Justia Class Action Opinion Summaries

Plaintiffs, on behalf of a purported class of similarly situated employees, appealed from the district court's dismissal of their claims under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., the Racketeer Influenced and Corrupt Organizations Act (RICO), 18 U.S.C. 1961-1968, and the New York Labor Law (NYLL), NYLL 663(1). Plaintiffs alleged that CHS failed to compensate them adequately for time worked during meal breaks, before and after scheduled shifts, and during required training sessions. The court affirmed the dismissal of the FLSA and RICO claims for failure to state a claim. The court affirmed the dismissal of the NYLL overtime claims, which have the same deficiencies as the FLSA overtime claims. However, because the district court did not explain why plaintiffs' NYLL gap-time claims were dismissed with prejudice, the court vacated that aspect of the judgment and remanded for further consideration. View "Lundy v. Catholic Health System of Long Island Inc." on Justia Law

A class of about 1,600 Minnesota delivery drivers employed by Domino's Pizza alleged that, under Minnesota law, a fixed delivery charge that customers paid Domino's was a gratuity wrongfully withheld from them. The court held that the varied context of the pizza delivery transactions made it unreasonable for some customers to construe the delivery charge as a payment for personal services, thereby preventing one-stroke determination of a classwide question. Therefore, the district court abused its discretion by certifying the class. Accordingly, the court reversed the class certification order and remanded for further proceedings. View "Luiken, et al v. Domino's Pizza, LLC" on Justia Law

Plaintiffs Ronica Tabor and Dacia Gray worked as inside salespeople for Hilti, Inc and Hilti of North America, Inc. After being denied promotions to Account Managers (outside sales), they each filed individual claims for gender discrimination under Title VII and moved to certify a class of all female inside salespersons at Hilti who were denied similar promotions. The district court refused to certify the class and granted summary judgment in favor of Hilti on all claims. Upon review, the Tenth Circuit affirmed the district court's grant of summary judgment as to Tabor's claim for retaliation, and Gray's claim for failure to promote. The Court also affirmed the refusal to certify a class. However, the Tenth Circuit reversed the district court with respect to Tabor's individual claims for failure to promote and disparate impact, and remanded Gray's individual disparate impact claim because the district court did not address that claim in its opinion. View "Tabor, et al v. Hilti, Inc., et al" on Justia Law

Bristol Care appealed the denial of its motion to compel arbitration in a suit initiated by its former employee asserting claims under the Fair Labor Standards Act (FLSA), 29 U.S.C. 201 et seq., and seeking class action certification. Given the absence of any contrary congressional command from the FLSA that a right to engage in class actions overrides the mandate of the Federal Arbitration Act, 9 U.S.C. 3-4, in favor of arbitration, the court held that arbitration agreements containing class waivers were enforceable in claims brought under the FLSA. Because the court concluded that the Mandatory Arbitration Agreement (MAA) signed by the employee and Bristol Care was enforceable, the court reversed the district court's decision and directed the district court to enter an order granting Bristol Care's motion to stay proceedings and compel arbitration. View "Owen v. Bristol Care, Inc." on Justia Law

In 1992 Navistar attempted to reduce its costs for retired employee health and life insurance benefits. Navistar’s retirement benefit plan is a registered employee health benefit plan under the Employee Retirement Income Security Act, 29 U.S.C. § 1001 and Navistar is both plan administrator and fiduciary. In 1993, the district court entered judgment in a class action challenging the change, adopting an agreement between the parties and retaining jurisdiction. The Agreement established the Retiree Health Benefit and Life Insurance Plan. The Plan established the Health Benefit Program Summary Plan Description, which contains a description of the health benefits and is furnished to all beneficiaries. The Agreement divides health benefits into two plans: Plan 2 for those eligible for Medicare and Plan 1 for those who are not eligible. A prescription drug benefit was provided under the Agreement, identical for both Plan 1 and Plan 2. When Navistar moved to substitute Medicare Part D into the Plan, class members claimed violation of the Agreement. The district court ordered Navistar to reinstate, retroactively, the prescription drug benefit that was in effect before Navistar made the unilateral substitution. The Sixth Circuit affirmed,View "Shy v. Navistar Int'l Corp." on Justia Law

Cintas’s SSRs drive trucks to deliver products and act as sales representatives, providing customer service, pitching sales, and collecting payments. Serrano, a female, unsuccessfully applied for a position as an SSR and filed a discrimination charge with the EEOC in 2000. In 2002, after investigating Serrano’s claims and expanding the investigation to include Cintas’s female hiring practices throughout Michigan, the EEOC issued a reasonable-cause determination and sent a proposed conciliation agreement to Cintas suggesting that relief be provided to Serrano, 111 other specified women, and an unspecified number of “other similarly situated females.” Cintas did not respond. In 2005, the EEOC notified Cintas that it was terminating conciliation efforts. In 2004, Serrano filed a Title VII class-action complaint, in which the EEOC intervened. In 2008, the district court denied nationwide class certification. By April 2010, all individual plaintiffs, save Serrano, had their cases resolved. In 2009 the EEOC filed an amended complaint, limiting its allegations to “a class of women in the State of Michigan” The district court granted Cintas’s judgment on 13 individual and “pattern or practice” claims, denying the EEOC’s discovery motions, and awarding costs and fees. The Sixth Circuit vacated and remanded View "Serrano v. Cintas Corp." on Justia Law

White was an emergency department nurse for Baptist 2005-2007. She did not have a regularly scheduled meal break; breaks occurred as work allowed. White received a copy of Baptist’s employee handbook, which stated that an unpaid meal break would be automatically deducted from their pay checks and that if a meal break was missed or interrupted because of work, the employee would be compensated. Employees were to record time spent working during meal breaks in an “exception log.” White signed a document concerning the policy and recorded occasions where her meal break was interrupted. She claims that if her entire unit missed a break, she was compensated, but that if she individually missed breaks she was sometimes not compensated. She never told her supervisors or human resources that she was not. Eventually, White stopped using the exception log. White knew Baptist’s procedure to report and correct payroll errors, but did not utilize this procedure to correct the unreported interrupted meal break errors because she felt it would be “an uphill battle.” White filed suit, alleging violations of the Fair Labor Standards Act, 29 U.S.C. 201. The district court granted Baptist summary judgment and class decertification. The Sixth Circuit affirmed. View "White v. Baptist Mem'l Health Care Corp." on Justia Law

While employed at PPG, plaintiffs were represented by three labor unions. In 2001 PPG modified health benefits for retirees, requiring that retirees pay a portion of the cost. The unions thought the modification was a breach of collective bargaining agreements and sued, requesting that the Pennsylvania district court order PPG to arbitrate the benefit dispute with the unions. The district court entered judgment for PPG, holding that the benefits had not vested. The Third Circuit affirmed. Meanwhile, in 2005, more than a year before the district court entered judgment, several individual retirees filed a putative class action in the Southern District of Ohio. Their core allegation was identical to that in the Pennsylvania action; they asserted claims under the Labor Management Relations Act and ERISA and sought monetary damages and an injunction ordering reinstatement of full coverage. The district court held that the Pennsylvania judgment collaterally estopped the plaintiffs from arguing the contrary in this case. The Sixth Circuit reversed. The district court in the Pennsylvania action neither certified a class nor employed any other “special procedures” to protect the retirees’ interests in that action, so the plaintiffs are not bound to that decision. View "Amos v. PPG Indus., Inc." on Justia Law

In this case a corporation abruptly cashiered a member of senior management, which prompted the employee to file suit for age discrimination and retaliation. After a protracted trial, the jury found the employer guilty of retaliation and returned a seven-figure verdict in the employee's favor. The district court allowed the liability finding to stand, trimmed the damages but doubled what remained, refused to grant either judgment notwithstanding the verdict or an unconditional new trial, and awarded the prevailing plaintiff attorneys' fees and an equitable remedy. The First Circuit Court of Appeals affirmed the judgment below except vacated the previously remitted award of emotional distress damages and directed the district court to order the plaintiff either to remit all of that award in excess of $200,000 or else undergo a new trial on that issue. The Court also directed the district court to adjust its award of multiplied damages to reflect the plaintiff's response to this remittitur. View "Trainor v. HEI Hospitality, LLC" on Justia Law

In 2005 brokers sued Merrill Lynch under 42 U.S.C. 1981 and Title VII raising claims of racial discrimination and seeking to litigate as a class. They alleged that the firm’s “teaming” and account-distribution policies had the effect of steering black brokers away from the most lucrative assignments and prevented them from earning compensation comparable to white brokers. That litigation is ongoing. Three years later, Bank of America acquired Merrill Lynch, and the companies introduced a retention-incentive program that would pay bonuses to Merrill Lynch brokers corresponding to their previous levels of production. Brokers filed a second class-action suit. The district court dismissed. The court held that the retention program qualified as a production-based compensation system within the meaning of the section 703(h) exemption and was protected from challenge unless it was adopted with “intention to discriminate because of race.” 42 U.S.C. 2000e-2(h). The court then held that the complaint’s allegations of discriminatory intent were conclusory. The Seventh Circuit affirmed. It is not enough to allege that the bonuses incorporated the past discriminatory effects of Merrill Lynch’s underlying employment practices. The disparate impact of those employment practices is the subject of the first lawsuit, and if proven, will be remedied there. View "McReynolds v. Merrill Lynch & Co. Inc." on Justia Law