internal policies, rules, and regulations. The court also found that Balakrishnan had received notice of the charges and that the sanctions were not excessive given the severity of his conduct. View "Balakrishnan v. Regents of the University of California" on Justia Law

David Steele filed a lawsuit against his employer, Johnson Controls, Inc. (JCI), alleging that the company had violated § 287.780 by retaliating and discriminating against him for filing a workers' compensation claim. Steele sought compensatory and punitive damages, arguing that JCI had acted with willful, deliberate, and reckless disregard for his rights. JCI did not file an answer or responsive pleading, and Steele subsequently filed a motion for default judgment and damages. The circuit court held a hearing regarding damages, during which Steele testified about his injuries and the discriminatory treatment he received from JCI. The court entered a default judgment for Steele, awarding him $300,000 in compensatory damages and $600,000 in punitive damages.JCI filed a motion to set aside the default judgment, citing Rules 75.01, 74.05(d), and 74.06(b)(1). JCI alleged that it had good cause for the default because its registered agent mislabeled the service documents and routed them to the incorrect section of JCI's legal department. The circuit court held a hearing on JCI's motion and subsequently overruled it, concluding that JCI failed to show good cause, a meritorious defense, or excusable neglect. JCI then filed a motion for a new trial, which the circuit court also overruled. JCI appealed the decision.The Supreme Court of Missouri affirmed the circuit court's judgment. The court found that JCI had failed to prove good cause for its default as required to set aside the default judgment pursuant to Rule 74.05(d). The court also found that JCI's reliance on Rules 75.01 and 74.06(b)(1) as alternate bases to set aside the default judgment was incorrect. Finally, the court ruled that JCI's defaulted claims asserting the circuit court plainly erred by awarding punitive damages in violation of § 510.2612 were not reviewable. View "Steele v. Johnson Controls, Inc." on Justia Law

The case involves Ramon Dejesus Cedeno, an employee of Strategic Financial Solutions, LLC, and a participant in its Strategic Employee Stock Ownership Plan. Cedeno sued the company, its trustee Argent Trust Company, and other defendants under the Employee Retirement Income Security Act (ERISA), alleging that a transaction caused the Plan to incur substantial losses and that Argent breached fiduciary duties owed to Plan participants. The defendants moved to compel arbitration under the Federal Arbitration Act (FAA), pointing to a provision in the Plan’s governing document that required Plan participants to resolve any claims related to the Plan in arbitration.The United States District Court for the Southern District of New York denied the motion, reasoning that the agreement was unenforceable because it would prevent Cedeno from effectuating rights guaranteed by Congress through ERISA, namely, the plan-wide relief available under Section 502(a)(2) to enforce the rights established in ERISA Section 409(a).On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court held that the arbitration provision is unenforceable because it would prevent Cedeno from pursuing the Plan-wide remedies Sections 409(a) and 502(a)(2) unequivocally provide. The court concluded that the entire arbitration provision is null and void due to a non-severability clause in the Plan. View "Cedeno v. Sasson" on Justia Law

The case revolves around a dispute over workers' compensation. The appellant, Brian Caldwell, was injured while working for the appellee, Whirlpool Corporation. After a successful initial workers’ compensation claim, Caldwell sought coverage for additional conditions a few years later. However, his claim for these additional conditions was denied after administrative hearings before the commission. Caldwell then appealed to a court of common pleas under R.C. 4123.512. The trial court and the court of appeals, in granting and affirming summary judgment in favor of Whirlpool, determined that Caldwell’s claim had expired as a matter of law because a separate statute, R.C. 4123.52, limited the commission’s continuing jurisdiction to five years from the date of the last payment of compensation on Caldwell’s initial claim and that five years had passed.The Supreme Court of Ohio disagreed with the lower courts' interpretation. The court held that when a workers’ compensation claimant perfects an appeal under R.C. 4123.512, the subsequent expiration of the commission’s five-year period of continuing jurisdiction under R.C. 4123.52 does not cause the claim that is pending in court to expire as a matter of law. The court reasoned that R.C. 4123.52, which establishes the continuing jurisdiction of the commission, does not affect R.C. 4123.512 court proceedings once they have been properly initiated. Therefore, the Supreme Court of Ohio reversed the judgment of the Third District Court of Appeals and remanded the case to the trial court for further proceedings. View "Caldwell v. Whirlpool Corp." on Justia Law

Monica Rongere, a former Diversity Procurement Officer for the City of Rockford, Illinois, sued the city after her employment was terminated. Rongere claimed that she was overworked and underpaid compared to her male colleagues, and that her termination was due to her complaints about this disparity. She brought claims under the Equal Pay Act, Title VII of the Civil Rights Act of 1964, the Illinois Human Rights Act, the Illinois Whistleblower Act, and Illinois common law, alleging equal pay, sex discrimination, hostile work environment, and retaliation.The district court ruled in favor of the City on the Equal Pay Act, Title VII, and Illinois Human Rights Act claims, and relinquished jurisdiction over the remaining state-law claims. Rongere appealed this decision.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The court found that Rongere failed to identify adequate comparators for her equal pay and sex discrimination claims, did not show that she engaged in protected activity based on an objectively reasonable belief for her retaliation claim, did not present sufficient evidence of a hostile work environment, and did not explain how the district court abused its discretion in relinquishing jurisdiction over the remaining claims. The court also found that Rongere did not hold an objectively reasonable belief that the City paid male employees more than female employees for the same work, which was necessary for her retaliation claims. View "Rongere v. City of Rockford" on Justia Law

The case involves Duke Bradford, Arkansas Valley Adventure (AVA), and the Colorado River Outfitters Association (CROA) who appealed against the District of Colorado’s order denying their motion to preliminarily enjoin a Department of Labor (DOL) rule. The rule required federal contractors to pay their employees a $15.00 minimum hourly wage. The DOL promulgated the rule pursuant to a directive in Executive Order (EO) 14,026, issued by President Biden. The EO imposed the minimum wage requirement on most federal contractors and rescinded an exemption for recreational services outfitters operating on federal lands.The appellants argued that the district court erred in concluding that the Federal Property and Administrative Services Act (FPASA) authorizes the minimum wage rule as applied to recreational services permittees because the government does not procure any services from them or supply anything to them. They also argued that the DOL acted arbitrarily and capriciously in promulgating the minimum wage rule without exempting recreational service permittees.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The court concluded that the appellants have not shown a substantial likelihood of success on the merits that the DOL’s rule was issued without statutory authority. The court held that FPASA likely authorizes the minimum wage rule because the DOL’s rule permissibly regulates the supply of nonpersonal services and advances the statutory objectives of economy and efficiency. The court also held that the appellants have not shown a substantial likelihood of success on the merits that the DOL’s rule is arbitrary and capricious. View "Bradford v. U.S. Department of Labor" on Justia Law