Justia Civil Procedure Opinion Summaries

Patricia Wright was employed by the Public Service Commission of Yazoo City (PSC) from August 2014 until November 2018, when she was terminated for allegedly falsifying documentation regarding reconnecting a customer for non-payment. Wright appealed her termination to the PSC Board, which upheld the decision. Subsequently, Wright filed a lawsuit against the PSC and its general manager, Richie Moore, claiming her termination was in retaliation for refusing to participate in illegal activities. She sought lost wages, benefits, compensatory damages, punitive damages, and costs.The Yazoo County Circuit Court denied the PSC's motion for summary judgment, finding that there was a genuine issue of material fact regarding the reason for Wright's termination. The trial judge noted that the question of whether Wright understood what falsifying documents entailed and whether she was asked to do so was a matter for the jury to decide. The PSC then filed a petition for interlocutory appeal, arguing that Wright failed to identify any illegal activity by her supervisor that could lead to criminal penalties.The Supreme Court of Mississippi reviewed the case and reversed the trial court's denial of summary judgment. The Court held that Wright failed to provide sufficient evidence that her supervisor's actions constituted illegal activities warranting criminal penalties. Wright's deposition revealed that she did not refuse to participate in any specific illegal act as required under the public policy exception to the employment at will doctrine. Consequently, the Court rendered judgment in favor of the PSC, concluding that Wright did not meet her burden of showing a genuine issue of material fact regarding her wrongful termination claim. View "Public Service Commission of Yazoo City v. Wright" on Justia Law

Next Century Rebar, LLC (NCR) worked on a project in Detroit, Michigan, within the jurisdiction of Local Union Number 25 (Local 25). Due to a shortage of Local 25 iron workers, NCR hired workers from out-of-state unions, Local 416 and Local 846. NCR made benefits contributions to the funds associated with these out-of-state unions. In 2021, Local 25 Funds conducted an audit and found that NCR had not made contributions to the Local 25 Funds for these out-of-state employees. NCR contested this, arguing that it had already made contributions to the out-of-state funds.The Local 25 Funds filed a lawsuit under 29 U.S.C. § 1145, seeking unpaid contributions. The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Local 25 Funds, awarding them $1,787,300.75 in unpaid contributions, $143,075.41 in interest, and $288,598.80 in liquidated damages. The court also awarded $18,233.15 in costs and $99,812.25 in attorney fees. NCR appealed, arguing that the district court applied the wrong summary-judgment standard, improperly granted summary judgment despite genuine disputes of material fact, and abused its discretion by not awarding a setoff for contributions made to out-of-state funds.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Local 25 CBA required contributions based on the specific employee’s gross earnings for the vacation fund and base wages for the pension fund. However, it was unclear whether the audit used the correct wage rates. The court also found that the Local 25 Funds' request for contributions violated the International Agreement’s prohibition on double payments. Consequently, the court affirmed the district court’s decision in part, reversed it in part, and remanded the case for further proceedings. View "Trustees of Iron Workers Defined Contribution Pension Fund v. Next Century Rebar, LLC" on Justia Law

Samuel Hickman was electrocuted while working on a construction site when a boom crane contacted overhead power lines. Hickman and his wife filed a personal injury lawsuit against Boomers, LLC, its owner Michael Landon, and employee Colter James Johnson, alleging negligence and recklessness. Boomers moved for summary judgment, claiming immunity under Idaho’s Worker’s Compensation Law. Hickman argued that the accident fell under the “willful or unprovoked physical aggression” exception to the exclusive remedy rule. The district court granted summary judgment for Boomers and denied Hickman’s motion for reconsideration.The district court applied the 2020 amended version of Idaho Code section 72-209(3), which clarified the “willful or unprovoked physical aggression” exception, and concluded that Boomers did not intend to harm Hickman or have actual knowledge that injury was substantially likely. Hickman appealed, arguing that the district court should have applied the pre-amendment version of the statute and the standard from Gomez v. Crookham Co., which interpreted the exception to include conscious disregard of knowledge that an injury would result.The Supreme Court of Idaho reversed the district court’s decision, holding that the pre-amendment version of section 72-209(3) and the Gomez standard should apply. The court found that the additional evidence submitted by Hickman in his motion for reconsideration created a genuine issue of material fact regarding whether Johnson consciously disregarded the known risk of injury from the power lines. The case was remanded for further proceedings consistent with this opinion. View "Hickman v. Boomers, LLC" on Justia Law

A member of the United Mine Workers of America arbitrated a dispute against Consol Energy, Inc. and won. The Union then sued to confirm the arbitration award, while Consol and its subsidiaries counterclaimed to vacate the award. The Union argued that the subsidiaries could not unilaterally reduce health benefits promised to miners for life, even if they no longer mined coal. Consol, which served as the health-plan administrator, had sent a letter indicating potential changes to benefits after the agreement expired, prompting the arbitration.The United States District Court for the District of Columbia dismissed the Union’s claim for lack of standing, reasoning that the Union was not injured as Consol had not actually modified the benefits. The court also declined to vacate the arbitration award on the merits of the Subsidiaries’ counterclaim. Both parties appealed the decision.The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court found that the Union’s claim did not fall under § 301(a) of the Labor Management Relations Act, which only authorizes suits for actual violations of contracts, not anticipated future violations. Consequently, the Union’s claim was dismissed for lack of subject-matter jurisdiction. Regarding the Subsidiaries’ counterclaim, the court determined that the Subsidiaries lacked standing as they were not named in the arbitration award and had not shown a concrete and imminent injury. The court vacated the district court’s orders on the Subsidiaries’ counterclaim and remanded it with instructions to dismiss for lack of standing.Thus, the appellate court affirmed the dismissal of the Union’s claim and vacated and remanded the Subsidiaries’ counterclaim for dismissal due to lack of standing. View "International Union, United Mine Workers of America v. Consol Energy Inc." on Justia Law

Christy Bunker sued Dow Chemical Company in Texas state court, alleging age discrimination and retaliation. Dow removed the case to federal court and filed a motion to dismiss, arguing that Bunker failed to exhaust her administrative remedies before filing suit. The district court granted Dow’s motion, finding that Bunker did not properly request that the Equal Employment Opportunity Commission (EEOC) file her charge with the appropriate state agency, the Texas Workforce Commission (TWC).The United States District Court for the Southern District of Texas dismissed Bunker’s claims under Federal Rule of Civil Procedure 12(b)(6). The court found that Bunker had filed a charge with the EEOC but did not indicate that the charge should also be filed with the TWC. Consequently, the court held that Bunker failed to exhaust her administrative remedies as required under the Texas Commission on Human Rights Act (TCHRA).The United States Court of Appeals for the Fifth Circuit reviewed the district court’s decision de novo. The appellate court affirmed the district court’s ruling, holding that Bunker’s failure to indicate on her EEOC charge that it should be filed with the TWC meant she did not meet the TCHRA’s filing requirements. The court noted that both Texas state and federal courts have consistently held that a charge filed with the EEOC must at least indicate that it is to be filed with the TWC to satisfy the TCHRA’s requirements. Therefore, Bunker’s claims were rightfully dismissed with prejudice for failing to exhaust her administrative remedies. View "Bunker v. Dow Chemical" on Justia Law

Five former participants in the Salvation Army's residential rehabilitation program filed a lawsuit alleging that the organization subjected them to forced labor. The plaintiffs, who participated in the program to address issues such as homelessness and substance abuse, were required to work approximately forty hours per week in exchange for food, clothing, and housing. They claimed that the work was not therapeutic but rather a coercive labor arrangement benefiting the Salvation Army financially. The plaintiffs included both individuals who voluntarily enrolled in the program and those referred by courts or parole/probation departments.The United States District Court for the Northern District of Illinois dismissed the plaintiffs' claims. The court found that the justice-referred plaintiffs' claims were barred by the Rooker-Feldman doctrine, as they were allegedly compelled to participate by state court orders. For the walk-in plaintiffs, the court concluded that the threats of losing food, clothing, and shelter were not sufficiently serious to constitute forced labor under federal law. The court also found that the plaintiffs failed to allege that the Salvation Army acted with the requisite intent to compel labor through threats of serious harm. The district court denied the plaintiffs' request to amend their complaint, leading to an immediate entry of judgment for the Salvation Army.The United States Court of Appeals for the Seventh Circuit affirmed the district court's judgment. The appellate court held that the Rooker-Feldman doctrine did not bar the justice-referred plaintiffs' claims, as their participation was not compelled by state court orders but by parole or probation officers. However, the court found that the plaintiffs' allegations did not plausibly indicate that the Salvation Army violated the forced labor provisions. The walk-in plaintiffs were free to leave the program at any time, and the justice-referred plaintiffs did not adequately demonstrate how the conditions of their participation constituted forced labor. The court also agreed that the proposed second amended complaint would not cure the deficiencies of the original complaint. View "Taylor v. The Salvation Army National Corporation" on Justia Law

A group of drivers sued their employer, Owl, Inc., for breach of contract and violations of the Fair Labor Standards Act (FLSA). They claimed they were not paid the correct hourly rate under their employment contract or overtime wages under the FLSA. The district court granted summary judgment for Owl on the breach of contract claim and limited the damages available to the drivers for the FLSA claim. The parties then settled the FLSA claim for $350,000, and the drivers appealed the district court’s rulings.The district court for the Middle District of Florida granted summary judgment on the breach of contract claim, reasoning that the drivers had agreed to a specific hourly rate, and enforcing a higher rate under the Service Contract Act (SCA) would create a private right of action under the SCA, which does not exist. The court also granted Owl’s motion in limine, limiting the FLSA damages to one-and-a-half times the rate the drivers were actually paid. The drivers settled the FLSA claim but reserved the right to appeal the district court’s rulings.The United States Court of Appeals for the Eleventh Circuit reviewed the case. It held that it had jurisdiction under 28 U.S.C. § 1291 because the district court entered a final judgment on all claims. The court also held that the drivers had standing to challenge the district court’s rulings despite the settlement. On the merits, the Eleventh Circuit affirmed the district court’s summary judgment on the breach of contract claim, holding that the SCA wage was not incorporated into the employment contracts. However, it reversed the district court’s ruling on the FLSA claim, holding that the “regular rate” under the FLSA should include the prevailing wage required by the SCA. The case was remanded for further proceedings consistent with this opinion. View "Perez v. Owl, Inc." on Justia Law

Lanlan Li, a 51-year-old woman of Chinese descent, worked as a senior scientist at Fresenius Kabi USA, LLC. In 2019, she developed back pain and eye strain, which led her to take various types of leave. Despite accommodations, her back injury persisted, and she could not return to her position. Consequently, Fresenius terminated her employment. Li sued the company for disability discrimination, retaliation, and failure to accommodate under the Americans with Disabilities Act (ADA) and the Illinois Human Rights Act (IHRA), as well as for national origin and age discrimination under Title VII and the Age Discrimination in Employment Act (ADEA).The United States District Court for the Northern District of Illinois granted summary judgment in favor of Fresenius on all claims. The court found that Li failed to exhaust her administrative remedies for her age and national origin claims, as she did not include a right-to-sue letter from the Equal Employment Opportunity Commission (EEOC) or the Illinois Department of Human Rights (IDHR). The court also held that her disability and retaliation claims failed on the merits, noting that Li was not a qualified individual under the ADA because she could not perform the essential functions of her job, including bench work.The United States Court of Appeals for the Seventh Circuit affirmed the district court's decision. The appellate court agreed that Li was not a qualified individual under the ADA and that Fresenius had provided reasonable accommodations. The court also found that Li failed to present evidence of age or national origin discrimination and that her retaliation claim lacked a causal connection between her EEOC charges and her termination. Therefore, the court upheld the summary judgment in favor of Fresenius. View "Li v. Fresenius Kabi USA, LLC" on Justia Law

A group of employees sued their employer, Metalcraft of Mayville, for not paying them for time spent working just before or after their shifts. The employees alleged that Metalcraft's timekeeping system, which allowed clocking in up to 15 minutes before and after shifts, did not accurately reflect the time they worked. They claimed that adjustments to their clock-in times were made even when they performed compensable work during these periods.The United States District Court for the Eastern District of Wisconsin decertified the collective action in April 2020, leading to 24 additional cases being filed and consolidated. Nine cases were dismissed for various reasons, and the district court granted summary judgment to Metalcraft in the four selected cases, ruling that the employees' evidence was speculative and insufficient. The remaining 12 plaintiffs voluntarily dismissed their cases, acknowledging that the summary judgment ruling likely determined their claims. Metalcraft then moved for sanctions against the plaintiffs' counsel, arguing that the lawsuits were frivolous.The United States Court of Appeals for the Seventh Circuit reviewed the case and upheld the district court's denial of sanctions. The appellate court found that the plaintiffs had enough factual and legal support for their claims to avoid sanctions. The court noted that FLSA claims can be based on reconstructed memories when an employer's record-keeping is inadequate. The court also determined that the plaintiffs' legal arguments regarding the Portal-to-Portal Act and the de minimis doctrine were not baseless. The appellate court emphasized that the standard for summary judgment is different from the standard for Rule 11 sanctions and that the plaintiffs' failure to win on summary judgment did not make their cases frivolous. Therefore, the denial of sanctions was affirmed. View "Farina v. Metalcraft of Mayville, Inc." on Justia Law

The case involves three Lyft drivers, Tina Turrieta, Brandon Olson, and Million Seifu, who each filed separate lawsuits under the California Labor Code Private Attorneys General Act of 2004 (PAGA) against Lyft, Inc. for alleged labor violations. Turrieta settled her case with Lyft, but before the settlement was approved, Olson and Seifu sought to intervene and object to the settlement, arguing it was unfair and that they had overlapping claims. The trial court denied their motions to intervene, approved the settlement, and later denied their motions to vacate the judgment.Olson and Seifu appealed the trial court's decisions. The Court of Appeal affirmed the trial court's rulings, holding that Olson and Seifu lacked standing to intervene or to challenge the settlement because they were not aggrieved by the judgment. The appellate court reasoned that PAGA actions are representative actions on behalf of the state, and thus, Olson and Seifu did not have a personal interest in the settlement of Turrieta’s PAGA claim.The California Supreme Court reviewed the case and agreed with the Court of Appeal. The Supreme Court held that PAGA does not authorize one aggrieved employee to intervene in another employee’s PAGA action asserting overlapping claims. The Court reasoned that allowing such intervention would be inconsistent with the statutory scheme of PAGA, which provides for oversight of settlements by the Labor and Workforce Development Agency (LWDA) and the courts, but does not mention intervention by other PAGA plaintiffs. The Court emphasized that the statutory language and legislative history indicate that the Legislature intended for the LWDA and the courts to ensure the fairness of PAGA settlements, not other PAGA plaintiffs.The Supreme Court affirmed the judgment of the Court of Appeal, concluding that Olson and Seifu did not have the right to intervene, object to, or move to vacate the judgment in Turrieta’s PAGA action. View "Turrieta v. Lyft, Inc." on Justia Law