Articles Posted in Labor & Employment Law

by
The Eighth Circuit affirmed the district court's grant of Medtronic's motion to remand an employment contract dispute back to state court. Applying Minnesota law, the court held that plaintiff waived his right to remove the case to federal court because the employment contract he signed contained an enforceable forum selection clause. In this case, Medtronic alleged that plaintiff failed to repay the company pursuant to the Repayment Agreement. The court held that the Employee Agreement contained a clear and unequivocal forum selection clause that unambiguously encompassed the Repayment Agreement. View "Medtronic Sofamor Danek, Inc. v. Gannon" on Justia Law

by
Plaintiff filed suit against his former employer for race and age discrimination under Title VII of the Civil Rights Act, the Age Discrimination in Employment Act (ADEA), the Arkansas Civil Rights Act, and for promissory estoppel. The Eighth Circuit affirmed the district court's grant of the company's motion to strike portions of plaintiff's statement of material disputed facts and grant of summary judgment. The court held that the district court did not abuse its discretion in striking paragraphs of plaintiff's statement of material fact as unsupported by the record or irrelevant and immaterial; the district court properly granted the employer summary judgment on claims arising more than 180 days before plaintiff filed his EEOC charges; the district court properly granted the employer summary judgment on the failure to rehire claim because plaintiff took no action, never applied for reemployment, and believed he could not perform the duties of the position; the Arkansas Civil Rights Act claims were time-barred; and there was no factual basis for the promissory estoppel claim. View "Kirklin v. Joshen Paper & Packaging of Arkansas Co." on Justia Law

by
The Eighth Circuit affirmed the district court's grant of summary judgment for Cargill in an action alleging that the company discriminated against a former employee in violation of the Americans with Disabilities Act (ADA) and the Iowa Civil Rights Act (ICRA). The court held that plaintiff failed to present direct and indirect evidence of disability discrimination; plaintiff was not a qualified individual protected by the ADA because she failed to demonstrate that at the time of her termination she could regularly and reliably attend work, an essential function of her employment; and the ADA's protections did not extend to providing plaintiff with her desired accommodation of more time off following her 194 days of unplanned absences. View "Lipp v. Cargill Meat Solutions Corp." on Justia Law

by
The Eighth Circuit affirmed the district court's grant of summary judgment to Allina in an action brought by a former employer under the Americans with Disabilities Act (ADA) and the Minnesota Human Rights Act (MHRA), after she was terminated for refusing to fulfill a job requirement that she take necessary steps to develop immunity to rubella. The court held that, although the district court erred in denying plaintiff's inquiry claim based on a lack of injury, summary judgment was proper where Allina's decision to require employees with client contact to complete an inquiry and exam was job-related, consistent with business necessity, and no more intrusive than necessary. Therefore, the health screening that plaintiff was required to take as a condition of her employment complied with the ADA and the MHRA The court also held that the evidence was insufficient to support plaintiff's claim that she was disabled under the ADA where the evidence was insufficient to support the conclusion that plaintiff's chemical sensitivities or allergies substantially or materially limited her ability to perform major life activities. Therefore, plaintiff's failure to accommodate claim failed. Likewise, her retaliation claim failed. View "Hustvet v. Allina Health System" on Justia Law

by
The Eighth Circuit affirmed the district court's order granting Steak 'n Shake's motion for summary judgment on plaintiff's Americans with Disabilities (ADA) discrimination claim and his Missouri Workers' Compensation claim. The court held that plaintiff failed to show that he was a qualified individual within the meaning of the ADA. In this case, although he believed that he could perform the essential job functions of a fountain operator, plaintiff's permanent medical restrictions barred him from performing the duties described in the job description. Likewise, plaintiff could not perform the duties of other positions he identified as alternative jobs. View "Denson v. Steak 'n Shake, Inc." on Justia Law

by
The Eighth Circuit affirmed the district court's dismissal of a class action brought by over 52,000 experienced and student over-the-road truck drivers, alleging claims under federal and state wage and hour laws. The court held that judicial estoppel was not applicable in this case and that Werner was not bound to previous statements in such a way that affected the outcome of the case. The court also held that, under the Fair Labor Standards Act (FLSA), the mileage-based payments were remuneration for employment and should be included in Werner's minimum wage calculation. Finally, the state law claims were foreclosed as well. View "Baouch v. Werner Enterprises, Inc." on Justia Law

by
The EEOC filed suit alleging that North Memorial violated 42 U.S.C. 2000e-3(a), by unlawfully retaliating against an employee. The district court granted summary judgment for North Memorial and dismissed the claim, concluding that North Memorial did not violate section 2000e-3(a) because it did not discriminate against the employee. The Eighth Circuit affirmed and held that the EEOC failed to establish a prima facie case of opposition-clause unlawful retaliation because merely requesting a religious accommodation was not the same as opposing the allegedly unlawful denial of a religious accommodation. The court reasoned that, when an employee or applicant requested a religious accommodation, and the request was denied by an employer such as North Memorial that accommodated reasonable requests that did not cause undue hardship, there was no basis for an opposition-clause retaliation claim under Sec. 2000e-3(a). The court held that the employee or applicant's exclusive Title VII remedy was an unlawful disparate treatment or disparate impact claim under section 2000e-2(a)(1). View "EEOC v. North Memorial Health Care" on Justia Law

by
The Eighth Circuit affirmed the district court's grant of summary judgment for Saint Luke's in an employment discrimination action. The court held that the district court did not abuse its discretion in denying defendant's motion to reconsider under Federal Rule of Civil Procedure 60(b)(1). The court explained that, although defendant's delay was brief, Saint Luke's made no claim of prejudice and defendant did not act in bad faith, such factors did not outweigh defendant's carelessness or mistake in construing the rules and the absence of any apparent meritorious defense. Furthermore, there were no exceptional circumstances in this case that warranted relief under Rule 60(b)(6). View "Giles v. St Luke's Northland-Smithville" on Justia Law

by
The Eighth Circuit affirmed the district court's grant of summary judgment for defendant in an action alleging that plaintiff's injuries were caused by defendant's negligence in driving a tractor trailer truck. The court held that the workers' compensation benefits plaintiff received were his exclusive remedy against defendant. In this case, defendant and plaintiff entered into an employment relationship in which Swift and Johnson were joint employers mutually liable under Iowa law to provide plaintiff workers' compensation benefits when he suffered a work-related injury, an obligation Swift has fully performed. View "Quiles v. Johnson" on Justia Law

by
The Eighth Circuit affirmed the district court's grant of summary judgment for DCDC in an action alleging claims of gender, age, and disability discrimination under state and federal civil rights laws. Plaintiff, a 56 year old woman, worked as a correctional officer until she was injured in inmate altercations. After plaintiff worked the maximum allowable number of days of light duty pursuant to the terms of the Collective Bargaining Agreement (CBA), she was terminated when no other suitable position was found. The court held that plaintiff failed to establish a prima facie case of sex discrimination; plaintiff's prima facie evidence of bad faith supporting her claim of failure to accommodate/disability was rebutted by the incontrovertible evidence that plaintiff could not have been reasonably accommodated; and plaintiff's age discrimination claim failed because she did not produce evidence of a similarly situated younger person who was treated differently. View "Faulkner v. Douglas County" on Justia Law