Justia Civil Procedure Opinion Summaries

Samuel Murray, a motor-vehicle operator for the District of Columbia Department of Youth Rehabilitation Services (DYRS), was wrongfully terminated after taking leave due to an injury sustained at work. In September 2020, DYRS was ordered to reinstate Mr. Murray and awarded him back-pay with benefits. Mr. Murray did not initially request interest on the back-pay. In February 2021, he petitioned the Office of Employee Appeals (OEA) to reopen his case for enforcement of the back-pay and benefits, which had not yet been provided, and for the first time sought accrued interest on the back-pay.The OEA Administrative Judge (AJ) ruled that OEA had the authority to award interest on back-pay and ordered DYRS to pay Mr. Murray prejudgment interest. DYRS sought review in the Superior Court, which reversed the AJ's decision, holding that the AJ did not have jurisdiction to grant interest on the back-pay award. The Superior Court reasoned that the AJ's jurisdiction was limited to correcting the record, ruling on attorney fees, or processing enforcement petitions, and Mr. Murray's request for prejudgment interest fell outside these parameters.The District of Columbia Court of Appeals reviewed the case and affirmed the Superior Court's judgment. The court held that D.C. Code § 1-606.03(c) clearly precluded Mr. Murray's belated request for prejudgment interest, as it was made over three months after the back-pay award became final and did not fall within the AJ's limited post-award jurisdiction. The court also noted that it did not address whether OEA has the authority to award prejudgment interest when timely requested or whether post-judgment interest could be part of enforcing an award not promptly paid. View "Murray v. District of Columbia Dep't of Youth and Rehabilitation Services" on Justia Law

Kristin Casey, a former employee of D.R. Horton, Inc., filed a lawsuit against the company and one of its employees, Kris Hansen, alleging sexual harassment and other claims. D.R. Horton moved to compel arbitration based on an employment agreement that included an arbitration clause governed by California law. Casey opposed the motion, citing the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA), which allows plaintiffs to invalidate arbitration agreements in cases involving sexual harassment. The trial court granted the motion to compel arbitration, reasoning that the EFAA was inapplicable due to the choice-of-law provision in the employment agreement.The Contra Costa County Superior Court initially reviewed the case and granted the motion to compel arbitration, accepting Hansen's joinder. The court concluded that the choice-of-law provision in the employment agreement meant that California law, not the EFAA, applied. Casey then filed a petition for a writ of mandate to challenge this decision.The California Court of Appeal, First Appellate District, Division One, reviewed the case. The court held that the EFAA preempts state law attempts to compel arbitration in cases related to sexual harassment disputes. The court determined that the EFAA applies to the parties' transaction because it sufficiently involved interstate commerce. The court also concluded that the EFAA's rule of unenforceability of arbitration agreements in sexual harassment cases preempts the state law and that parties cannot contract around the EFAA through a choice-of-law provision. Consequently, the court granted Casey's petition and directed the trial court to vacate its order compelling arbitration and to enter a new order denying the motion. View "Casey v. Superior Court" on Justia Law

Prestige Home Care Agency, operated by Nursing Home Care Management Inc., did not compensate its employees for travel time between clients' homes. The U.S. Department of Labor (DOL) sued Prestige for this and other violations of the Fair Labor Standards Act (FLSA). The District Court found Prestige's actions to be willful violations of the FLSA and granted summary judgment in favor of the DOL. Prestige appealed the summary judgment, the exclusion of its expert witness, and the denial of its motion for sanctions against the DOL.The District Court for the Eastern District of Pennsylvania excluded Prestige’s expert witness, denied Prestige’s motion for sanctions, and granted summary judgment for the DOL on all claims. The court found that Prestige willfully violated the FLSA by not compensating for travel time, failing to pay for short breaks, improperly compensating overtime, and not keeping accurate records.The United States Court of Appeals for the Third Circuit reviewed the case. The court held that travel time between job sites during the workday is compensable under the FLSA. It affirmed the District Court’s finding that Prestige violated the FLSA’s recordkeeping requirements and acted willfully in its violations, extending the statute of limitations to three years. The court also upheld the District Court’s calculation of back wages and liquidated damages, finding the DOL’s estimates sufficient given Prestige’s inadequate records.The Third Circuit found no abuse of discretion in the District Court’s exclusion of Prestige’s expert witness, who made several legal errors in his report. The court also upheld the denial of sanctions against the DOL, as the documents in question were already in Prestige’s possession and had little impact on the case. The Third Circuit affirmed the District Court’s judgment in all respects. View "Secretary United States Department of Labor v. Nursing Home Care Management Inc." on Justia Law

Armando Guevara worked as a domestic service employee for Robert and Maria Zamora for over a decade, performing various tasks such as cleaning, car maintenance, and grocery shopping. Occasionally, he also provided services for the Zamoras' businesses, Lafise Corporation and Latin American Financial Services, Inc. (LAFS). Guevara was paid $1,365.88 biweekly, but there was no written employment agreement, and the parties disagreed on whether this amount represented a salary or an hourly wage. The Zamoras claimed they paid him an hourly rate with overtime, while Guevara asserted he was paid a salary without proper overtime compensation.Guevara filed a putative class action against the Zamoras, Lafise, and LAFS for unpaid overtime wages under the Fair Labor Standards Act (FLSA). The United States District Court for the Southern District of Florida granted summary judgment in favor of the defendants, finding that Guevara was not covered by the FLSA through either "enterprise coverage" or "individual coverage." The court also found that Guevara was fully compensated for all his overtime work hours based on the Zamoras' testimony and calculations.The United States Court of Appeals for the Eleventh Circuit reviewed the case and found that the district court erred in granting summary judgment. The appellate court determined that there was a genuine dispute regarding Guevara's regular hourly rate and, therefore, his overtime rate. The court noted that the Zamoras did not maintain accurate records, and the evidence presented created a genuine issue of fact that should be determined by a jury. The appellate court also vacated the district court's ruling on whether Lafise was a joint employer, as the lower court failed to provide sufficient reasoning and did not address the relevant factors. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Guevara v. Lafise Corp." on Justia Law

A national news reporter employed by a prominent newspaper sued her employer and six of its editors in Superior Court, alleging violations of the D.C. Human Rights Act and the common law tort of negligent infliction of emotional distress. She claimed that the defendants discriminated against her based on her status as a sexual assault victim and her gender, took adverse employment actions against her, subjected her to a hostile work environment, and retaliated against her for protesting their discriminatory actions.The defendants moved to dismiss the complaint under Superior Court Civil Rule 12(b)(6) for failure to state a claim and filed a special motion to dismiss under the D.C. Anti-SLAPP Act, arguing that the claims arose from acts in furtherance of the right of advocacy on issues of public interest. The Superior Court denied the special motion to dismiss, finding that the claims did not arise from speech protected by the Anti-SLAPP Act, but granted the Rule 12(b)(6) motion, concluding that the complaint failed to plausibly allege unlawful discrimination or retaliation.The District of Columbia Court of Appeals reviewed the case and affirmed the denial of the special motion to dismiss, agreeing that the Anti-SLAPP Act did not apply. The court reversed the dismissal of the counts alleging adverse action discrimination, finding that the complaint plausibly alleged that the defendants took certain adverse employment actions against the reporter in violation of the Human Rights Act. However, the court affirmed the dismissal of the hostile work environment and retaliation claims, concluding that the allegations did not meet the necessary legal standards. The court also noted that it was premature to decide whether the defendants' actions were protected by the First Amendment, leaving that issue open for further proceedings. View "Sonmez v. WP Company, LLC" on Justia Law

Rodney Martin worked for B.F. Goodrich Company from 1966 to 2012 and was exposed to vinyl chloride monomer until 1974. He was diagnosed with angiosarcoma of the liver in December 2019 and died in July 2020. His widow, Candice Martin, filed a civil action in November 2021, alleging that Rodney’s occupational exposure caused his illness and death. She invoked the exception in section 1.1 of the Workers’ Occupational Diseases Act to avoid its exclusivity provisions.PolyOne filed a motion to dismiss for lack of personal jurisdiction, and Goodrich filed a motion to dismiss under the exclusivity provisions, arguing that section 1.1 did not apply and that using it would infringe on their due process rights. The district court denied these motions and certified two questions for interlocutory appeal to the United States Court of Appeals for the Seventh Circuit, which then certified three related questions to the Illinois Supreme Court.The Illinois Supreme Court reviewed the case and answered the certified questions. The court held that section 1(f) of the Workers’ Occupational Diseases Act is a period of repose for purposes of section 1.1. The court also determined that section 1.1 applies prospectively under section 4 of the Statute on Statutes, meaning it applies to new actions filed after the amendment was enacted. Finally, the court found that applying section 1.1 prospectively does not violate Illinois’s due process guarantee, as defendants did not have a vested right in an exclusivity defense before the employee’s injury was discovered. View "Martin v. Goodrich Corp." on Justia Law

Plaintiffs, train dispatchers for Bombardier Mass Transit Corporation, filed claims for unpaid wages, alleging they were entitled to overtime wages and wage statement penalties for on-call time. Initially, they sought relief through the labor commissioner’s Berman hearing process, which was denied. Subsequently, they requested a de novo hearing in the San Diego Superior Court, where they prevailed, receiving over $140,000 in back wages and penalties. They then moved for attorney fees and costs, which the trial court granted, awarding $200,000.In the Superior Court of San Diego County, the plaintiffs' claims were initially denied by the labor commissioner. Upon seeking a de novo trial, the superior court ruled in favor of the plaintiffs, awarding them unpaid wages and penalties. The court also granted their motion for attorney fees and costs, amounting to $200,000, rejecting Bombardier’s argument that section 98.2, subdivision (c) was the exclusive statute for awarding attorney fees and costs in such cases.The Court of Appeal, Fourth Appellate District, Division One, State of California, reviewed the case. Bombardier contended that section 98.2, subdivision (c) should be the sole basis for awarding attorney fees and costs in a de novo trial following a Berman hearing. The appellate court disagreed, affirming the trial court’s decision. The court held that prevailing plaintiffs in superior court actions for unpaid wages are generally entitled to an award of reasonable fees and costs under sections 218.5, 226, and 1194, and nothing in section 98.2 suggests otherwise. The court emphasized that the Berman process is designed to benefit employees and should not restrict their remedies. Thus, the order awarding $200,000 in attorney fees and costs to the plaintiffs was affirmed. View "Villalva v. Bombardier Mass Transit Corp." on Justia Law

Regina M. Thornton was employed by Ipsen Biopharmaceuticals, Inc. as Associate Director - Patient Safety. In September 2021, Ipsen required employees to receive COVID-19 vaccinations. Thornton requested a religious exemption, which Ipsen denied. After she did not comply with the vaccination requirement, Ipsen terminated her employment. Thornton sued Ipsen in the Superior Court of Massachusetts, alleging violations of Title VII, Massachusetts law (Chapter 151B), the Fourteenth Amendment, and the Massachusetts Declaration of Rights (MDR). Ipsen removed the case to the United States District Court for the District of Massachusetts and moved to dismiss all counts. The Magistrate Judge granted Ipsen's motion, dismissing Thornton's complaint. Thornton appealed.The United States District Court for the District of Massachusetts dismissed Thornton's complaint, finding that she failed to state a plausible claim of religious discrimination under Title VII or Chapter 151B. The court concluded that Thornton did not adequately state her religious beliefs or how they related to vaccines. The court also found that Thornton's federal constitutional claims failed because Ipsen was not a state actor, and her MDR claims failed because the MDR does not provide a private right of action.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the Magistrate Judge's dismissal of Thornton's religious discrimination claims under Title VII and Chapter 151B, finding that she had plausibly alleged that her religious beliefs conflicted with the vaccination requirement. However, the court affirmed the dismissal of her federal constitutional claims, as the Fourteenth Amendment does not apply to private actors like Ipsen. The court also affirmed the dismissal of her MDR claims, noting that Thornton had waived any argument that her claim should be reimagined under the Massachusetts Civil Rights Act. View "Thornton v. Ipsen Biopharmaceuticals, Inc." on Justia Law

EMD Sales, Inc. distributes food products in the Washington, D.C. area and employs sales representatives who manage inventory and take orders at grocery stores. Several sales representatives sued EMD, alleging that the company violated the Fair Labor Standards Act (FLSA) by failing to pay them overtime. EMD argued that the sales representatives were outside salesmen and therefore exempt from the FLSA’s overtime-pay requirement.The U.S. District Court for the District of Maryland held a bench trial and found EMD liable for overtime pay because EMD did not prove by clear and convincing evidence that its sales representatives were outside salesmen. The court ordered EMD to pay overtime wages and liquidated damages. EMD appealed, arguing that the District Court should have used the preponderance-of-the-evidence standard instead of the clear-and-convincing-evidence standard. The U.S. Court of Appeals for the Fourth Circuit affirmed the District Court’s judgment, adhering to Circuit precedent that required employers to prove FLSA exemptions by clear and convincing evidence.The Supreme Court of the United States reviewed the case and held that the preponderance-of-the-evidence standard applies when an employer seeks to demonstrate that an employee is exempt from the minimum-wage and overtime-pay provisions of the FLSA. The Court reasoned that the FLSA does not specify a standard of proof for exemptions, and in the absence of such specification, the default preponderance standard should apply. The Court reversed the Fourth Circuit’s judgment and remanded the case for further proceedings consistent with this opinion. View "E.M.D. Sales, Inc. v. Carrera" on Justia Law

Michael Gifford, a beneficiary of the Operating Engineers 139 Health Benefit Fund, sought reimbursement for out-of-network medical expenses incurred during his treatment for a stroke and subsequent brain aneurysm surgery. The Fund denied the claim, stating the services were not provided in an emergency and were not medically necessary. Gifford's wife, Suzanne, appealed the decision, but the Fund upheld the denial after consulting two independent medical reviewers who concluded the surgery was not an emergency and not medically necessary.The United States District Court for the Eastern District of Wisconsin granted the Fund's motion for summary judgment, agreeing that the Fund's decision was not arbitrary and capricious. The court also granted the Fund's motion for a protective order, limiting discovery to the administrative record. The Estate of Michael Gifford, represented by Suzanne, appealed the decision, arguing that the Fund failed to conduct a full and fair review by not considering a surgical note from Dr. Ahuja, which was not included in the administrative record.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court held that the Fund's denial of benefits was not arbitrary and capricious, as the Fund reasonably relied on the independent medical reviewers' reports and the administrative record. The court also found that the Fund was not required to seek out additional information not provided by the claimant. Additionally, the court upheld the district court's grant of the protective order, finding no abuse of discretion in limiting discovery to the administrative record. The court concluded that the Fund provided a full and fair review of the claim, and the denial of benefits was reasonable. View "Estate of Gifford v Operating Engineers 139 Health Benefit Fund" on Justia Law