Justia Civil Procedure Opinion Summaries

Newton Jones, the President of the International Brotherhood of Boilermakers, was removed from office and expelled from the Union by the Union’s Executive Council after it was determined that he had misused Union funds. Jones challenged the disciplinary proceedings in the United States District Court for the District of Kansas, arguing that the proceedings violated the Union Constitution and his due-process rights under the Labor-Management Reporting and Disclosure Act (LMRDA). He also claimed that the district court erred by not allowing him sufficient time to respond to the motion for summary judgment and by not permitting discovery.The district court granted partial summary judgment in favor of the Vice Presidents who had acted against Jones, affirming their decision to remove him from office. The court ruled that the Executive Council’s decision was binding and entitled to full effect. Jones then appealed the district court’s summary judgment.The United States Court of Appeals for the Tenth Circuit reviewed the case and affirmed the district court’s summary judgment. The appellate court held that the Executive Council did not violate the Union Constitution in removing Jones from office. The court deferred to the Union’s interpretation of its constitutional provisions, concluding that the Council’s interpretations were not unreasonable. The court also found that Jones had not shown any violation of the LMRDA or any error by the district court in conducting the summary-judgment proceedings.The Tenth Circuit concluded that Jones received a full and fair hearing under the LMRDA and that the district court did not err in setting an expedited briefing schedule or in not allowing additional time for discovery. The court affirmed the district court’s order granting summary judgment. View "International Brotherhood of Boilermakers v. Jones" on Justia Law

Four former employees of Litster Frost Injury Lawyers (LFIL) filed a lawsuit against LFIL and its former sole shareholder, Martha Frost, for unpaid wages and breach of an employment agreement. They claimed LFIL owed them compensation in the form of wages, bonuses, profit sharing, and other expenses incurred while employed. The district court granted summary judgment in favor of LFIL, concluding that the employees' claims were time-barred by the one-year statute of limitations under Idaho Code section 45-614 and that the employment agreement was an unenforceable "agreement to agree."The employees appealed, arguing that the district court erred in determining that the provisions of the employment agreement were not severable or enforceable and that the court should have supplied a "reasonable time" for performance. LFIL cross-appealed, arguing that the district court erred in denying their request for attorney fees following summary judgment.The Supreme Court of Idaho reviewed the case and held that the district court did not err in granting summary judgment on the employees' breach of contract claims because the employment agreement was unenforceable. The court found that the agreement's essential terms were too indefinite and subject to future negotiations. However, the court reversed the district court's decision regarding Sarah's reimbursement claim, finding that issues of material fact existed as to whether her claim fell within Idaho's Wage Claim Act. The court affirmed the district court's grant of summary judgment on all other claims.The Supreme Court also reversed the district court's decision on attorney fees, holding that the district court did not apply the correct legal standard. The court remanded the case for further proceedings consistent with its opinion. Attorney fees on appeal were awarded to LFIL for the time spent responding to certain claims, and costs were awarded to LFIL. View "Litster v. Litster Frost Injury Lawyers PLLC" on Justia Law

The case involves Patricia A. Heilman, the surviving spouse of Arthur J. Heilman, who died from an industrial accident. Patricia Heilman sought scheduled-loss compensation under Ohio law, claiming her husband had lost the use of both arms, both legs, sight in both eyes, and hearing in both ears before his death. The Industrial Commission of Ohio denied her request based on a nonexamining physician's report, which did not fully accept the findings of the examining physicians.The Tenth District Court of Appeals reviewed the case and granted a limited writ of mandamus. The court ordered the Industrial Commission to vacate its denial of scheduled-loss compensation and to re-evaluate whether Patricia Heilman had established her claims under the relevant statute. The court found that the Commission had improperly relied on the nonexamining physician's report, which did not comply with the requirements set forth in Wallace v. Industrial Commission.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's judgment. The court held that the Industrial Commission abused its discretion by relying solely on the nonexamining physician's report, which failed to accept the objective findings of the examining physicians. The Supreme Court clarified that while the Commission could not base its decision solely on the nonexamining physician's report, it could use the report as guidance in evaluating the remaining medical evidence. The court ordered the Commission to vacate its previous order and issue a new decision based on a proper evaluation of the evidence. View "State ex rel. Heilman v. Industrial Commission" on Justia Law

Cristin Dent filed a Title VII racial discrimination claim against her former employer, Charles Schwab & Co., Inc. Dent received a notice of right to sue from the Equal Employment Opportunity Commission on April 5, 2023, giving her until July 5, 2023, to file her complaint. Her attorney attempted to file the complaint on July 4, 2023, but failed to complete the online submission process. The complaint was ultimately filed on July 10, 2023, five days late. Dent requested that the district court deem her complaint timely by equitably tolling the statutory period for filing.The United States District Court for the Southern District of Indiana granted Charles Schwab’s motion for judgment on the pleadings, finding that Dent’s complaint was time-barred. The court denied Dent’s request for equitable tolling, concluding that her attorney’s failure to follow the court’s instructions and local rules on submitting complaints did not constitute an extraordinary circumstance warranting such relief.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s decision for abuse of discretion. The appellate court affirmed the district court’s judgment, agreeing that equitable tolling is an extraordinary remedy and that Dent’s attorney’s mistake was merely “garden variety” neglect, not an extraordinary circumstance. The court held that the district court did not abuse its discretion in denying the request for equitable tolling and in granting the motion to dismiss. The judgment of the district court was affirmed. View "Dent v. Charles Schwab & Co., Inc." on Justia Law

Marlon Quesada, a deputy sheriff with the Los Angeles County Sheriff's Department, was not promoted to sergeant despite taking the sergeant's examination in 2017 and 2019, scoring in band two and band one, respectively. Quesada had a mixed employment record, including two suspensions for misconduct and a 2015 investigation that was terminated due to a statute of limitations. Quesada claimed the Department improperly considered this time-barred investigation during the promotion process, which he argued was illegal.The Superior Court of Los Angeles County denied Quesada's petition for a writ of mandate, which sought to compel the Department to promote him and provide back pay and other damages. The trial court rejected Quesada's argument for a burden-shifting approach, similar to that used in discrimination cases, and found that Quesada did not establish that the Department's decision was illegal.The California Court of Appeal, Second Appellate District, reviewed the case. The court affirmed the trial court's decision, holding that the standard approach to civil litigation applies, where the plaintiff bears the burden of proving the elements of their claim by a preponderance of the evidence. The court declined to adopt a burden-shifting approach, noting that Quesada's case did not involve discrimination based on race or membership in a historically oppressed group. The court also found substantial evidence supporting the Department's decision, including Quesada's mediocre performance evaluations and past misconduct. The court concluded that Quesada's policy arguments did not justify a departure from the standard legal approach. View "Quesada v. County of L.A." on Justia Law

Miko Thomas, an employee of JBS Green Bay, filed a lawsuit under Title VII of the Civil Rights Act of 1964, alleging racial discrimination. He claimed that his employer delayed his training for three years, denied his vacation requests while approving similar requests for others, and transferred him to a different shift despite knowing it caused childcare issues. Thomas argued these actions were discriminatory based on his color.The United States District Court for the Eastern District of Wisconsin dismissed Thomas's complaint under Rule 12(b)(6) for failure to state a claim. The court found that the alleged events were not serious enough to be actionable under Title VII and that Thomas's complaint did not include all necessary elements to prove his case. After Thomas amended his complaint, the district court dismissed the suit outright, maintaining that the complaint lacked sufficient detail and did not meet the required legal standards.The United States Court of Appeals for the Seventh Circuit reviewed the case and found the district court's dismissal to be mistaken. The appellate court held that the district court incorrectly required the complaint to allege significant or material injury, which is not necessary under Title VII as clarified by the Supreme Court in Muldrow v. St. Louis. The appellate court also noted that the district court improperly demanded that the complaint include every element of proof needed for summary judgment, contrary to the notice pleading standard established by the Federal Rules of Civil Procedure and reaffirmed in Swierkiewicz v. Sorema N.A.The Seventh Circuit reversed the district court's dismissal and remanded the case for further proceedings, allowing it to move to the summary-judgment stage and potentially to trial. View "Thomas v. JBS Green Bay, Inc." on Justia Law

Julian Rodriguez, a former employee of Lawrence Equipment, Inc., filed a lawsuit alleging various wage-and-hour violations under the California Labor Code. Rodriguez claimed that Lawrence failed to pay for all hours worked, including overtime, did not provide adequate meal and rest breaks, issued inaccurate wage statements, and did not pay all due wages upon termination. He also sought civil penalties under the Private Attorneys General Act (PAGA). Rodriguez had signed an arbitration agreement with Lawrence, which led to the arbitration of his non-PAGA claims.The Superior Court of Los Angeles County ordered arbitration for Rodriguez’s wage-and-hour claims and stayed the PAGA claim. The arbitrator ruled in favor of Lawrence, finding that Rodriguez failed to prove any of the alleged Labor Code violations. The trial court confirmed the arbitration award and entered judgment for Lawrence. Subsequently, Lawrence moved for judgment on the pleadings, arguing that the arbitration award precluded Rodriguez from pursuing his PAGA claim due to lack of standing as an aggrieved employee. The trial court granted this motion and dismissed the PAGA claim.The California Court of Appeal, Second Appellate District, reviewed the case. The court held that the arbitration award, which found no Labor Code violations, precluded Rodriguez from establishing standing under PAGA. The court applied the doctrine of issue preclusion, determining that the issues litigated in arbitration were identical to those required to establish PAGA standing. Since Rodriguez could not prove any Labor Code violations, he lacked standing to pursue the PAGA claim. The court affirmed the trial court’s judgment of dismissal. View "Rodriguez v. Lawrence Equipment, Inc." on Justia Law

MaChelle Joseph, a former head women’s basketball coach at Georgia Tech, and Thomas Crowther, a former art professor at Augusta University, filed separate complaints alleging sex discrimination and retaliation under Title IX and other laws. Joseph claimed that Georgia Tech provided fewer resources to the women’s basketball team compared to the men’s team and retaliated against her for raising these issues. Crowther alleged that he was retaliated against after being accused of sexual harassment and participating in the investigation.The United States District Court for the Northern District of Georgia dismissed Joseph’s Title IX claims, ruling that Title VII precluded them, and granted summary judgment against her remaining claims. For Crowther, the district court denied the motion to dismiss his Title IX claims, allowing them to proceed.The United States Court of Appeals for the Eleventh Circuit reviewed these consolidated appeals. The court held that Title IX does not provide an implied right of action for sex discrimination in employment, reversing the district court’s decision to allow Crowther’s Title IX claims and affirming the dismissal of Joseph’s Title IX claims. The court also ruled that Crowther’s retaliation claim under Title IX, based on his participation in the investigation, did not state a valid claim. Additionally, the court found that Joseph’s claims of sex discrimination under Title VII, based on her association with the women’s team, were not viable. Finally, the court affirmed the summary judgment against Joseph’s retaliation claims under Title VII, Title IX, and the Georgia Whistleblower Act, concluding that she failed to show that the reasons for her termination were pretextual. View "Joseph v. Board of Regents of the University System of Georgia" on Justia Law

Leroy Williams, a special police officer with the D.C. Department of General Services (DGS), was terminated in August 2019 for conduct related to unauthorized traffic stops. He was given three options to appeal: filing an appeal with the Office of Employee Appeals, having his union (Fraternal Order of Police, FOP) file a grievance, or filing a grievance personally. Williams chose the second option, and FOP filed a grievance on his behalf. When the grievance could not be settled, it was advanced to arbitration, where the arbitrator upheld Williams's termination.FOP then sought review from the Public Employee Relations Board (PERB), which upheld the arbitrator's decision. FOP subsequently petitioned the Superior Court of the District of Columbia for review, which affirmed PERB's decision. After FOP's counsel withdrew, Williams filed an appeal to the District of Columbia Court of Appeals on his own.The District of Columbia Court of Appeals reviewed whether Williams had standing to bring the appeal. The court noted that the collective bargaining agreement granted the union the sole authority to arbitrate grievances and, consequently, the sole authority to appeal arbitration decisions. The court found that Williams lacked standing to appeal because only the union could pursue such an appeal unless the union breached its duty of fair representation, which was not argued in this case.The court dismissed Williams's appeal for lack of standing, concluding that he could not independently challenge the arbitration award under the terms of the collective bargaining agreement. View "Williams v. Department of General Services" on Justia Law

Alfreida Hogan, an African-American woman, was employed by the Department of Veterans Affairs (VA) as a nurse practitioner from July 2012 until March 2019, when she was demoted to staff nurse and subsequently resigned. She alleged that her immediate supervisor harassed her and gave her false, negative performance reviews due to her race, leading to her demotion. In April 2019, Hogan contacted her agency counselor, claiming racial discrimination. On July 3, 2019, the counselor informed her that informal resolution efforts had ended and that she could file a formal administrative complaint. Hogan's counsel claimed to have emailed the complaint on July 19, 2019, but the VA never received it. Hogan's counsel did not follow up until April 2020, when he learned the VA had not received the complaint. The VA dismissed the complaint due to the missed 15-day filing deadline.The district court dismissed Hogan's Title VII claims for race discrimination and retaliation, citing the Eleventh Circuit's decision in Crawford v. Babbitt, which held that failure to exhaust administrative remedies was a jurisdictional bar. The district court concluded it lacked subject-matter jurisdiction due to Hogan's untimely filing of her administrative complaint.The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court determined that the 15-day deadline to file a formal administrative complaint, set by EEOC regulation 29 C.F.R. § 1614.106(b), is a claims-processing rule subject to equitable tolling, not a jurisdictional requirement. The court noted that Crawford did not control this case because it involved a different issue. The court also referenced the Supreme Court's decision in Fort Bend County v. Davis, which held that Title VII's charge-filing requirement is not jurisdictional. Despite this, the court affirmed the district court's dismissal, concluding that Hogan did not demonstrate due diligence to warrant equitable tolling of the 15-day deadline. View "Hogan v. Secretary, U.S. Department of Veterans Affairs" on Justia Law