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

Plaintiff and 19 other employees represent a class of hourly production employees at a meat-processing facility of Tyson Foods. The employees sued Tyson for not paying wages due under the Fair Labor Standards Act of 1938 (FLSA), 29 U.S.C. 201 et seq., and the Nebraska Wage Payment and Collection Act (NWPCA), Neb. Rev. Stat. 48-1228 et seq. At issue was the calculation of the employees' compensable work time where Tyson measured "gang time" - when the employees were at their working stations and the production line was moving. The employees claimed that Tyson failed to provide FLSA overtime compensation for donning personal protective equipment (PPE) and clothing before production and again after lunch, and for doffing PPE and clothing before lunch and again after production. The court held that the employees waived some of their claims and the district court did not err in instructing the jury or in its evidentiary findings. View "Lopez, et al. v. Tyson Foods, Inc." on Justia Law

Plaintiff sued his employer, Trinity, alleging that Trinity discriminated against him on the basis of his son's disabilities, in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101 et seq. He also alleged a violation of his rights under the Family Medical Leave Act (FMLA), 29 U.S.C. 2601 et seq. The court affirmed the district court's grant of summary judgment, holding that the district court did not err in applying the honest belief rule; plaintiff failed to show that his termination was based on pretext or a discriminatory motive; and plaintiff failed to present sufficient evidence of an FMLA violation. Trinity proffered a legitimate nondiscriminatory reason for the termination - it believed that plaintiff violated company policy by encouraging a work slowdown - and plaintiff presented insufficient evidence to show that the explanation was pretextual. View "Pulczinski v. Trinity Structural Towers" on Justia Law

Warren Unilube petitioned for review of an order of the NLRB that directed the company to recognize and bargain with the Union. The NLRB cross-applied for enforcement of its order. The court held that there was substantial evidence to support the NLRB's determination that the Union's unfair labor practice charge was not baseless or frivolous. The court also held that the NLRB properly denied the company's objections without a hearing where, in considering objections, the Regional Director could act on the basis of an investigation or upon the record of a hearing. Accordingly, the court denied the petition for review and enforced the NLRB's order. View "Warren Unilube, Inc. v. NLRB" on Justia Law

The Union attempted to commence arbitration of a terminated employee's grievance. Before arbitration proceedings commenced, the employee died, and the employer refused to proceed with arbitration. The Union brought this suit to compel arbitration. The district court found that the employer did not agree to arbitrate claims of a deceased employee and dismissed the case. The court reversed and held that the parties agreed to mandatory arbitration of the employee's claim and no legal principal deprived the Union of power to enforce that agreement. View "Sheet Metal Workers, etc. v. Silgan Containers, etc." on Justia Law

Plaintiff brought suit against Seagate, alleging a violation of Minnesota Statutes section 181.64, false statements as inducement to entering employment, and a common law claim of promissory estoppel. On appeal, Seagate argued, among other things, that the district court submitted an erroneous jury instruction. Plaintiff cross-appealed, arguing that if a new trial was ordered on the statutory claim, his promissory estoppel claim should likewise be retried. The court concluded that the district court erred in instructing the jury, and thus the court reversed. The court vacated the order dismissing the promissory estoppel claim and remanded for a new trial on both claims. The court also vacated the order granting attorneys' fees. View "Vaidyanathan v. Seagate US LLC, et al." on Justia Law

David Fesler, a former sales representative with Whelen Engineering Company, sued Whelen for breach of contract. Fesler alleging that he was an employee of Whelen, that policy documents issued by Whelen applicable to sales representatives created a unilateral contract of employment, and that Whelen breached that unilateral contract of employment by terminating him without just cause and by failing to provide him with notice of substandard performance and an opportunity to cure. The district court granted summary judgment for Whelen. The Eighth Circuit Court of Appeals affirmed, holding that because Fesler was an independent contractor and not an employee, the policy documents could not have created a unilateral contract. Thus, the district court properly dismissed Fesler's claim for breach of contract. View "Fesler v. Whelen Eng'g Co." on Justia Law

Southeast Technical Institute (STI) in South Dakota is a public post-secondary technical school funded by the State through Sioux Falls School District No. 49-5 and governed by the Sioux Falls School Board. STI terminated Registrar Matt Onnen for awarding degrees to students who had not earned them, not awarding degrees when students had earned them, and failing to verify students for graduation. Meanwhile, Onnen filed a qui tam complaint against the school district, its superintendent, and the school board members, alleging that Defendants violated the False Claims Act (FCA) by knowingly submitting false or fraudulent claims to the federal government for student grants and guaranteed loans. Onnen did not sue STI or any STI employee. The district court granted summary judgment for Defendants. The Eighth Circuit Court of Appeals affirmed, holding the district court did not err in concluding Onnen's affidavit was insufficient to prove that any defendant committed a knowing violation of the FCA. Therefore, summary judgment was appropriate. View "United States ex rel. Onnen v. Sioux Falls Indep. Sch. Dist." on Justia Law

The United Automobile, Aerospace, and Agricultural Implement Workers International Union and Local 997 appealed the district court judgment after a five-day bench trial declaring that Whirlpool Corporation may unilaterally modify the health care benefits it provided to retired hourly workers previously employed at the Newton, Iowa manufacturing facilities of Whirlpool's now-dissolved subsidiary, Maytag Corporation. The Eighth Circuit Court of Appeals affirmed, holding (1) the district court correctly found that a case or controversy existed when Whirlpool filed its declaratory judgment action; and (2) the retirees did not have a vested right to the previously granted health benefits under ERISA, as the benefits were provided in a collectively bargained agreement that had no express vesting provision. View "Maytag Corp. v. Int'l Union" on Justia Law

The Laborers District Council of Minnesota and North Dakota (the Union) petitioned for review of a decision of the National Labor Relations Board ordering the Union to cease and desist violating section 8(b)(4)(ii)(B) of the National Labor Relations Act by coercing Lake Area Fence, a newly formed commercial fencing subcontractor, not to do fence installation work for Century Fence Company, a nonunion contractor. The Eighth Circuit Court of Appeals denied the petition for review and granted the Board's cross-petition to enforce its decision and order, holding that the Board's decision was a reasonable construction of the statute and was supported by substantial evidence on the administrative record as a whole. View "Laborers Dist. Council v. NLRB" on Justia Law

Plaintiff sued the County of Dakota, Nebraska, and former sheriff's deputy Rodney Herron, alleging Title VII violations, sexual harassment, and violation of the Equal Pay Act. The County advanced a limited offer to settle the Title VII and Equal Pay Act claims, which Plaintiff accepted. Plaintiff then sought an award of attorney's fees on the partial judgment, and the district court ultimately awarded $24,500 in attorney's fees to Williams in two separate orders. The district court certified its orders as final judgments under Fed. R. Civ. P. 54(b) so as to allow for an interlocutory appeal. Defendants appealed. The Eighth Circuit Court of Appeals dismissed the appeal for lack of jurisdiction, holding that the district court abused its discretion by entering final judgment under Rule 54(b). View "Williams v. County of Dakota" on Justia Law