Justia Labor & Employment Law Opinion Summaries

The case involves Appvion, Inc., a Wisconsin-based paper company, which was sold to its employees through an Employee Stock Ownership Plan (ESOP) in 2001. The company declared bankruptcy in 2017. Grant Lyon, acting on behalf of the ESOP, filed a lawsuit against various individuals and corporations, alleging that they fraudulently inflated the price of Appvion in 2001 and that the price remained inflated until Appvion’s bankruptcy. The district court dismissed almost all the claims.On appeal, the United States Court of Appeals for the Seventh Circuit affirmed the dismissal of some claims and reversed and remanded others. The court affirmed the dismissal of claims related to actions before November 26, 2012, as they were time-barred under the Employee Retirement Income Security Act (ERISA). However, the court reversed the dismissal of claims related to actions after November 26, 2012, finding that the plaintiff had adequately alleged that the defendants breached their fiduciary duties under ERISA by failing to ensure that the company's valuations were sound. The court also reversed the dismissal of claims alleging that the defendants engaged in prohibited transactions and co-fiduciary liability. The court affirmed the dismissal of state-law claims against the defendants, finding them preempted by ERISA. View "Appvion, Inc. Retirement Savings and Employee Stock Ownership Plan v. Buth" on Justia Law

The case revolves around June LaMarr, an employee at the University of California Davis Medical Center, who was transferred to a different department following performance issues and conflicts with her supervisor. The transfer was initially temporary, but later became permanent, resulting in a decrease in LaMarr's pay. LaMarr sued the Regents of the University of California, alleging that her due process rights were violated as she was not provided a hearing under Skelly v. State Personnel Bd. before her demotion.The trial court found in favor of the Regents. It concluded that LaMarr was not deprived of due process when she was offered the option to either transfer to a non-supervisory position with reduced pay or return to her higher paying supervisory position and face possible termination proceedings. The court reasoned that the Regents never issued a notice of intent to dismiss and that LaMarr's feeling of duress did not trigger due process protections.In the Court of Appeal of the State of California Third Appellate District, LaMarr appealed the trial court's decision, arguing that the finding lacked substantial evidence. She contended that she was not informed of the adverse consequences of accepting a transfer and that her acceptance of the transfer was not voluntary.The appellate court affirmed the trial court's decision. It found substantial evidence that the Regents did not violate LaMarr's due process rights because she was never notified of an intent to terminate and any demotion was voluntary. The court also noted that a difficult choice is not the same as an involuntary choice. It concluded that there was substantial evidence supporting the trial court's finding that the Regents did not deprive LaMarr of due process. View "LaMarr v. The Regents of the University of California" on Justia Law

The case involves Angel Mondragon, an employee of Sunrun Inc., who was required to sign an arbitration agreement as a condition of his employment. The agreement covered most disputes related to Mondragon’s employment but excluded claims brought under the Private Attorney General Act of 2004 (PAGA). After his employment ended, Mondragon filed a complaint asserting several causes of action under PAGA. Sunrun filed a motion to compel arbitration of Mondragon’s claims, which the trial court denied. Sunrun appealed the decision, arguing that the trial court erred in ruling on whether Mondragon’s claims were arbitrable.The Superior Court of Los Angeles County had previously denied Sunrun's motion to compel arbitration. The court ruled that it, not the arbitrator, should decide questions of arbitrability. The court also ruled that the arbitration agreement unambiguously excluded PAGA claims and did not differentiate between individual PAGA claims and PAGA claims brought on behalf of other employees.The Court of Appeal of the State of California Second Appellate District Division Seven affirmed the decision of the lower court. The court concluded that Mondragon, an unsophisticated party, did not delegate arbitrability decisions to the arbitrator. The court also concluded that the language of the arbitration agreement did not require Mondragon to arbitrate his individual PAGA claims. Therefore, the court affirmed the decision of the lower court. View "Mondragon v. Sunrun Inc." on Justia Law

The case involves Daniel L. Renner, a groundskeeper for Saginaw County, Michigan, who was part of a bargaining unit represented by the Technical, Professional, and Officeworkers Association of Michigan (the Union). Renner opted out of dues-paying membership with the Union in 2017. In 2018, Renner filed a complaint with his employer, alleging that a coworker smoked around him, which was injurious to his health. When Renner attempted to commence a formal grievance procedure, he was informed that only the Union could pursue the grievance procedure. The Union, however, required Renner to pay a fee for its assistance with the grievance under its pay-for-service policy for nonmembers. Renner refused to pay the fee, the Union did not provide assistance, and the deadline for pursuing the grievance expired.Renner filed an unfair labor practice charge with the Michigan Employment Relations Commission (MERC) against the Union, alleging that the Union violated its duty of fair representation by refusing to represent him in a grievance with his employer unless Renner paid a fee for direct representation services. An administrative law judge (ALJ) ruled in favor of Renner, concluding that the direct service fee was not permitted under the public employment relations act (PERA) or the collective bargaining agreement and that it constituted an unfair labor practice. MERC adopted the decision of the ALJ, and the Union appealed in the Court of Appeals, which affirmed MERC’s decision.The Union sought leave to appeal in the Michigan Supreme Court, which granted the Union’s application in part. The Supreme Court held that under the 2014 version of PERA, a public sector union that is the exclusive bargaining representative of a bargaining unit violates the union’s duty of fair representation by requiring an employee in that bargaining unit who is not a member of the union to pay a fee for the union’s representative services when the union’s pay-for-service policy denies the nonmember employee access to the grievance administration process under the collective bargaining agreement. The Supreme Court affirmed in part and vacated in part the judgment of the Court of Appeals and the decision of MERC. View "Technical, Professional, and Officeworkers Assn v. Renner" on Justia Law

The case involves David Duff II, a Kanawha County Deputy Sheriff, who injured his back while on duty. He applied for workers' compensation benefits and was awarded a 13% Permanent Partial Disability (PPD) award. The award was based on a medical report that found Duff had a 25% whole person impairment, but 12% of this was attributed to a preexisting condition. Duff protested this award to the West Virginia Workers’ Compensation Board of Review (BOR), arguing that no apportionment was indicated. However, the BOR affirmed the 13% PPD award. Duff then appealed to the Intermediate Court of Appeals of West Virginia (ICA), which also affirmed the BOR's decision.The case was then brought before the Supreme Court of Appeals of West Virginia. The court found that the ICA erred in affirming the BOR's decision. The court held that under West Virginia Code § 23-4-9b (2003), the employer has the burden of proving apportionment is warranted in a workers' compensation case. This requires the employer to prove the claimant "has a definitely ascertainable impairment resulting from" a preexisting condition(s). The court found that the respondent failed to carry its burden of proving the degree of impairment to be attributed to any preexisting condition for purposes of apportionment. The court reversed the ICA's decision and remanded the case to the BOR with directions to grant Duff an additional 12% PPD award for a total PPD award of 25%. View "Duff v. Kanawha County Commission" on Justia Law

A group of non-convicted individuals detained at the Santa Rita Jail in Alameda County, California, filed a lawsuit against the county and a private contractor, Aramark Correctional Services, LLC. The detainees were working in the jail's kitchen, preparing meals for the jail population and staff under an agreement between the county and Aramark. They were not paid for their labor. The detainees sued for failure to pay minimum wage and overtime.The case was initially heard in a federal district court, which granted in part and denied in part the defendants' motions to dismiss. The court reasoned that while the Penal Code addresses employment and wages of state prisoners, it does not address such matters for pretrial detainees confined in county jails. The court also agreed with the County that government entities are exempt from state overtime laws and therefore granted the County's motion to dismiss the claim for overtime wages. The district court certified for interlocutory appeal the legal question of pretrial detainees’ entitlement to minimum and overtime wages.The Supreme Court of California was asked by the United States Court of Appeals for the Ninth Circuit to decide whether non-convicted incarcerated individuals working in a county jail for a private company have a claim for minimum wage and overtime under California law. The Supreme Court of California concluded that non-convicted incarcerated individuals performing services in county jails for a for-profit company do not have a claim for minimum wages and overtime under Section 1194 of the California Labor Code, even in the absence of a local ordinance prescribing or prohibiting the payment of wages for these individuals. View "Ruelas v. County of Alameda" on Justia Law

A scientist with physical disabilities, Dr. Andrew Mattioda, sued his employer, the National Aeronautics and Space Administration (NASA), under the Rehabilitation Act of 1973. He alleged that he suffered a hostile work environment after informing his supervisors of his disabilities and requesting upgraded airline tickets for work travel. He also claimed he was discriminated against due to his disability by being passed over for a promotion.The United States District Court for the Northern District of California dismissed Dr. Mattioda’s hostile-work-environment claim and granted summary judgment in favor of NASA on his disability-discrimination claim. The court concluded that Dr. Mattioda failed to allege a plausible causal nexus between the claimed harassment and his disabilities. It also held that NASA provided a legitimate nondiscriminatory reason for not selecting Dr. Mattioda for an available senior scientist position.On appeal, the United States Court of Appeals for the Ninth Circuit reversed the district court’s dismissal of Dr. Mattioda’s hostile-work-environment claim, affirming that a disability-based harassment claim is available under the Americans with Disabilities Act of 1990 and the Rehabilitation Act. The court held that Dr. Mattioda plausibly alleged a hostile-work-environment claim based on his disability. However, the court affirmed the district court’s order granting summary judgment for NASA on the disability-discrimination claim, agreeing that NASA had provided a legitimate nondiscriminatory reason for not selecting Dr. Mattioda for the senior scientist position. The case was remanded for further proceedings. View "MATTIODA V. NELSON" on Justia Law

Kevin D. Jones, an attorney, held a term position with the U.S. Department of Agriculture (USDA) before transferring to the Department of Justice’s (DOJ) Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). At the USDA, Jones primarily provided advice and counsel regarding discrimination complaints filed against the agency and litigated ensuing discrimination claims before the Equal Employment Opportunity Commission (EEOC). At the ATF, Jones served as an advisor to the Professional Review Board (PRB) as part of a team of attorneys in the Management Division of the ATF Office of General Counsel (OGC). After three months at the ATF, Jones was asked to resign due to his lack of contract law experience. Jones filed a complaint alleging discrimination and lack of due process in his termination.The Merit Systems Protection Board (MSPB) dismissed Jones's administrative appeal for lack of jurisdiction. The Administrative Judge (AJ) of the MSPB found that Jones was not an "employee" as defined by 5 U.S.C. § 7511(a)(1)(B) because his positions at the USDA and ATF were not the same or similar. The AJ noted several distinctions between the tasks Jones performed at each agency. Jones did not appeal the Initial Decision to the full Board, so the AJ’s Initial Decision became the Final Decision of the Board.The United States Court of Appeals for the Federal Circuit affirmed the Board's decision. The court found that the AJ did not err in her determination that Jones's positions at the USDA and ATF were not similar. The court also found that the AJ's decision was supported by substantial evidence. Therefore, the court affirmed the Board's determination that it lacked jurisdiction to hear Jones's appeal. View "Jones v. Merit Systems Protection Board" on Justia Law

The case revolves around a social worker, Janine Tea, who claimed to have developed post-traumatic stress disorder (PTSD) due to her exposure to the details of a murder committed by one of her clients. The county initially provided workers’ compensation benefits to Tea but discontinued those benefits after a licensed psychiatrist concluded she did not have PTSD. Tea objected to the discontinuance of her benefits and underwent an independent psychological evaluation in which she was diagnosed with PTSD. The compensation judge determined that Tea has compensable PTSD.The Workers’ Compensation Court of Appeals (WCCA) affirmed the compensation judge's decision. The county appealed, arguing that Tea did not meet the diagnostic criteria for PTSD listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM).The Supreme Court of Minnesota affirmed the WCCA's decision. The court held that the WCCA’s affirmance of the compensation judge’s finding that Tea has compensable PTSD is not manifestly contrary to the evidence. The court also held that the WCCA did not err in refusing to use the DSM to re-evaluate the compensation judge’s factual finding that Tea has PTSD. The court clarified that compensation judges may review the DSM criteria when considering the persuasiveness of expert reports, but judges may not use those criteria to make their own diagnosis of a claimant’s condition. View "Tea vs. Ramsey County" on Justia Law

The case involves Lizbeth Balderas, a former employee of Fresh Start Harvesting, Inc., who filed a complaint for civil penalties under the California Labor Code Private Attorneys General Act of 2004 (PAGA) on behalf of herself and 500 other current and former employees. Balderas alleged that Fresh Start violated labor laws by not providing required meal and rest breaks, providing inaccurate wage statements, making untimely wage payments, and failing to pay wages at termination. Balderas did not file an individual claim but proceeded solely under PAGA, representing all aggrieved employees.The trial court struck Balderas's complaint, ruling that she lacked standing to bring a representative PAGA action on behalf of other employees because she did not allege an individual claim in the action. The court relied on language from a United States Supreme Court decision that had incorrectly recited California law on PAGA standing.The Court of Appeal of the State of California Second Appellate District Division Six reviewed the case. The court concluded that Balderas, as an alleged aggrieved employee who was subject to alleged Labor Code violations by Fresh Start, may bring a representative PAGA action on behalf of herself and other Fresh Start employees, even though she did not file an individual cause of action seeking individual relief for herself in this action. The court held that the trial court erred by relying on the United States Supreme Court decision, which was incorrect on PAGA standing requirements. The court reversed the order striking the pleading. View "Balderas v. Fresh Start Harvesting, Inc." on Justia Law