Justia Civil Procedure Opinion Summaries

LaTonya Jackson, a former patient services coordinator at Hennepin Healthcare System, Inc., was terminated in October 2022. She filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC) in May 2021, alleging race, age, and disability discrimination, as well as retaliation. The EEOC issued a right to sue letter on May 5, 2023. Jackson filed a complaint against Hennepin Healthcare on August 4, 2023, alleging violations of Title VII, the Americans with Disabilities Act (ADA), and the Age Discrimination in Employment Act (ADEA). She also initially sued a supervisor, Duang See, but later withdrew that claim.The United States District Court for the District of Minnesota dismissed Jackson's complaint as untimely. The court found that the complaint was filed one day past the ninety-day deadline following the issuance of the right to sue letter. Additionally, the court concluded that Jackson failed to state a claim and had not properly exhausted administrative remedies.The United States Court of Appeals for the Eighth Circuit reviewed the district court's decision de novo. The appellate court affirmed the district court's dismissal, agreeing that Jackson's complaint was filed on August 4, 2023, one day after the deadline. The court found no evidence to support Jackson's claim that a computer glitch caused the delay. The court also declined to apply the doctrine of equitable tolling, noting that Jackson had adequate notice of the deadline, was represented by counsel, and there was no misconduct by the defendant or misleading action by the court. The court emphasized that equitable tolling is reserved for circumstances beyond the plaintiff's control, which did not apply in this case. The judgment of the district court was affirmed. View "Jackson v. Hennepin Healthcare System, Inc." on Justia Law

A railroad worker, Phillip Morgan, committed suicide after experiencing months of alleged harassment by his supervisor at Union Pacific Railroad Company. His wife, Kera Morgan, acting as the administrator of his estate, filed a lawsuit under the Federal Employers’ Liability Act (FELA), seeking wrongful death damages. She claimed that the harassment and stress from his job led to Phillip's emotional distress and eventual suicide.The Iowa District Court for Polk County granted summary judgment in favor of Union Pacific, concluding that Phillip's injuries were emotional and not tied to a physical impact or near physical harm, thus falling outside the scope of FELA. The court held that FELA did not cover emotional injuries unless there was a physical impact or the worker was in imminent danger of physical harm.The Iowa Supreme Court reviewed the case and affirmed the district court's decision. The court held that under the precedent set by the United States Supreme Court in Consolidated Rail v. Gottshall, FELA incorporates common law limits on compensable injuries. The court concluded that Phillip's emotional injuries, which led to his suicide, did not meet the "zone of danger" test established in Gottshall. This test requires that the worker must have been in immediate risk of physical impact or harm to recover for emotional injuries under FELA. Since Phillip's injuries were purely emotional and not tied to any physical impact or imminent threat of physical harm, the court ruled that FELA did not provide coverage for his case. View "Estate of Morgan v. Union Pacific Railroad Company" on Justia Law

The case involves Leika Joanna García-Gesualdo, who filed an employment discrimination lawsuit against Honeywell Aerospace of Puerto Rico, Inc., and Honeywell International, Inc. García-Gesualdo alleged that Honeywell discriminated against her in violation of Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA). The EEOC investigated her claims but decided not to proceed further, issuing a right-to-sue letter on March 29, 2022. García-Gesualdo filed her lawsuit on July 7, 2022, 100 days after the EEOC's decision.The United States District Court for the District of Puerto Rico dismissed García-Gesualdo's claims as time-barred, agreeing with Honeywell that the complaint was filed more than ninety days after the EEOC issued the right-to-sue letter. The court noted that García-Gesualdo's attorney received emails from the EEOC on March 29 and April 6, indicating that a new document was available on the EEOC's portal. The district court concluded that the ninety-day period began on either March 29 or April 6, making the July 7 filing untimely.The United States Court of Appeals for the First Circuit reviewed the case and reversed the district court's dismissal. The appellate court held that neither the March 29 email nor the April 6 email provided sufficient notice of García-Gesualdo's right to sue. The court emphasized that the emails did not unambiguously indicate that the EEOC had terminated its processes or that the ninety-day period to file a lawsuit had begun. Therefore, the appellate court concluded that the facts establishing untimeliness were not clear on the face of the pleadings, and the case was remanded for further proceedings. View "Garcia-Gesualdo v. Honeywell Aerospace of Puerto Rico, Inc." on Justia Law

A former employee, Corbin Williams, worked as an insurance adjuster for Alacrity Solutions Group, LLC, from 2014 until January 2022. Williams typically worked 84-hour weeks but was not paid overtime, violating the Labor Code. In March 2023, over a year after his employment ended, Williams notified the California Labor & Workforce Development Agency of his intent to pursue a PAGA action for these violations. He then filed a lawsuit seeking civil penalties on behalf of other current and former employees but not on his own behalf.The Superior Court of Los Angeles County sustained a demurrer to Williams's complaint without leave to amend, finding the action time-barred. The court noted that Williams had not suffered any Labor Code violations within the one-year statute of limitations period before notifying the Agency, as his employment ended in January 2022. Consequently, the court did not address the defendant's alternative argument regarding Williams's standing.The California Court of Appeal, Second Appellate District, Division Five, affirmed the lower court's decision. The court held that to be a PAGA plaintiff, an individual must have a timely individual claim for at least one Labor Code violation. Since Williams's individual claims were time-barred, he could not satisfy this requirement. The court rejected Williams's arguments that other aggrieved employees' timely claims could substitute for his own untimely claims and that the continuous accrual doctrine applied. The court also found no abuse of discretion in denying leave to amend, as Williams's proposed amendments would not cure the timeliness defect. View "Williams v. Alacrity Solutions Grp." on Justia Law

Samuel Shanks and Taylor Lambert, former employees of the International Union of Bricklayers & Allied Craftworkers, filed pro se lawsuits against the Union alleging discrimination. Shanks, who worked in accounting for over twenty years, claimed discrimination based on disability, race, color, and sexual orientation, as well as a hostile work environment and retaliation. Lambert, his niece, alleged wrongful termination, retaliation, and discrimination based on race, religion, and gender. Both claimed violations of various civil rights laws, including the D.C. Human Rights Act, the Americans with Disabilities Act, and Title VII of the Civil Rights Act of 1964.The Union removed the cases to the United States District Court for the District of Columbia, which dismissed the complaints for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). Shanks and Lambert appealed the dismissals. The United States Court of Appeals for the District of Columbia Circuit affirmed the dismissals in part but appointed amicus curiae to present arguments in favor of claims that were not suited for summary dismissal.The D.C. Circuit reviewed the district court’s dismissal de novo and concluded that the allegations of racial discrimination related to the Union’s COVID-19 vaccination policy were plausible. The court found that the Union’s two-stage roll-out of the policy disproportionately affected Black employees, who were given less time and fewer resources to comply with the vaccination mandate. The court held that the disparate impact and discriminatory treatment claims based on race were sufficiently pled to survive a motion to dismiss. The court affirmed the dismissal of other claims, including those based on sexual orientation, gender, and religion, as well as Shanks’ hostile work environment claim. The case was remanded to the district court for further proceedings on the racial discrimination claims. View "Shanks v. International Union of Bricklayers and Allied Craftworkers" on Justia Law

Two former employees sued Zen Nails Studio LLC and its owners for violating the Fair Labor Standards Act (FLSA) and a similar Maryland state law. After a five-day bench trial, the plaintiffs won and were awarded approximately 60% of their requested damages. The plaintiffs then sought $343,189.85 in attorney’s fees, but the district court awarded them $167,115.49, which was less than half of what they requested. The plaintiffs appealed the district court’s decision regarding the hourly rates used to calculate the attorney’s fees.The United States District Court for the District of Maryland, at Greenbelt, initially reviewed the case. The district court set the hourly rates for the plaintiffs’ attorneys, paralegals, and paraprofessionals based on the local rules' guidelines, which it treated as presumptively reasonable. The court then calculated the hours reasonably worked and reduced the total by 35% due to the plaintiffs achieving a moderately successful outcome. The plaintiffs challenged the district court’s reliance on the local rules' guidelines for setting the hourly rates.The United States Court of Appeals for the Fourth Circuit reviewed the case. The appellate court held that the district court erred by treating the hourly rates in the local rules as presumptively correct and requiring special justification for higher rates. The Fourth Circuit emphasized that while fee matrices can be a useful starting point, they should not be treated as setting a baseline that requires special justification to deviate from. The appellate court vacated the fee award and remanded the case for further proceedings, instructing the district court to consider all relevant evidence to determine the prevailing market rates without giving undue weight to the local rules' guidelines. View "De Paredes v. Zen Nails Studio LLC" on Justia Law

Scott Hampe was employed by Charles Gabus Motors, Inc. (Gabus) from 2008 until December 2019. Gabus conducted an unannounced drug test on December 5, 2019, assisted by Mid-Iowa Occupational Testing (Mid-Iowa). Hampe was selected as an alternate for testing and was ultimately tested. During the test, Hampe provided two insufficient urine samples and decided to leave the testing area to care for his sick child, despite being warned by his manager that leaving would result in termination. Hampe was subsequently fired.Hampe filed a lawsuit against Gabus and Mid-Iowa in May 2020, alleging violations of Iowa Code section 730.5, which governs employer drug testing, and asserting common law claims. The Iowa District Court for Polk County granted summary judgment in favor of Gabus and Mid-Iowa, dismissing all of Hampe’s claims. Hampe appealed, and the Iowa Court of Appeals affirmed the dismissal of claims against Mid-Iowa and most claims against Gabus but reversed the dismissal of claims related to testing pool requirements, supervisor training, and uniform disciplinary policy, finding genuine issues of material fact.The Iowa Supreme Court reviewed the case and focused on Hampe’s claim that Gabus violated section 730.5’s requirements for the composition of testing pools. The court concluded that Gabus failed to substantially comply with the statutory requirements for the testing pool, as the pool included employees who were not scheduled to work at the time of testing. The court also found that Hampe was aggrieved by this failure, as his selection for testing and subsequent termination were based on a non-compliant process. The court reversed the district court’s judgment in part, affirmed it in part, and remanded the case for further proceedings to determine the appropriate relief for Hampe. The court also deemed Hampe’s claims concerning supervisor training and uniform disciplinary policy moot in light of the resolution of the pooling claim. View "Hampe v. Charles Gabus Motors, Inc." on Justia Law

Jan Kuklenski was terminated by Medtronic USA, Inc. and subsequently filed a lawsuit in federal court, claiming that her termination violated the Minnesota Human Rights Act (MHRA) due to her disability. Kuklenski had worked for Medtronic since 1999 but had not resided in Minnesota. She occasionally traveled to Minnesota for work until the COVID-19 pandemic, after which she worked remotely. She went on medical leave in June 2021, and after her initial three-month leave expired, Medtronic filled her position and formally terminated her in December 2021.The United States District Court for the District of Minnesota granted summary judgment in favor of Medtronic, concluding that Kuklenski could not bring claims under the MHRA because she did not meet the statutory definition of an “employee,” which requires either residency or physical presence in Minnesota. The court found that Kuklenski had not been physically present in Minnesota for almost two years before her termination.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. The court affirmed the district court’s grant of summary judgment, agreeing that the MHRA’s definition of “employee” requires some degree of physical presence in Minnesota. The court found that the statutory language was clear and unambiguous, requiring that an individual must either reside or work within the physical limits of Minnesota to be protected under the MHRA. The court also denied Kuklenski’s request to certify the question to the Minnesota Supreme Court, noting that the case did not present a close question of state law and that certification was not appropriate given the circumstances.The Eighth Circuit held that the MHRA’s definition of “employee” necessitates physical presence in Minnesota, and since Kuklenski had not been physically present in the state for nearly two years, she did not qualify as an employee under the Act. View "Kuklenski v. Medtronic USA, Inc." on Justia Law

Natasha Knox, a Black woman of Jamaican descent, worked as a customer service attendant at three Clean Rite laundromats in the Bronx from December 2018 until her termination in April 2019. She alleged that her supervisors, Cecilia Ashmeade and Kenneth Ferris, made derogatory comments about her race and national origin, and that Clean Rite failed to accommodate her disability following a thumb injury. Knox also claimed she was not paid for extra shifts worked at other locations and was wrongfully terminated after reimbursing herself for taxi fare from the cash register, which she claimed was permitted.The United States District Court for the Southern District of New York granted summary judgment in favor of Clean Rite, dismissing Knox’s claims of discriminatory and retaliatory termination, hostile work environment, refusal to accommodate her disability, and unpaid wages. The district court found that Knox had not provided sufficient evidence to support her claims. Knox’s motion to strike the defendants’ answer and request for default judgment against Ashmeade and Ferris, who had failed to appear, was denied as moot.The United States Court of Appeals for the Second Circuit reviewed the case de novo and found that Knox had presented sufficient evidence to survive summary judgment on all her claims. The court noted that evidence such as Knox’s testimony and sworn affidavit could lead a reasonable jury to find in her favor. The court vacated the district court’s judgment and remanded the case for further proceedings on each of Knox’s claims. The claims against Ashmeade and Ferris were reinstated for the district court to reconsider Knox’s motion to strike their answer and for default judgment. View "Knox v. CRC Management Co." on Justia Law

Sharon Lewis, a former employee of Louisiana State University (LSU) football department, reported sexual harassment by former head football coach Les Miles and assistant coach Frank Wilson. She claimed retaliation for these reports, including exclusion from meetings, restructuring of her position, and eventual termination in 2022. Lewis filed a lawsuit under Titles IX and VII against the LSU Board of Supervisors, alleging retaliation and hostile work environment.The United States District Court for the Middle District of Louisiana held a six-day trial, after which the jury found in favor of the Board on all claims. The district court entered judgment accordingly. Lewis filed a renewed motion for judgment as a matter of law or, alternatively, for a new trial, which the district court denied. Lewis then appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the district court’s judgment and denial of Lewis’s motions. The appellate court found that the jury had a legally sufficient evidentiary basis to conclude that Lewis’s termination was part of a broader restructuring initiative by new head coach Brian Kelly, rather than retaliation for her Title IX and Title VII complaints. The court noted that Kelly and other key decision-makers were unaware of Lewis’s prior complaints at the time of her termination. The court also found no abuse of discretion in the district court’s denial of a new trial, as the jury’s verdict was supported by the evidence presented. View "Lewis v. Board of Supervisors of Louisiana State University" on Justia Law