Justia Labor & Employment Law Opinion Summaries

Eva Stramaski, an academic advisor at Texas A&M University, was concerned her paycheck might arrive late after returning from medical leave. Despite being paid on time, her supervisor, Mark Lawley, accused her of being “aggressive” about the issue, sent her home, and issued a “coaching letter” citing performance problems. Stramaski disputed these allegations, and Lawley fired her a few days later. She then brought suit against Lawley in his personal capacity under the Fair Labor Standards Act (FLSA), claiming retaliation for asserting her right to timely pay.The United States District Court for the Southern District of Texas first heard the case. Lawley moved to dismiss the suit, arguing sovereign immunity and qualified immunity. A magistrate judge recommended dismissing claims for injunctive and declaratory relief but rejected both immunity defenses, and the district court adopted the recommendations over Lawley’s objections. Lawley appealed. In its first review (Stramaski I), the United States Court of Appeals for the Fifth Circuit held that sovereign immunity did not bar the case against Lawley personally but left open the issue of qualified immunity, remanding for further analysis. On remand, the district court again denied Lawley’s qualified immunity defense, and Lawley appealed a second time.The United States Court of Appeals for the Fifth Circuit, in this second appeal, addressed whether a public official may invoke qualified immunity in an FLSA retaliation suit. The court held that qualified immunity does not apply to such claims. It reasoned that, at the time Congress authorized private FLSA retaliation suits, the common law did not shield officials from malicious retaliation, and the purposes underlying qualified immunity are incompatible with the FLSA’s anti-retaliation protections. The court affirmed the district court’s denial of Lawley’s motion to dismiss. View "Stramaski v. Lawley" on Justia Law

A former police officer alleged that he experienced discrimination while employed by a municipal police department, culminating in his termination. The officer identified as Hispanic due to his Ecuadorian heritage and pointed to comments made by a superior several years prior, which he asserted reflected animus based on his background. Over the course of his employment, the officer was subject to multiple disciplinary actions, including remedial training, negative performance reviews, and investigations for failing to properly search arrestees. He was ultimately terminated after a hearing found repeated rule violations and dishonesty during official proceedings.After his termination, the officer filed a complaint in the United States District Court for the Southern District of New York, asserting, among other claims, discrimination based on national origin under 42 U.S.C. § 1983 and the New York State Human Rights Law. The court granted summary judgment to the defendants, finding that the officer failed to establish a prima facie case of discrimination, as he did not provide evidence that his superiors were aware of his Hispanic background or that the adverse employment actions were motivated by discriminatory intent. The court also determined that the municipality had legitimate, non-discriminatory reasons for the termination and that the officer failed to show pretext.On appeal, the United States Court of Appeals for the Second Circuit reviewed only the discrimination claims under Section 1983 and the NYSHRL regarding the officer’s termination. The appellate court affirmed the district court’s decision, holding that the officer failed to provide non-speculative evidence that the defendants knew of his Hispanic national origin or that his termination was the result of discrimination. The court concluded that the employer’s stated reasons for termination were legitimate and not a pretext for discrimination. View "Barberan v. Town of Eastchester" on Justia Law

This case involves a dispute between a county juvenile court and a labor union regarding the interpretation and application of two collective-bargaining agreements covering employees at a juvenile detention center and other court employees. Both agreements contained duration clauses, evergreen clauses, and arbitration provisions. When negotiations for successor agreements failed, the juvenile court declared the agreements expired and ceased recognizing the union. In response, the union filed a grievance and counterclaims, asserting that the evergreen clauses extended the agreements until certain conditions were met and that the court breached the agreements by unilaterally terminating them.Initially, the Cuyahoga County Court of Common Pleas found the agreements were not void ab initio for lack of consideration and recognized an extension of the agreements under the evergreen clauses, but not beyond December 31, 2020, due to public policy. The court ruled the union was entitled to damages for the breach but held that the union’s emailed grievance was not arbitrable, as considering it a grievance would violate public policy. The parties then cross-appealed.The Eighth District Court of Appeals reversed the trial court, holding that disputes concerning the interpretation of the evergreen and duration clauses, as well as the question of when the agreements expired, were subject to arbitration under the agreements. The appellate court ordered the parties to proceed to arbitration.The Supreme Court of Ohio affirmed the Eighth District’s decision. The court held that disputes about the expiration and interpretation of the collective-bargaining agreements are arbitrable, as they concern contract interpretation within the scope of the arbitration clauses. The court found sufficient consideration for the arbitration provisions and determined that challenges to the agreements’ formation did not affect the enforceability of the arbitration clauses. The matter was remanded to the trial court to order arbitration. View "O'Malley v. Laborers' Internatl. Union of N. Am., Local 860" on Justia Law

James Bien worked as a conductor for Union Pacific Railroad Company. In 2013, he failed two vision tests required for his job and was subsequently removed from his conductor position, receiving a work restriction that prevented him from performing duties requiring color signal recognition. After several months, he was employed by Union Pacific in a different, lower-paying role. In 2015, following a notification from the company, Bien took another vision test, which he passed. He then requested a follow-up test to potentially remove his work restriction and be reinstated as a conductor. Union Pacific denied this request, determining that his prior test failures were dispositive and that the new test had been administered in error. Bien filed a discrimination charge with the EEOC in April 2020 and later brought suit under the Americans with Disabilities Act (ADA) in January 2025.Prior to Bien's lawsuit, a class action had been filed in the District of Nebraska, Harris v. Union Pacific Railroad Company, challenging similar employment actions by Union Pacific. The initial class definition was broad, but the court later certified a narrower class. The United States District Court for the Eastern District of Texas concluded that Bien fell within the original class definition but not the certified, narrower one, reasoning that his 2015 testing and related correspondence did not constitute a “fitness-for-duty examination” under the certified class. As a result, the district court held that the statute of limitations barred Bien’s claim and dismissed his case.The United States Court of Appeals for the Fifth Circuit reviewed the dismissal de novo and reversed the district court’s decision. The Fifth Circuit held that, under American Pipe tolling, a plaintiff must be unambiguously excluded from a class definition to terminate tolling of the statute of limitations. Because Bien was not unambiguously excluded from the certified class, he was entitled to tolling, and his suit was not time-barred. The case was remanded for further proceedings. View "Bien v. Union Pacific" on Justia Law

The plaintiff was employed as a restaurant hostess by two corporate entities. She alleged that her supervisor engaged in sexual harassment and retaliation, resulting in her constructive discharge. She brought claims under California’s Fair Employment and Housing Act (FEHA) for gender discrimination, sexual harassment, retaliation, and failure to prevent discrimination, harassment, and retaliation. The plaintiff sought to hold the sole owner of the corporate entities personally liable, arguing he was their alter ego.A jury trial was held in the Superior Court of Los Angeles County on liability, which resulted in verdicts against the two corporate defendants and awarded the plaintiff compensatory and punitive damages. The alter ego claim against the owner was tried separately to the court. The trial court applied the common law presumption of corporate separateness, requiring the plaintiff to prove that the corporations’ distinct identities should be disregarded. The court found the plaintiff failed to meet her burden and issued judgment in favor of the owner. The plaintiff appealed, contending that FEHA should alter the presumption and favor alter ego liability.The Court of Appeal of the State of California, Second Appellate District, Division One, reviewed the legal question de novo. The court held that FEHA does not modify or abrogate the common law presumption of corporate separateness. It found no statutory language, legislative history, or case law that clearly or unequivocally indicated a legislative intent to alter the presumption. The court concluded that public policy and FEHA’s purpose do not require a contrary presumption favoring alter ego liability. The judgment for the owner was affirmed, and the parties were directed to bear their own costs on appeal. View "Villasenor v. Schneiter" on Justia Law

A teachers’ association and several former teachers sued a school district after the district declined to pay retroactive salary increases and stipends to teachers who had resigned before the district approved a collective bargaining agreement (CBA). The CBA, negotiated between the teachers’ association and the school district, provided for retroactive salary adjustments and stipends for the period July 1, 2022 through June 30, 2024. The six former teachers had worked during the period covered by the retroactive provisions but resigned before the CBA’s approval in August 2023. The district paid the retroactive benefits only to those who remained employed as of the approval date, excluding the former teachers.The plaintiffs filed a verified petition for writ of mandate in the Superior Court of San Bernardino County, arguing that Education Code section 45028 required uniform pay for teachers with equivalent training and experience, absent a negotiated exception. They contended the CBA applied retroactively to all teachers who worked during the relevant period, including those who had since resigned. The district argued that only current employees and certain former employees (laid off or retired) were covered, and relied on California Teachers Assn. v. Governing Bd. of Hilmar Unified School Dist. to support its interpretation. The trial court denied the petition, finding the CBA did not expressly include former employees and concluding that only active teachers were entitled to retroactive increases.The California Court of Appeal, Fourth Appellate District, Division One, reviewed the case de novo. It held that because the CBA did not restrict retroactive benefits to current employees and no negotiated criterion excluded resigned teachers, the district violated section 45028’s uniformity requirement by denying the former teachers retroactive payments. The judgment was reversed, and the trial court was directed to issue a writ compelling the district to pay the retroactive salary adjustments and stipends, plus associated employer contributions, to the former teachers. View "Trona Teachers Assn. v. Bd. of Trust. Trona Jt. Uni. Sch. Dist." on Justia Law

An employee who worked for a company from May 2021 until his termination in January 2024 signed an arbitration agreement at the start of his employment. This agreement required any employment-related disputes to be resolved through binding arbitration on an individual basis, with a waiver of class and collective actions. In November 2024, the employee notified the Labor and Workforce Development Agency (LWDA) of alleged Labor Code violations by his employer. After the LWDA did not respond within the statutory period, he became authorized to pursue a civil action for penalties under the Private Attorneys General Act (PAGA), acting as a proxy for the state. He subsequently filed a complaint in Stanislaus County Superior Court asserting only nonindividual PAGA claims—claims on behalf of other aggrieved employees and not for his own individual recovery—for various Labor Code violations.The employer responded by filing a motion to compel arbitration, arguing that PAGA required the inclusion of individual claims and that the arbitration agreement should apply. The Superior Court denied this motion, noting procedural irregularities and emphasizing that binding precedent allowed PAGA actions consisting solely of nonindividual claims. The court referenced a split in authority on whether PAGA actions could be limited to nonindividual claims, but ultimately relied on decisions holding such actions permissible, especially after recent statutory amendments.On appeal, the California Court of Appeal, Fifth Appellate District, affirmed the trial court’s decision. The appellate court held that, under the version of PAGA effective July 1, 2024, an aggrieved employee may bring a PAGA action consisting only of nonindividual claims and that these claims are not subject to arbitration, even if an arbitration agreement exists. The court further found that the statutory amendments did not require an employee to include individual claims, and that denying arbitration of nonindividual PAGA claims does not violate federal or state policy favoring arbitration. The denial of the motion to compel arbitration was affirmed. View "Castillo v. Belkorp AG, LLP" on Justia Law

The plaintiff, a former employee, brought claims against her employer alleging discrimination and retaliation under the California Fair Employment and Housing Act (FEHA), as well as wrongful discharge and breach of contract. After the employer prevailed on a motion for summary judgment, the trial court entered judgment in its favor, stating that the employer as the prevailing party could recover costs upon filing a memorandum of costs. The employer submitted a memorandum seeking over $15,000 in costs, which the trial court approved in an amended judgment when the plaintiff did not timely object.Following this, the plaintiff appealed solely on the issue of costs, not contesting the dismissal of her claims. She argued that, under FEHA, a prevailing defendant may only recover costs if the court expressly finds the action was frivolous, unreasonable, or groundless, as required by Government Code section 12965, subdivision (c)(6). The employer countered that the trial court’s judgment sufficiently implied such a finding, and that the plaintiff had waived her objections by not responding earlier. The Court of Appeal examined whether the trial court followed the proper procedure for awarding costs in FEHA cases.The Court of Appeal of the State of California, First Appellate District, Division Four, held that a prevailing defendant in a FEHA case cannot be awarded costs absent an express finding that the plaintiff’s action was frivolous, unreasonable, or groundless. The court found no such finding in the record, and determined that the trial court appeared to have applied the general rule for cost awards, not the heightened FEHA standard. Therefore, the appellate court reversed the amended judgment as to costs and remanded for further proceedings to determine whether the employer is entitled to costs under the correct legal standard. The plaintiff was awarded costs on appeal. View "San Diego-Tomas v. Aspire Bakeries, LLC" on Justia Law

A property management company in Los Angeles employed an individual from April 2023 to September 2024. As part of the hiring and onboarding process, the employee was required to sign an arbitration agreement that mandated all employment-related claims be resolved through binding arbitration and included a waiver of class and representative actions. The employee later filed a class action lawsuit against the employer, alleging wage-and-hour violations and unfair business practices.The employer responded by filing a motion in the Superior Court of Los Angeles County to compel arbitration of the employee's individual claims, dismiss the class claims, and stay the action. The employer made clear that the Federal Arbitration Act (FAA) did not apply and relied on California law. The employee opposed, arguing that under California Labor Code section 432.6, it is illegal for an employer to require an employee to sign an arbitration agreement as a condition of employment unless the agreement is enforceable under the FAA. The Superior Court denied the employer’s motion, finding that the arbitration agreement was required as a condition of employment, thus violating section 432.6, and that, since the FAA did not apply, the agreement was unenforceable under California law.On appeal, the Court of Appeal of the State of California, Second Appellate District, Division Four, affirmed the trial court’s order. The appellate court held that, under California law, an arbitration agreement required as a condition of employment in violation of section 432.6 is unenforceable unless it is otherwise enforceable under the FAA. Because the parties agreed the FAA did not apply and the agreement was required as a condition of employment, the employer could not enforce it. The court affirmed the denial of the motion to compel arbitration. View "Molina v. Triumph Residential Services, Inc." on Justia Law

Douglas Smith, a long-term high school science teacher, refused to comply with his employer’s COVID-19 vaccination mandate due to his religious beliefs. The Burbank Unified School District granted his request for a religious exemption but placed him on indefinite unpaid leave, stating that no other accommodation could be provided without undue hardship. Smith requested alternative accommodations such as masking and weekly PCR testing, but the District denied these, citing concerns about health and safety for staff and students. After a year on unpaid leave, Smith found employment at a school without a vaccine mandate and eventually resigned from the District.The Superior Court of Los Angeles County reviewed Smith’s claims under the Fair Employment and Housing Act (FEHA), which included religious discrimination, failure to prevent discrimination, and retaliation. The District moved for summary judgment, arguing that unpaid leave was the only reasonable accommodation that did not pose an undue hardship, given the nature of Smith’s teaching responsibilities and the operational impacts of allowing unvaccinated teachers on campus. The trial court found that Smith established a prima facie case for religious discrimination, but concluded the District met its burden in showing that alternative accommodations were not feasible, and thus granted summary judgment in favor of the District.The Court of Appeal of the State of California, Second Appellate District, Division Eight, independently reviewed the summary judgment. It held that, under FEHA, unpaid leave can be a reasonable accommodation where other options pose an undue hardship, especially given the District’s obligation to protect health and safety during the pandemic. The Court affirmed the trial court’s judgment, specifying that the parties would bear their own costs on appeal. View "Smith v. Burbank Unified School Dist." on Justia Law