Justia Civil Procedure Opinion Summaries

Daniel’la Deering, an in-house lawyer for Lockheed Martin, was terminated and subsequently sued the company for discrimination and retaliation. While her discrimination claim was dismissed at the summary judgment stage, her retaliation claim was set to go to trial. However, during the litigation, Deering misled Lockheed Martin and the district court about her employment status and income. She falsely claimed to be employed by nVent and did not disclose her higher-paying job elsewhere, even submitting false information in a deposition, declaration, and settlement letters.The United States District Court for the District of Minnesota, presided over by Judge David S. Doty, found that Deering’s actions constituted intentional, willful, and bad-faith misconduct. Lockheed Martin discovered the deception shortly before the trial, leading to an emergency motion for sanctions. The district court dismissed Deering’s case with prejudice and awarded Lockheed Martin $93,193 in attorney fees. Deering’s motions for a continuance and reconsideration were also denied by the district court.The United States Court of Appeals for the Eighth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that the district court did not abuse its discretion in dismissing the case due to Deering’s prolonged and intentional deception. The court emphasized that dismissal was appropriate given the severity and duration of the misconduct. Additionally, the appellate court found no abuse of discretion in the district court’s denial of Deering’s motions for a continuance and reconsideration. However, the appellate court dismissed Deering’s appeal regarding the attorney fee award due to a premature notice of appeal. View "Deering v. Lockheed Martin Corp." on Justia Law

A former chauffeur, Hyunhuy Nam, filed a lawsuit against the Permanent Mission of the Republic of Korea to the United Nations, alleging violations of federal, state, and city wage-and-hour and anti-discrimination laws. Nam, a South Korean citizen and U.S. permanent resident, was employed by the Mission as a chauffeur. His duties included driving high-level officials, adhering to diplomatic protocols, and maintaining confidentiality of classified information. Nam was required to undergo a high-level security clearance and sign annual confidentiality agreements. He was eventually terminated at age 61, after his contract was extended due to his wife's job loss during the pandemic.The United States District Court for the Southern District of New York denied the Mission's motion to dismiss, holding that Nam's employment fell within the "commercial activity" exception to the Foreign Sovereign Immunities Act (FSIA). The court later granted Nam's motion for partial summary judgment, awarding him damages and interest on his wage-and-hour claims, while the remaining claims were set for trial. The Mission appealed, arguing that it was immune under the FSIA.The United States Court of Appeals for the Second Circuit vacated the district court's decision and remanded the case for further proceedings. The appellate court held that the district court erred in granting summary judgment to Nam without resolving factual disputes regarding the nature of his employment. The court emphasized that the district court should have considered whether Nam's employment was governmental or commercial in nature, taking into account the context of his duties and the security measures involved. The appellate court instructed the district court to weigh the evidence, resolve conflicts, and, if necessary, conduct an evidentiary hearing to determine the applicability of the FSIA's commercial activity exception. View "Nam v. Permanent Mission of the Republic of Korea to the United" on Justia Law

In this case, Denise Kemp, a manager at Regeneron Pharmaceuticals, Inc., worked remotely in June 2016 to care for her child with a serious medical condition. Regeneron then restricted her remote work to one day per week and required her to use intermittent leave under the Family and Medical Leave Act (FMLA) for additional time away. Kemp sued Regeneron, alleging interference with her FMLA rights, and discrimination, retaliation, and constructive discharge under the New York State Human Rights Law (NYSHRL).The United States District Court for the Southern District of New York dismissed Kemp’s FMLA claim, reasoning that Regeneron had not denied her FMLA benefits and that the claim was time-barred. The court also dismissed her NYSHRL claims on the merits.The United States Court of Appeals for the Second Circuit reviewed the case. The court held that an employer can violate the FMLA by interfering with an employee’s use of FMLA benefits, even if the benefits are ultimately granted. However, the court affirmed the dismissal of Kemp’s FMLA claim as time-barred, finding no evidence of a willful violation by Regeneron to extend the statute of limitations. The court also affirmed the dismissal of Kemp’s NYSHRL claims for discrimination and retaliation as time-barred, noting that Kemp was informed of the adverse actions before the relevant date. Lastly, the court upheld the dismissal of Kemp’s constructive discharge claim, concluding that her working conditions were not intolerable enough to compel resignation.The Second Circuit affirmed the District Court’s judgment, dismissing all of Kemp’s claims. View "Kemp v. Regeneron Pharm., Inc." on Justia Law

Caitlin Julia Weathers, a white woman, was hired by Houston Methodist Hospital as a Patient Transporter in May 2019 and later became a Patient Care Assistant in June 2021. She reported racial harassment and discrimination by her co-workers to her supervisor, Sunila Ali, and Human Resources (HR). HR investigated but found no evidence supporting her claims and instead received negative feedback about her performance. Weathers was placed on a performance improvement plan (PIP) and was eventually terminated on October 4, 2021, for allegedly failing to meet the PIP's expectations. Weathers claimed her termination was retaliatory.Weathers filed an online inquiry with the EEOC on February 11, 2022, but faced difficulties scheduling an interview due to the EEOC's unavailability. After several delays and cancellations, she finally had an interview on August 1, 2022, and filed her charge of discrimination on August 3, 2022, 303 days after her termination. The EEOC issued a Right to Sue letter on August 11, 2022. Weathers then sued Methodist and Ali for discrimination and retaliation under Title VII. The district court dismissed her claims against Ali, citing that employees are not personally liable under Title VII, and dismissed her claims against Methodist as time-barred for not filing within the 300-day deadline.The United States Court of Appeals for the Fifth Circuit reviewed the case. The court affirmed the dismissal of claims against Ali but found that the district court erred in not applying equitable tolling to Weathers's claims against Methodist. The court noted that the delays were partly due to the EEOC's actions and that Weathers had diligently pursued her claim. The court vacated the district court's judgment for Methodist and remanded the case for further proceedings, allowing Weathers's claims to proceed. View "Weathers v. Houston Methodist Hospital" on Justia Law

Employees of Smith International, Inc. filed a claim for unpaid overtime wages under the Fair Labor Standards Act (FLSA). The employees, known as reamers, supervised the use of Smith’s underreaming tool on offshore drilling rigs. They were paid an annual salary plus daily-rate job bonuses, with their total annual compensation exceeding $100,000. The employees argued that they were misclassified as exempt from overtime requirements and sought to recover unpaid overtime wages, liquidated damages, and attorney fees.The United States District Court for the Western District of Louisiana conditionally certified the action as a collective action. Later, the claims of some plaintiffs were severed into separate individual actions, while others continued as a collective action. The district court consolidated the five proceedings for all purposes except for trial. After discovery, both parties filed cross motions for summary judgment. The district court granted Smith’s motion for summary judgment, finding that the employees were exempt from the FLSA’s overtime pay guarantee as bona fide executives. The employees appealed the decision.The United States Court of Appeals for the Fifth Circuit reviewed the case de novo. The court held that each employee met the criteria for the bona fide executive exemption under the FLSA. Specifically, the employees satisfied the salary basis test, the salary level test, and the job duties test. The court found that the employees were paid a guaranteed annual salary, which was not subject to reduction based on the quality or quantity of work performed, and that the additional daily-rate compensation did not defeat their qualification for the exemption. The court affirmed the district court’s grant of summary judgment in favor of Smith International, Inc. View "Venable v. Smith International" on Justia Law

Andrew Morgan, a millwright laborer, was employed by Allison Crane & Rigging LLC until his termination on November 18, 2020. Morgan injured his lower back on September 29, 2020, and was diagnosed with a bulged or herniated disc by a chiropractor. He was placed on light duty and given restrictions on bending and lifting. Despite these accommodations, Morgan was terminated, allegedly for failing to follow company policies and not showing up for work on November 17, 2020. Morgan filed a lawsuit claiming disability-based discrimination, retaliation, and failure to accommodate under the ADA and PHRA, as well as wrongful discharge under Pennsylvania common law.The United States District Court for the Middle District of Pennsylvania granted summary judgment in favor of Allison Crane. The court held that Morgan did not establish an actual or perceived disability under the ADA and PHRA, as his testimony about the chiropractor's diagnosis was inadmissible hearsay and he failed to provide necessary medical evidence. The court also found that Morgan's back pain was transitory and minor, thus not qualifying as a disability. Additionally, the court dismissed Morgan's wrongful discharge claim for lack of prima facie evidence of protected activity.The United States Court of Appeals for the Third Circuit reviewed the case and found that the District Court applied an incorrect legal standard. The Third Circuit clarified that under the ADA Amendments Act of 2008, temporary impairments can qualify as disabilities if they substantially limit major life activities. The court reversed the District Court's dismissal of Morgan's back pain-based discrimination claims, vacated the dismissal of his retaliation and failure to accommodate claims, and affirmed the dismissal of his wrongful discharge claim. The case was remanded for further proceedings consistent with the Third Circuit's opinion. View "Morgan v. Allison Crane & Rigging LLC" on Justia Law

A group of Union Pacific Railroad Company employees filed a class action lawsuit against the company, alleging that its fitness-for-duty program violated the Americans with Disabilities Act (ADA). Todd DeGeer, believing he was part of this class, filed an Equal Employment Opportunity Commission (EEOC) charge and an individual lawsuit after the class was decertified. DeGeer argued that his claims were tolled under the American Pipe & Construction Co. v. Utah doctrine. The district court dismissed his claims as untimely, finding that DeGeer was not a member of the narrowly defined class.The United States District Court for the District of Nebraska initially certified a class that included Union Pacific employees subjected to fitness-for-duty evaluations due to a reportable health event. DeGeer was on a list of employees provided by Union Pacific and submitted a declaration supporting the plaintiffs' certification motion. However, the class definition was later narrowed, and the district court certified the class under this new definition. The Eighth Circuit Court of Appeals later reversed the class certification, leading DeGeer to file his individual claims.The United States Court of Appeals for the Eighth Circuit reviewed the case and reversed the district court's decision. The Eighth Circuit held that DeGeer was entitled to American Pipe tolling because the revised class definition did not unambiguously exclude him. The court emphasized that ambiguities in class definitions should be resolved in favor of applying tolling. Consequently, DeGeer's claims were tolled during the pendency of the class action, making his individual lawsuit timely. The case was remanded for further proceedings. View "DeGeer v. Union Pacific Railroad Co." on Justia Law

The case involves a long-standing employment discrimination dispute between a well-known columnist, T.J. Simers, and his former employer, Los Angeles Times Communications LLC. Simers was demoted in 2013 and subsequently filed a lawsuit alleging constructive termination and age and disability discrimination under the Fair Employment and Housing Act (FEHA). The litigation spanned nine years and included three jury trials. The first trial resulted in a mixed verdict, with the jury awarding significant economic and noneconomic damages. However, the trial court granted the defendant's motion for judgment notwithstanding the verdict (JNOV) on the constructive termination claim and ordered a new trial on noneconomic damages. Both parties appealed, and the appellate court affirmed the trial court's orders, necessitating a second trial.In the second trial, the jury awarded Simers $15.4 million in noneconomic damages, but the trial court granted a new trial due to misconduct by Simers's counsel during closing arguments and the excessive nature of the damages awarded. The third trial focused solely on the amount of noneconomic damages, resulting in a $1.25 million award, which matched a pre-trial settlement offer made by the defendant.The Superior Court of Los Angeles County awarded Simers $3,264,906 in attorney fees and $210,882.55 in costs, but excluded fees and costs incurred after the defendant's settlement offer. The defendant appealed, arguing that fees for the second trial and the unsuccessful appeal should not be awarded due to counsel's misconduct and the unrelated nature of the work. The plaintiff cross-appealed, seeking recovery of appellate fees despite the trial court's ruling.The California Court of Appeal, Second Appellate District, Division Eight, affirmed the trial court's order. The appellate court found no abuse of discretion in awarding fees for the second trial and the appeal, noting that the trial court had considered the misconduct and the overall reasonableness of the fees. The court also upheld the exclusion of post-offer fees and costs, in line with statutory requirements under section 998. View "Simers v. Los Angeles Times Communications LLC" on Justia Law

Plaintiffs Tommy Coleman and Jason Perkins, who worked as oil and gas pipeline inspectors for System One Holdings, LLC, were paid a flat daily rate without overtime compensation, even when working over forty hours a week. They filed a lawsuit claiming this violated the Fair Labor Standards Act (FLSA) and sought unpaid overtime on behalf of themselves and a putative class of similarly compensated inspectors.The United States District Court for the Western District of Pennsylvania reviewed the case. System One moved to dismiss and compel arbitration, arguing that the plaintiffs had signed arbitration agreements enforceable under the Federal Arbitration Act (FAA). The plaintiffs countered that they fell under the transportation workers' exemption to the FAA. The District Court, following the precedent set in Guidotti v. Legal Helpers Debt Resolution, L.L.C., ordered limited discovery into the arbitrability of the claims before deciding on the motion to compel arbitration. System One's motion for reconsideration of this order was denied.The United States Court of Appeals for the Third Circuit reviewed the case to determine if it had jurisdiction over the interlocutory appeal from the District Court's order. The Third Circuit held that it lacked appellate jurisdiction because the District Court's order did not formally deny the motion to compel arbitration but rather deferred its decision pending limited discovery. The court emphasized that the FAA permits appeals from specific types of orders, and the order in question did not fall within those categories. Consequently, the appeal was dismissed for lack of jurisdiction. View "Coleman v. System One Holdings LLC" on Justia Law

Robert Guthrie, a former employee of Rainbow Fencing Inc. (RFI), filed a lawsuit seeking unpaid wages and statutory damages for RFI's failure to provide wage notices and wage statements as required by New York law. Guthrie worked as a welder for RFI from 2014 to 2021 and claimed he was not paid for overtime hours. The district court entered a default judgment for the unpaid wages but dismissed Guthrie's claim for statutory damages, ruling that he lacked standing because he did not allege an injury-in-fact resulting from the failure to provide the required notices and statements.The United States District Court for the Eastern District of New York initially reviewed the case. The court granted a default judgment for Guthrie's unpaid wages but dismissed his claim for statutory damages due to lack of standing. The court concluded that Guthrie did not allege a concrete injury-in-fact caused by the absence of wage notices and statements, which is necessary to meet the case-or-controversy requirement of Article III.The United States Court of Appeals for the Second Circuit reviewed the case on appeal. The court affirmed the district court's decision, agreeing that Guthrie lacked standing to pursue statutory damages. The appellate court held that a plaintiff must allege a concrete injury-in-fact resulting from the statutory violation to have standing. Guthrie's general claims about potential harms did not suffice, as he failed to link these potential harms to any actual injury he experienced. Therefore, the court concluded that Guthrie did not meet the requirements for Article III standing and affirmed the dismissal of his claim for statutory damages. View "Guthrie v. Rainbow Fencing Inc." on Justia Law