Justia Civil Procedure Opinion Summaries

Andrew Sangster, on behalf of a class of flight instructors, filed suit against the University of North Dakota alleging that instructors were not paid for all hours worked. Sangster claimed the university compensated instructors only for student contact hours and excluded other work-related tasks such as scheduling, pre- and post-flight procedures, recordkeeping, and waiting at the airport. He sought damages for violations of the Fair Labor Standards Act (FLSA), North Dakota wage laws, unjust enrichment, and conversion.The District Court for Cass County reviewed the university’s motion to dismiss, which argued the court lacked jurisdiction because Sangster failed to give timely notice to the Office of Management and Budget as required by North Dakota law. Sangster admitted he had not provided this notice but contended his claims were contractual and thus exempt from the notice requirement. The district court denied the motion to dismiss with respect to the FLSA, state wage law, and unjust enrichment claims, finding them contractual in nature. The conversion claim was dismissed because Sangster conceded the notice requirement applied.The Supreme Court of the State of North Dakota subsequently reviewed the district court’s decision upon the University’s petition for a supervisory writ. The Supreme Court exercised its discretionary supervisory jurisdiction, holding that Sangster’s claims for relief under the FLSA, North Dakota wage laws, and unjust enrichment were not contractual in nature and therefore not authorized by N.D.C.C. ch. 32-12. The Supreme Court concluded that because Sangster had not complied with the statutory notice requirements for noncontractual claims, the district court lacked subject matter jurisdiction. The court granted the supervisory writ and directed the district court to dismiss Sangster’s case for lack of jurisdiction. View "UND v. Whelan" on Justia Law

An employee of a New York City tour company was terminated in 2012, allegedly for attempting to unionize. The National Labor Relations Board (NLRB) began investigating the termination, and in 2013, its adjudicative body found the discharge violated the National Labor Relations Act (NLRA), ordering the company to reinstate the employee and compensate him for lost earnings. After a brief reinstatement and a second termination, further proceedings led to a backpay judgment against the company and several affiliates, including some of the current appellants. When the judgment debtors failed to pay, the NLRB issued administrative subpoenas seeking documents to determine whether the appellants could be held liable for the judgment. The appellants did not comply with these subpoenas.The United States District Court for the Southern District of New York reviewed the NLRB’s application to enforce the subpoenas. The court rejected the appellants’ arguments concerning lack of subject-matter jurisdiction, personal jurisdiction, and improper venue, holding that the NLRA authorized nationwide service of process and that the inquiry was conducted in the Southern District of New York. The court denied the appellants’ motion to transfer the case to the Southern District of Texas and awarded attorneys’ fees and costs to the NLRB, later specifying the amount.The United States Court of Appeals for the Second Circuit found that the district court had subject-matter and personal jurisdiction to enforce the subpoenas, and that venue was proper. It held that the district court did not abuse its discretion by refusing to transfer the case or by awarding fees and costs based on the appellants’ repeated evasion of service and failure to comply. However, the appellate court lacked jurisdiction to review the district court’s subsequent order fixing the amount of fees and costs, as no timely notice of appeal was filed for that order. The judgment was thus affirmed in part and dismissed in part. View "Nat'l Lab. Rels. Bd. v. Universal Smart Conts., LLC" on Justia Law

The plaintiff brought claims against her former employer alleging violations of federal and state wage and hour laws. After removal to the United States District Court for the District of Rhode Island, some claims were resolved at summary judgment, leaving the federal wage claims for trial. Before trial, the parties participated in a court-ordered mediation before a magistrate judge, during which they reached an oral settlement agreement whose terms were recited on the record. The agreement included payment to the plaintiff, confidentiality, non-defamation, and no-rehire clauses, as well as dismissal of the action with prejudice. Both parties, including the plaintiff and her counsel, confirmed their assent to the agreement.Following the mediation, the defendant prepared written settlement documents and a stipulation of dismissal. However, the plaintiff refused to sign, asserting she felt pressured and that certain terms were ambiguous or not sufficiently definite. The district court reviewed these objections after the defendant moved to enforce the settlement. The court found the agreement enforceable, denied the plaintiff’s request for an evidentiary hearing on alleged undue influence due to lack of factual support, and ordered her to execute the documents. After the plaintiff failed to comply, the court ultimately dismissed the case with prejudice under Federal Rule of Civil Procedure 41(b).On appeal, the United States Court of Appeals for the First Circuit held that the district court did not err in enforcing the oral settlement agreement or in denying the plaintiff’s motion for reconsideration and request for an evidentiary hearing. The appellate court found no genuine dispute of material fact as to the existence or terms of the settlement and affirmed the district court’s judgment, awarding costs and attorney fees to the defendant. View "Maccarone v. Siemens Industry, Inc." on Justia Law

A tenured teacher employed by a city was charged with a criminal offense, resulting in his placement on paid administrative leave. Over a year later, while the charge was still pending, the city changed the teacher's status to unpaid suspension. The teacher’s union filed a grievance contesting the unpaid suspension, leading to arbitration, where the arbitrator determined that the city had good and just cause for the suspension without pay. After the criminal charge was dismissed, the city reinstated the teacher. The union then filed a second grievance seeking back pay for the period of unpaid suspension, which both parties agreed to arbitrate.Following this, while the arbitration on the back-pay grievance was still pending, the teacher independently filed an action for declaratory relief in the Providence County Superior Court, seeking a declaration that he was entitled to back pay under the Teachers’ Tenure Act. The city moved to dismiss, arguing that the teacher had already selected the grievance and arbitration process as his remedy. The trial justice granted the motion, citing the election of remedies doctrine and relying on precedent, specifically Martone v. Johnston School Committee, which precludes pursuing multiple remedies for the same dispute when a party has already elected a process under a collective bargaining agreement.The Supreme Court of Rhode Island reviewed the case and affirmed the Superior Court’s dismissal. The Court held that once a party elects to pursue a remedy through the grievance and arbitration procedures in a collective bargaining agreement, they are foreclosed from simultaneously or subsequently seeking judicial relief for the same dispute under the doctrine of election of remedies. The disposition by the Supreme Court of Rhode Island was to affirm the lower court’s judgment. View "Peasley v. City of Providence" on Justia Law

A public employee working for the Pennsylvania Department of Human Services alleged that the union representing her bargaining unit failed to fairly represent her during a workplace grievance process. After being temporarily reassigned during a purported investigation, she lost opportunities for overtime work. She requested the union file a grievance, but claimed the union delayed providing information and failed to adequately pursue her complaint. When she followed up, union officials allegedly made derogatory remarks about her non-membership status and admitted to providing minimal representation. By the time she received notice of the grievance resolution, the period to appeal had expired, and she was dissatisfied with the outcome, believing she was denied proper relief under the collective bargaining agreement.The employee filed suit in the Cambria County Court of Common Pleas against the union, seeking compensatory and punitive damages for breach of the duty of fair representation, but did not request an order for arbitration or join her employer as a party. The trial court granted the union’s preliminary objections and dismissed the complaint with prejudice, finding the claim for damages legally insufficient. On appeal, the Commonwealth Court reversed and remanded, holding it was not free from doubt that the employee could seek damages against the union for such a breach.The Supreme Court of Pennsylvania reviewed the case and held that, under the Public Employe Relations Act (PERA), when a public employee’s claim against a union arises from the union’s handling of a grievance, the employee’s remedy is limited to a court order compelling the union and the employer to arbitrate the grievance nunc pro tunc. Damages against the union are not available in this context, and the public employer is an indispensable party to such proceedings. The Supreme Court reversed the Commonwealth Court’s decision. View "Gustafson v. American Fed. of State" on Justia Law

The plaintiff, a former employee of California State University, Chico, filed suit against her prior employer and other parties alleging employment discrimination, whistleblower retaliation, and wrongful termination. She initiated the lawsuit on April 19, 2019. Under Code of Civil Procedure section 583.310, as extended by Judicial Council emergency rule 10 due to the COVID-19 pandemic, she was required to bring her case to trial by October 19, 2024. However, at a case management conference in March 2024, the trial court scheduled the trial for February 3, 2025, a date beyond the statutory deadline.After the trial date was set, the defendants moved to dismiss the case for failure to bring it to trial within the statutory period. They argued that no exception to the deadline applied, specifically contesting the existence of any oral agreement to extend the deadline. The plaintiff opposed dismissal, asserting that both parties had verbally agreed in open court to the February 2025 trial date, and that this agreement was recorded in the minute order. However, the minute order only documented the setting of the trial and related conferences, and contained no indication of any oral stipulation or agreement. The Superior Court of Butte County found that the plaintiff had not demonstrated a valid oral agreement to extend the deadline under section 583.330, subdivision (b), and granted the motion to dismiss with prejudice.On appeal, the California Court of Appeal, Third Appellate District, reviewed the trial court’s decision under the abuse of discretion standard, and interpreted the statute de novo. The appellate court held that an oral agreement to extend the statutory trial deadline under section 583.330, subdivision (b), must be reflected in the court’s minutes or a transcript. Because the record did not include any such evidence, the exception did not apply. The court affirmed the judgment of dismissal and awarded costs to the defendants. View "Randolph v. Trustees of the Cal. State University" on Justia Law

Employees of a property management company reported to the Minnesota Attorney General that their employer had failed to pay legally required wages and overtime, allegedly using subsidiaries to evade wage laws. Acting on these complaints, the Attorney General issued a civil investigative demand (CID) to the company and its subsidiaries in October 2019, seeking documents relevant to wage practices. The company challenged the CID in court, resulting in over three years of litigation before it ultimately provided the requested documents in July 2022. Following the conclusion of the CID litigation, the Attorney General filed a civil enforcement action in June 2023, alleging violations of the Minnesota Fair Labor Standards Act (MFLSA) related to wage theft.The Ramsey County District Court granted the company’s motion to dismiss the MFLSA claim under Minnesota Rule of Civil Procedure 12.02(e), finding the claim was barred by the two-year statute of limitations set forth in Minn. Stat. § 541.07(5). The court determined the claim accrued by late 2019, when the employees first came forward. The Minnesota Court of Appeals affirmed, rejecting the Attorney General’s argument that litigation over the CID should toll the limitations period, and citing a lack of precedent for such tolling.On review, the Minnesota Supreme Court held that litigation over a civil investigative demand issued under Minn. Stat. § 8.31 tolls the statute of limitations for a subsequent civil enforcement action, provided the CID and the enforcement action concern the same alleged unlawful practice. The Supreme Court reversed the dismissal of the MFLSA claim and remanded the case to the district court for further proceedings, establishing a narrow rule that tolling applies specifically during CID litigation under the Attorney General’s investigative authority. View "State of Minnesota v. Madison Equities, Inc." on Justia Law

Plaintiff was employed by defendant and, as a condition of employment, electronically signed both an offer letter containing an arbitration provision and a separate nondisclosure agreement (NDIAA) on the same day. The offer letter required arbitration for most employment-related disputes, while the NDIAA included terms such as a waiver of bond for injunctive relief and a heightened burden of proof for public domain information. Plaintiff’s employment ended in March 2023, after which she sued defendant in Alameda County Superior Court for disability discrimination, retaliation, and related claims under California’s Fair Employment and Housing Act, as well as wrongful termination. None of her claims involved confidential information or sought injunctive relief.Defendant moved to compel arbitration, asserting the Federal Arbitration Act (FAA) governed and that plaintiff’s claims fell within the arbitration agreement’s scope. The trial court found the arbitration agreement and NDIAA should be read together under California Civil Code section 1642, determined that certain NDIAA provisions were unconscionable, and concluded that unconscionability permeated the arbitration agreement. The court declined to sever the NDIAA’s unconscionable provisions and denied the motion to compel arbitration.On appeal, the California Court of Appeal, First Appellate District, Division Five, disagreed with the trial court’s refusal to sever. The appellate court held that the FAA does not preempt section 1642, and even assuming the NDIAA’s challenged provisions were unconscionable and properly considered alongside the arbitration agreement, those provisions were collateral to the arbitration agreement’s central purpose and did not affect the claims at issue. Applying Ramirez v. Charter Communications, Inc., the appellate court determined that the unconscionable terms should have been severed and the arbitration agreement enforced. Consequently, the order denying arbitration was reversed. View "Wise v. Tesla Motors, Inc." on Justia Law

A public hospital in New York contracted with a new parking management company to provide valet services, replacing a previous vendor whose employees were represented by a union and were covered by a collective bargaining agreement (CBA). After winning the contract, the new company considered retaining the existing unionized valet attendants but ultimately did not hire any of them, despite initially recruiting them. Instead, the company posted job listings for the same roles and hired other workers, leaving the former unionized employees without jobs. Evidence suggested that the new company’s refusal to hire was motivated by the employees’ union affiliation.After the union filed an unfair labor practice charge, the Regional Director of the National Labor Relations Board (NLRB) filed a petition with the United States District Court for the Eastern District of New York, seeking a temporary injunction under § 10(j) of the National Labor Relations Act. The requested injunction would have required the company to reinstate the discharged employees, recognize the union, and bargain in good faith. The district court denied the petition in a brief text order, finding no cognizable irreparable harm and noting the delay in seeking relief. Meanwhile, an Administrative Law Judge found that the company violated the Act by refusing to hire the unionized employees and failing to recognize and bargain with the union.The United States Court of Appeals for the Second Circuit reviewed the district court’s denial. The Second Circuit held that the district court’s order violated Rule 52(a)(2) by failing to provide adequate findings and conclusions. The Second Circuit further found that the Regional Director had met all four prongs required for a § 10(j) injunction: likelihood of success on the merits, irreparable harm, balance of equities, and public interest. The court reversed the district court’s order and remanded for entry of the requested injunction. View "Poor v. Parking Systems Plus, Inc." on Justia Law

Two individuals worked as delivery drivers for a transportation company for over a decade, primarily out of the company’s New Jersey terminal. Their work mainly involved picking up and delivering goods in New Jersey, with occasional deliveries in neighboring states. Each driver had a contract with the company that included a forum-selection clause requiring any disputes to be litigated in Memphis, Tennessee, and a choice-of-law clause providing that Tennessee law would govern any disputes. The company is incorporated in Delaware, headquartered in Illinois, and has operations nationwide, including in Tennessee, but neither the drivers nor the company’s relevant activities were based in Tennessee.The drivers filed a putative class action in the United States District Court for the District of New Jersey, alleging that the company violated New Jersey wage laws by withholding earnings and failing to pay overtime, among other claims. The case was transferred to the United States District Court for the Western District of Tennessee pursuant to the forum-selection clause. The company then moved to dismiss the complaint, arguing that the Tennessee choice-of-law provision applied and that Tennessee law did not recognize the claims brought under New Jersey statutes. The district court agreed, upheld the choice-of-law provision, and dismissed the case.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the enforceability of the choice-of-law provision under Tennessee’s choice-of-law rules. The court held that the contractual choice-of-law clause was unenforceable because there was no material connection between Tennessee and the transactions or parties. As a result, the Sixth Circuit reversed the district court’s dismissal and remanded the case for further proceedings. The court did not reach the question of whether Tennessee law was contrary to the fundamental policies of New Jersey. View "Andujar v. Hub Group Trucking, Inc." on Justia Law