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

Plaintiff, a surgical technologist, filed suit against the hospital alleging racial discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and 42 U.S.C. 1981. The court concluded that the district court did not clearly err in concluding that plaintiff failed to prove the hospital terminated her in retaliation for complaining of racial discrimination; in finding that plaintiff failed to prove that race was the motivating factor behind her termination, rather the district court believed that plaintiff was terminated for being insubordinate; and in finding that plaintiff was not subject to disparate terms and conditions of her employment based on race. Accordingly, the court affirmed the judgment of the district court. View "Wright v. St. Vincent Health System" on Justia Law

The Unions filed a grievance against Alcan, claiming that Alcan violated a collective bargaining agreement. On appeal, the Unions challenged the district court's order vacating the arbitrator's award of severance pay. The court reversed the judgment because a federal court must defer to the arbitrator's interpretation where the arbitrator was at least arguably construing or applying the collective bargaining agreement. The court denied the Unions' request for attorneys' fees. Alcan acted promptly to seek an order vacating the arbitration award and the company did not act dishonestly or in bad faith. View "Alcan Packaging Co. v. Graphic Communications, et al." on Justia Law

Plaintiff filed suit against Trinity alleging wrongful termination in violation of the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; Title VII of the Civil Rights Act, 42 U.S.C. 2000e-1 et seq.; the North Dakota whistleblower statute, N.D. Cent. Code 34-01-20(1); and N.D. Cent. Code 34-01-04 (the intimidation statute). On appeal, plaintiff challenged the district court's grant of summary judgment in favor of Trinity and the denial of her motion for a default judgment. The court found no abuse of discretion in the district court's denial of plaintiff's motion for summary judgment or default judgment, which asked the court to grant a dispositive discovery sanction against Trinity for its willful pattern of action in failing to comply with the scheduling order. Plaintiff failed to advance any evidence indicating that Trinity did in fact replace plaintiff with someone substantially younger, that she was treated differently than any other similarly situated male employee, that plaintiff engaged in a protected activity under the whistleblower statute, and that there was a private right of action under the intimidation statute. Accordingly, the court affirmed the judgment of the district court. View "Holmes v. Trinity Health" on Justia Law

ABF filed suit against defendants alleging a violation of a collective bargaining agreement (CBA). On appeal, ABF challenged the district court's grant of defendants' motion to dismiss under Rule 12(b)(6). ABF contended that because the agreement's grievance-resolution system was unavailable, the district court may appoint a disinterested tribunal to hear the grievance or, alternatively to provide redress. The court concluded that the district court could not appoint a new tribunal because the National Grievance Committee (NGC) rules provided a solution. Though the rules here did not mandate the NGC's specific response to a disqualification, they nonetheless made clear that resolving it by amending or modifying the rules was an issue for the NGC. In regards to ABF's request for redress directly from the court for breach of the National Master Freight Agreement (NMFA), the court rejected ABF's unavailability and futility arguments, as well as its remaining claims. Accordingly, the court affirmed the judgment of the district court. View "ABF Freight System, Inc. v. Int'l Brotherhood of Teamsters, et al." on Justia Law

Plaintiffs, two laborers, filed suit against their employer, ConAgra Foods, alleging that ConAgra violated the Fair Labor Standards Act (FLSA), 29 U.S.C. 216(b), by failing to compensate them and others similarly situated for time spent walking between changing stations where they donned and doffed their uniforms and the time clock where they punch in and out for the day. The court concluded that the time spent by the laborers donning and doffing their uniforms was excluded by agreement from the hours for which they were employed; donning and doffing was not an activity that the laborers were employed to perform, and it was therefore not a principal activity that begins and ends the workday; and it follows that the time spent walking between the clothes-changing stations and the time clock was not part of the workday and workweek for which the employer was liable to pay overtime compensation under the FLSA. Accordingly, the court reversed the district court's denial of ConAgra's motion for summary judgment and remanded for further proceedings. View "Adair, et al. v. ConAgra Foods, et al." on Justia Law

Plaintiff filed suit alleging sex and race discrimination, retaliation, and sex and race harassment in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., and retaliation in violation of the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The court concluded that the district court properly granted summary judgment for the state on plaintiff's race and sex discrimination and retaliation claims where plaintiff did not establish a prima facie case because she could not show, as a matter of law, that she suffered an adverse employment action. The court also concluded that summary judgment was appropriately granted on the harassment claim where the conduct described did not affect a term, condition, or privilege of employment because this conduct was not severe or pervasive enough to constitute actionable discrimination. Accordingly, the court affirmed the district court's judgment. View "Jackman v. Fifth Judicial District, et al." on Justia Law

Plaintiff filed suit against his employer (Nichols) for breach of the Collective Bargaining Agreement (CBA) and against his union for breach of its duty of fair representation. Plaintiff alleged that Nichols breached the CBA by failing to establish rest periods for workers on the continuously operating lines as required by Section 17.1 of the CBA. In this case, the union had a duty not to pursue a grievance to arbitration that it believed did not warrant such action. The court concluded that plaintiff had not raised a genuine issue of material fact on whether the union failed in its duty of fair representation on the issue before the court. Accordingly, the court affirmed the district court's grant of summary judgment for the union and the employer. View "Inechien v. Nichols Aluminum, LLC, et al." on Justia Law

Plaintiff, aged 76, filed suit under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq, and state law, contending that Securitas fired him because of his age. Plaintiff cited evidence that prior to his termination, Securitas supervisors showed age animus through negative comments regarding plaintiff's age. Plaintiff adduced enough evidence to raise genuine doubt as to the legitimacy of Securitas's motive, even if that evidence did not directly contradict or disprove Securitas's articulated reasons for its actions. Accordingly, the court reversed the district court's grant of summary judgment in favor of Securitas, concluding that there were genuine issues of material fact concerning pretext. View "Johnson v. Securitas Security Services" on Justia Law

In this case, the parties disagreed about the nature of their dissolution agreement after one of them experienced a change in circumstances. Patriot Coal and Heritage Coal sought declaratory relief under 28 U.S.C. 2201 and Fed. R. Civ. P. 57, and requested a declaration that Peabody Holding's obligations with respect to the healthcare benefits owed to the Assumed Retirees would not be affected by modification of the benefits of retirees of Heritage or Eastern Associated under 11 U.S.C. 1114. The bankruptcy court denied relief and Patriot and Heritage appealed. While Heritage's rejection of its collective bargaining agreement relieved it of its contractual obligation to pay benefits, it still has a statutory obligation to pay those same benefits, at least until all of the steps of section 1114 are complied with. Therefore, the bankruptcy appellate panel (BAP) held that upon rejection of the "me too" agreement under section 1113, absent modification under section 1114, Heritage was still required to comply with the terms of the individual employer plan and provide its retirees those plan defined benefits; neither Heritage or United Mine Workers of America requested a modification; Peabody Holding's obligation under the liabilities assumption agreement remains undisturbed upon grant of the sections 1113 and 1114 motion; and Peabody Holding's remaining arguments lacked merit. Accordingly, the BAP reversed the decision of the bankruptcy court. View "Patriot Coal Corp., et al. v. Peabody Holding Co., et al." on Justia Law

In these consolidated cases, the court addressed the Board's finding that RELCO unlawfully discharged eight workers for engaging in protected labor activity and RELCO's subsequent challenge to the Board's composition. The court concluded that substantial evidence supported the Board's labor law conclusions. The court also concluded that it lacked authority to decide RELCO's challenge to the recess appointments where RELCO's challenge was barred by 29 U.S.C. 160(e)'s jurisdictional exhaustion requirement. Accordingly, the court granted the Board's application for enforcement and denied RELCO's petitions for review. View "NLRB v. RELCO Locomotive" on Justia Law