Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

Jason Schmit, a truck driver for Trimac Transportation, Inc., was diagnosed with Parkinson’s disease in 2018. Following his diagnosis, Trimac provided informal accommodations, allowing Schmit to perform tasks that avoided climbing, pulling hoses, or making certain connections, and adjusting his work schedule to end earlier in the day. In 2021, after a new terminal manager was hired, Schmit was asked to formalize his accommodation requests, which Trimac largely approved. However, Schmit encountered difficulties, including changes in internal shop procedures that affected his ability to perform required tasks, disputes about hauling heavy loads, and disciplinary actions for job violations. Schmit complained to Human Resources about alleged harassment and difficulties related to his disability, but Trimac concluded its policies were being properly enforced. In August 2021, following a dispute, Schmit left work and Trimac treated his departure as a resignation. Schmit later applied for and received Social Security disability benefits, representing that his condition made it impossible for him to work.The United States District Court for the District of South Dakota dismissed Schmit’s state law claims for failure to exhaust administrative remedies and granted summary judgment to Trimac on the remaining claims. The district court found genuine disputes existed regarding whether Schmit resigned or was fired and whether there was discriminatory intent, but determined that Schmit’s statements to the Social Security Administration prevented him from showing that he was a “qualified individual” under the ADA.The United States Court of Appeals for the Eighth Circuit affirmed the district court’s decision. The Eighth Circuit held that Schmit failed to adequately explain the contradiction between his representations to the Social Security Administration and his litigation position, barring his ADA claim. The court also concluded that Schmit failed to establish a hostile work environment, retaliation, or wrongful termination under South Dakota law. The judgment of the district court was affirmed. View "Schmit v. Trimac Transportation, Inc." on Justia Law

After being employed by the City of St. Louis as a corrections officer for over two decades, the plaintiff was transferred to a clerk typist position in the City’s towing division following an injury. In her new role, she uncovered and reported numerous instances of apparent misconduct and fraud involving the unlawful sale or transfer of vehicles by employees at the tow lot. She conveyed her concerns to various city officials, including her supervisors, the mayor’s office, and the comptroller’s office, and ultimately disclosed the information to the media. Following these disclosures, she experienced workplace retaliation and was ultimately terminated by the Director of the Department of Streets the day after a news story, which included information she had provided, was broadcast.The United States District Court for the Eastern District of Missouri dismissed the First Amendment claim against the City but allowed the First Amendment retaliation claim against the Director, in his individual capacity, to proceed to trial. The jury found in favor of the plaintiff, concluding that her protected speech was a motivating factor in her termination, and awarded compensatory and punitive damages. The district court denied the Director’s post-trial motions for judgment as a matter of law and for a new trial.The United States Court of Appeals for the Eighth Circuit reviewed the case. It held that the Director failed to preserve his qualified immunity defense for appeal and found that there was sufficient evidence for the jury to find that the plaintiff’s protected speech motivated her termination. The court further determined that the district court did not abuse its discretion in admitting contested evidence or in denying a new trial, and that there was enough evidence for punitive damages. The Eighth Circuit affirmed the district court’s judgment. View "Woods v. City of St. Louis, Missouri" on Justia Law

The plaintiff, a Hawaii resident, entered into a National Employment Agreement with Cardiovascular Systems, Inc. (CSI), a Minnesota-based medical device company, to serve as District Sales Manager for Hawaii. The agreement required him to complete mandatory training in Minnesota before he could work fully in Hawaii. He attended training in Minnesota for a total of twelve days over two visits during early 2023 and participated in remote meetings from Hawaii. Shortly after completing training, CSI terminated his employment. The plaintiff alleged that his termination was in retaliation for reporting illegal conduct in violation of federal law, while CSI claimed it was due to his conduct. Subsequently, Abbott Laboratories, Inc. acquired CSI.The plaintiff first filed a complaint in Minnesota state court against Abbott Laboratories, Inc. (ALI) under the Minnesota Whistleblower Act (MWA). ALI removed the case to federal court and moved to dismiss the complaint. After an unsuccessful attempt to amend his complaint, the plaintiff voluntarily dismissed the action and refiled a nearly identical complaint, later amending it to add CSI as a defendant and a claim under the Hawaii Whistleblowers’ Protection Act (HWPA). The defendants again moved to dismiss, and the plaintiff sought to further amend the complaint to add more details and another defendant.The United States District Court for the District of Minnesota granted the motion to dismiss, holding that the plaintiff did not qualify as an “employee” under the MWA because he neither performed “services for hire” nor maintained ongoing physical presence in Minnesota, and that he had waived his HWPA claim by agreeing to a Minnesota choice-of-law provision in his employment contract. The Eighth Circuit Court of Appeals affirmed, concluding that the district court correctly applied Minnesota law, enforced the choice-of-law provision, and properly denied leave to amend as futile. View "Ghosh v. Abbott Laboratories" on Justia Law

Midwest Division-RMC, LLC operates a hospital in Kansas City, Missouri, and has had collective bargaining relationships with two unions: the Service Employees International Union HCII (SEIU) and the National Nurses Organizing Committee (NNOC). In June 2021, employees in the SEIU bargaining unit voted to decertify SEIU as their representative, but SEIU’s objections to the election were still pending before the National Labor Relations Board (NLRB). Midwest stopped recognizing SEIU and ceased processing grievances, taking actions that included halting dues deductions and denying SEIU access to the facility. Separately, after an unrelated grievance meeting in September 2021, NNOC’s labor representative was denied participation by Midwest.SEIU and NNOC filed unfair labor practice charges with the NLRB. An Administrative Law Judge found Midwest violated the National Labor Relations Act (NLRA) by withdrawing recognition from SEIU before the election was certified and by preventing the NNOC representative from attending the grievance meeting. The NLRB affirmed these findings and ordered Midwest to remedy both violations, but denied SEIU’s request for a notice reading remedy. Midwest sought review of these orders, the NLRB sought enforcement, and SEIU also petitioned for review regarding the remedy.The United States Court of Appeals for the Eighth Circuit reviewed the case. The court held that Midwest did not automatically violate the NLRA by withdrawing recognition from SEIU after the vote but before certification; instead, Midwest acted at its peril, and when the NLRB ultimately certified the decertification, Midwest’s actions did not violate the Act. The court reversed the NLRB’s order regarding SEIU and remanded with instructions to dismiss those claims. However, the court enforced the NLRB’s order regarding the NNOC grievance, finding that the collective bargaining agreement did not clearly limit the number of union representatives at the grievance meeting. View "Midwest Division-RMC, LLC v. NLRB" on Justia Law

During the COVID-19 pandemic, a county employer required its employees to either be fully vaccinated or undergo weekly COVID-19 testing. Employees could test at county facilities during work hours or use at-home test kits and count that time as work. Two employees objected to these requirements on religious grounds. One employee, Borgheiinck, asserted that mandatory vaccines and testing conflicted with her Christian beliefs about bodily autonomy. She was initially given unpaid leave as an accommodation, but the county later revoked this, citing undue hardship, and ultimately terminated her after not responding to her proposals for alternative work arrangements. The other employee, Colson, also objected on religious grounds. She was granted an exemption from nasal swab testing and allowed to use saliva tests, which she found intrusive and non-private, but she was not terminated.The United States District Court for the District of Minnesota dismissed all claims, including those under Title VII. The plaintiffs sought leave to file a motion for reconsideration based on new legal precedent, but the court denied this request. The plaintiffs appealed the dismissal of their Title VII claims and the denial of reconsideration.The United States Court of Appeals for the Eighth Circuit reviewed the case de novo. It held that Borgheiinck’s complaint did not sufficiently connect her religious beliefs to an objection to the testing policy, as required to state a plausible claim under Title VII. For Colson, the court held that she had not plausibly alleged that she suffered any adverse employment action, such as termination or unpaid testing time, since the county’s policy allowed testing during compensated time. The Eighth Circuit affirmed the district court’s dismissal of the Title VII claims and its denial of leave to seek reconsideration. View "Colson v. Hennepin County" on Justia Law

Donald Stephens was employed as an operator for United States Environmental Services, LLC, a position that required him to maintain a valid commercial driver's license (CDL). During a Saturday shift, Stephens refused to perform tasks typically assigned to technicians and raised several safety concerns, including inadequate equipment and staff. He also disclosed a heart condition to his supervisor. As a result, he was required to undergo a medical examination, which led to a 45-day medical hold on his CDL. Although he was medically cleared to perform non-driving work, USES denied his request for reassignment and recommended he seek short-term disability. After the hold was lifted and he was cleared to drive, Stephens resigned, claiming discomfort with his treatment by USES. Stephens filed suit in the United States District Court for the Eastern District of Arkansas, alleging disability discrimination and retaliation under the Americans with Disabilities Act (ADA) and the Arkansas Civil Rights Act, as well as violations of the Fair Labor Standards Act (FLSA). The district court dismissed the FLSA claim and granted summary judgment to USES on the remaining claims. The court held that Stephens did not have a disability as defined by the ADA because his heart condition did not substantially limit a major life activity, and that USES did not regard him as disabled. The court also found that Stephens had not engaged in protected activity necessary to support a retaliation claim. On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s summary judgment ruling de novo. The appellate court affirmed the district court’s judgment, holding that Stephens did not demonstrate a substantial limitation of a major life activity and did not establish that he engaged in protected activity under the ADA. The Eighth Circuit also declined to consider an argument Stephens raised for the first time on appeal. View "Stephens v. U.S. Environmental Services LLC" on Justia Law

Benjamin Zarn, a Forensic Support Specialist employed at a state-run treatment center, challenged workplace Covid-19 protocols implemented by the Minnesota Department of Human Services (MDHS). In 2021, MDHS adopted policies requiring employees who did not telework to provide proof of Covid-19 vaccination or undergo weekly testing. Additionally, vaccinated employees who tested positive for Covid-19 could receive up to seven days of paid administrative leave if they exhausted their sick leave. Zarn objected to the vaccine and testing requirements on religious and moral grounds, citing his Catholic beliefs and concerns about the use of fetal cells in vaccines. Despite his objections, Zarn complied with the testing policy but claimed he did so under duress, fearing job loss. Although Zarn expressed dissatisfaction with the policies to his supervisor, union president, and administrators, he did not formally request a religious accommodation.Zarn filed charges with the Equal Employment Opportunity Commission (EEOC), alleging religious discrimination under Title VII and violations of the Americans with Disabilities Act (ADA). After receiving right-to-sue letters, he sued MDHS in the United States District Court for the District of Minnesota, also alleging violations of the Minnesota Human Rights Act and the Minnesota Refusal of Treatment statute. The district court dismissed the state law claims for lack of jurisdiction and failure to state a claim, and then granted summary judgment to MDHS on the federal claims, finding that Zarn failed to exhaust administrative remedies for some claims and did not notify MDHS of a religious conflict or suffer an adverse employment action.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 judgment, holding that Zarn failed to exhaust administrative remedies regarding the Covid Pay Policy, did not notify MDHS of a religious conflict as required to establish a prima facie Title VII failure-to-accommodate claim, and that the Covid testing requirement did not violate the ADA because it was job-related and consistent with business necessity. View "Zarn v. Minn. Dept. of Human Services" on Justia Law

Michelle Siebrecht worked as a physician assistant in the emergency room at a rural Iowa hospital operated by Mercy Health Services. Her employment contract required her to work three 24-hour shifts per pay period, including weekends. Siebrecht, diagnosed with multiple sclerosis, took FMLA leave twice due to her condition. Upon returning, her doctor imposed restrictions: she could work no more than one 24-hour shift per week and no weekends. Mercy’s CEO expressed concern that these limitations made it difficult to staff the ER and were unfair to other providers. Mercy ultimately chose not to renew Siebrecht’s contract, notifying her that her employment would end after the temporary renewal period.Siebrecht filed suit in Iowa state court, alleging that Mercy violated the Americans with Disabilities Act, the Iowa Civil Rights Act, and the Family and Medical Leave Act by discriminating against her based on her disability and retaliating against her for taking FMLA leave. Mercy removed the case to the United States District Court for the Northern District of Iowa. The district court granted summary judgment in favor of Mercy, finding that Siebrecht was not a “qualified individual” under the ADA and ICRA, as she could not perform the essential functions of her job with or without reasonable accommodation. The court also concluded that there was no causal connection between her FMLA leave and the termination of her employment.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s grant of summary judgment de novo and affirmed. The Eighth Circuit held that the ability to work three 24-hour shifts per pay period and weekends was an essential function of Siebrecht’s position and that no reasonable accommodation would have enabled her to perform these functions. The court also found insufficient evidence of FMLA retaliation or pretextual termination. The judgment of the district court was affirmed. View "Siebrecht v. Mercy Health Services - Iowa Corp." on Justia Law

Several former employees of a logistics company left their positions and later joined a competitor. The former employer alleged that, as a condition of their employment, these individuals had signed agreements containing restrictive covenants, including broad non-solicitation and business interference clauses. The company claimed the employees breached these restrictive covenants and further alleged that the competitor had tortiously interfered with its contractual relationships.Initially, the United States District Court for the District of Minnesota granted summary judgment for the defendants, holding that the agreements were unenforceable under California law, and thus the breach of contract and tortious interference claims failed. On the first appeal, the Eighth Circuit determined that Minnesota law rather than California law governed the agreements for all but one employee, remanding the case to the district court to reconsider the enforceability of the contracts under Minnesota law and to resolve related summary judgment motions. On remand, the district court again granted summary judgment to the defendants, holding the restrictive covenants were overly broad and unenforceable under Minnesota law, and denied the plaintiff’s motion for voluntary dismissal of certain claims.On appeal, the United States Court of Appeals for the Eighth Circuit held that the restrictive covenants in the agreements are unenforceable under Minnesota law, as they sweep more broadly than necessary to protect the former employer’s business interests, both in scope and geographic reach. The Eighth Circuit also affirmed the district court’s denial of voluntary dismissal, finding it would waste judicial resources and could prejudice the affected employee. The Eighth Circuit affirmed the district court's grant of summary judgment for the defendants, denial of the plaintiff’s summary judgment motion, and denial of the plaintiff’s motion for voluntary dismissal. View "C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc." on Justia Law

A company that manufactures emergency-use auto-injectors terminated a senior technician after she certified that a probationary employee completed five on-the-job training (OJT) tasks in a single day. The company alleged that this certification was fraudulent and did not comply with its training policies, as the forms lacked supporting documentation and the employee did not demonstrate proficiency. The technician, a qualified trainer, filed a grievance through her union, arguing that it was common practice on her shift to conduct and certify multiple OJTs in one day and that supervisors were aware of these practices.An arbitrator reviewed the grievance under the collective bargaining agreement (CBA) between the company and the union. The arbitrator found that the company failed to prove by a preponderance of the evidence that the technician’s actions were intentionally fraudulent or falsified. The arbitrator also noted that the company’s staffing shortages and established practices contributed to the situation and drew an adverse inference against the company for not calling key supervisors as witnesses. The arbitrator ordered the technician’s reinstatement with back pay and benefits. The United States District Court for the Eastern District of Missouri granted summary judgment to the union, affirming the arbitrator’s award.On appeal, the United States Court of Appeals for the Eighth Circuit reviewed the district court’s decision de novo for legal conclusions and for clear error on factual findings. The Eighth Circuit held that the arbitrator acted within his authority in interpreting ambiguous terms in the CBA, such as “dishonesty,” and in considering past practices. The court also found that the arbitrator’s adverse inference and allocation of the burden of proof were permissible. Finally, the court concluded that reinstating the technician did not violate any well-defined and dominant public policy. The judgment affirming the arbitrator’s award was affirmed. View "Meridian Medical Technologies, Inc. v. International Brotherhood of Teamsters, Local 688" on Justia Law