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

Plaintiffs were unionized delivery drivers covered by a collective bargaining agreement (CBA), which established a pension plan operated by a third-party pension management firm. After a dispute arose in 2006 after the drivers' employers and union re-negotiated the CBA, the drivers sued their employer, the union, and the pension management firm for various breaches of duty. Because the drivers failed to establish that equitable tolling applied, the court held that their complaint was untimely and the district court's summary judgment dismissal was proper. The court also held that the employer failed to identify a compelling reason why it could not have brought its claims against the union in an NLRB proceeding. Accordingly, the court affirmed the district court's judgment that the drivers' claims were barred by the statute of limitations under 29 U.S.C. 160(b) and that the other claims were dismissed, including the employer's crossclaims against the union. View "Gerhardson, et al v. Gopher News Co., et al" on Justia Law

Plaintiff, a female physician of Iranian origin, brought claims under Title VII, 42 U.S.C. 2000e et seq., and the Iowa Civil Rights Act, Iowa Code ch. 216, alleging discrimination based on her sex, pregnancy, and national origin. The court affirmed the district court's grant of summary judgment to defendant, concluding that plaintiff could not assert a claim under either statute because she was an independent contractor. View "Glascock v. Linn County Emergency Medicine" on Justia Law

Plaintiff filed suit against her employer, alleging discrimination and retaliation claims under 42 U.S.C. 1983; the Arkansas Equal Pay Act, Ark. Code. Ann. 11-4-601; and the Arkansas Civil Rights Act (ACRA), Ark. Code. Ann. 16-123-101 et seq. On appeal, plaintiff challenged the district court's grant of summary judgment dismissing all claims. The court affirmed the judgment, concluding that no reasonable factfinder could find that any defendant was guilty of intentional, gender-based wage discrimination when plaintiff's initial salary as a new zoning official was established in November 2006; plaintiff's failure-to-hire claim failed based on undisputed evidence supporting defendants' nondiscriminatory reason for hiring another candidate based on more experience and better qualifications and because plaintiff failed to demonstrate pretext; and plaintiff's remaining claims also failed. View "Hill v. City of Pine Bluff, et al" on Justia Law

Plaintiffs, current and former employees of Redland, commenced this action alleging that Redland violated the overtime provision of the Fair Labor Standards Act (FLSA), 29 U.S.C. 207(a)(1), by changing the designation of their workweek, but not their work schedule, so that fewer hours qualified as "overtime." Agreeing with a Department of Labor investigator, the district court found no FLSA violation and granted Redland's motion for summary judgment. The court rejected plaintiffs' contention that an employer's permanent change in the designated workweek violated section 207(a)(1) unless it was justified by a legitimate business purpose. So long as the change was intended to be permanent, and it was implemented in accordance with the FLSA, the employer's reasons for adopting the change are irrelevant. Accordingly, the court affirmed the judgment. View "Abshire, et al v. Redland Energy Services" on Justia Law

This dispute arose out of an employment contract between defendant and plaintiffs, his employer. After receiving a favorable judgment in a prior proceeding, defendant moved to dismiss plaintiffs' complaint in the present action on the basis of res judicata. Defendant also filed a motion requesting sanctions and attorney's fees. The district court granted the motion to dismiss but declined to impose sanctions or award attorney's fees. Both parties appealed. The court concluded that the district court properly decided the merits of defendant's res judicata defense on a motion to dismiss. On the merits, Count VI was barred by res judicata where the cause of action existed at the time of the first judgment and it occurred from the same transaction or occurrence. Finally, the court affirmed the district court's decision to deny sanctions and attorney's fees. View "C.H. Robinson Worldwide, Inc., et al v. Lobrano, Jr." on Justia Law

Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), 29 U.S.C. 1001 et seq., the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and state law, alleging that defendant had retaliated against him after he raised complaints protected by those statutes. The district court granted summary judgment to defendant on the federal law claims and dismissed the state law claims without prejudice. The court concluded that plaintiff failed to make a prima facie case of retaliation under ERISA. Likewise, plaintiff failed to make a prima facie case of retaliation under the FLSA. At any rate, plaintiff failed to show a causal connection between his complaint about holiday meal time and his termination six months later. Accordingly, the court affirmed the judgment. View "Shrable v. Eaton Corp." on Justia Law

Plaintiff filed suit claiming that UPS discriminated against him based on his gender, sexual orientation, and disability when it failed to hire him as a part-time package handler. The court affirmed the district court's grant of summary judgment in favor of UPS, holding that plaintiff could not prove that UPS discriminated against him because of a protected status of which it was unaware and even if a jury could find that there was discrimination, UPS provided a legitimate non-discriminatory reason for not hiring plaintiff. View "Hunter v. United Parcel Service, Inc." on Justia Law

Plaintiff brought suit against his employer, the City of O'Fallon, alleging, among other things, that the city retaliated against him for exercising his right to free speech guaranteed by the United States and Missouri Constitutions. Plaintiff's free speech claim alleged that the city retaliated against him for the comments made in his report to the Board of Alderman by failing to promote plaintiff, by failing to follow internal procedures while investigating him, and by taking negative personnel actions against him. Defendant's Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-634, and Missouri Human Rights Act (MHRA), Mo. Rev. Stat. 213.055, claims alleged that the city failed to promote plaintiff because of his age. The district court granted summary judgment in favor of the city. The court held that the district court did not err in granting summary judgment in favor of the city on plaintiff's free speech claims; plaintiff failed to meet his burden under the MHRA and summary judgment was properly granted on this claim; summary judgment was properly granted on the ADEA claim; and his Missouri Workers' Compensation Act, Mo. Rev. Stat. 287.780 claim. Accordingly, the court affirmed the judgment. View "Buehrle v. City of O'Fallon, Missouri" on Justia Law

Plaintiff sued her employer alleging disability discrimination in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and the Iowa Civil Rights Act (ICRA), Iowa Code 216 et seq. Because plaintiff was unable to perform the essential functions of her position, with or without reasonable accommodation, she failed to make a prima facie showing of discrimination under the ADA. Accordingly, the court affirmed the judgment of the district court. View "Kallail v. Alliant Energy" on Justia Law

Plaintiff sustained injuries while riding in a locomotive operated by his employer, BNSF. Plaintiff brought suit seeking compensation under the Federal Employer's Liability Act (FELA), 45 U.S.C. 51 et seq. The district court concluded that relevant regulations promulgated under the Federal Safety Act (FRSA), 49 U.S.C. 20101 et seq., provided the sole duty of care owed to plaintiff in relation to his claim. The district court ruled that plaintiff had not demonstrated a failure to comply with the relevant regulations and that plaintiff had therefore failed to establish a breach in BNSF's duty of care under the FELA, and therefore granted summary judgment for BNSF. Because the district court granted summary judgment on an issue not raised or discussed by either party, the court reversed and remanded for further proceedings. The court also reversed in part the district court's order excluding expert testimony, because BNSF had not met its burden of showing that FRSA regulations substantially subsumed plaintiff's claim. The court affirmed that order in part because the district court correctly excluded other portions of the expert's testimony as prohibited by Rule 47 of the Federal Rules of Evidence. View "Cowden v. BNSF Railway Co." on Justia Law