Justia U.S. 3rd Circuit Court of Appeals Opinion Summaries

Plaintiffs Tommy Coleman and Jason Perkins, who worked as oil and gas pipeline inspectors for System One Holdings, LLC, were paid a flat daily rate without overtime compensation, even when working over forty hours a week. They filed a lawsuit claiming this violated the Fair Labor Standards Act (FLSA) and sought unpaid overtime on behalf of themselves and a putative class of similarly compensated inspectors.The United States District Court for the Western District of Pennsylvania reviewed the case. System One moved to dismiss and compel arbitration, arguing that the plaintiffs had signed arbitration agreements enforceable under the Federal Arbitration Act (FAA). The plaintiffs countered that they fell under the transportation workers' exemption to the FAA. The District Court, following the precedent set in Guidotti v. Legal Helpers Debt Resolution, L.L.C., ordered limited discovery into the arbitrability of the claims before deciding on the motion to compel arbitration. System One's motion for reconsideration of this order was denied.The United States Court of Appeals for the Third Circuit reviewed the case to determine if it had jurisdiction over the interlocutory appeal from the District Court's order. The Third Circuit held that it lacked appellate jurisdiction because the District Court's order did not formally deny the motion to compel arbitration but rather deferred its decision pending limited discovery. The court emphasized that the FAA permits appeals from specific types of orders, and the order in question did not fall within those categories. Consequently, the appeal was dismissed for lack of jurisdiction. View "Coleman v. System One Holdings LLC" on Justia Law

Timothy Mullins, a coal miner, suffered an ankle stress fracture in 2015 while working as a Section Supervisor at a coal mine owned by CONSOL Energy, Inc. He initially received long-term disability benefits under CONSOL's ERISA-governed Long-Term Disability Plan, administered by Lincoln Financial Group. However, his benefits were terminated in 2020 after Lincoln determined, based on medical evaluations and a vocational assessment, that Mullins did not demonstrate "total disability" as required under the Plan. Lincoln's decision was based on a vocational report that incorrectly listed Mullins's job as "Mine Superintendent" rather than Section Supervisor.The United States District Court for the Western District of Pennsylvania upheld Lincoln's decision to terminate Mullins's benefits, granting summary judgment in favor of the Plan. The District Court found that Lincoln's decision was supported by substantial medical and vocational evidence and was not arbitrary and capricious. Mullins appealed the decision, arguing that Lincoln's reliance on the incorrect job title in the vocational report led to an erroneous termination of his benefits.The United States Court of Appeals for the Third Circuit reviewed the case and found that Lincoln's reliance on the incorrect vocational report was arbitrary and capricious. The court noted that the error in the job title led to an incorrect assessment of Mullins's qualifications and experience, which in turn resulted in the wrongful termination of his benefits. The Third Circuit vacated the District Court's judgment and remanded the case for reinstatement of Mullins's long-term disability benefits. The court also instructed the District Court to consider Mullins's claim regarding the improper offset of benefits due to Social Security disability benefits. View "Mullins v. Consol Energy Inc Long Term Disability Plan" on Justia Law

Rachel Spivack, an employee at the Philadelphia District Attorney’s Office (DAO), was subject to a COVID-19 vaccine mandate. The DAO denied her request for a religious exemption, leading to her termination. Spivack then sued the City of Philadelphia and District Attorney Lawrence Krasner, alleging that the mandate violated her constitutional right to the free exercise of religion.The United States District Court for the Eastern District of Pennsylvania granted summary judgment in favor of the defendants, holding that the vaccine mandate was neutral and generally applicable, thus subject to rational basis review. The court found that the mandate was rationally related to the DAO’s interests in curtailing the spread of COVID-19, avoiding staffing shortages, and reducing the risk of death and serious illness among DAO staff and the public. The court also held that the mandate satisfied strict scrutiny as an alternative ruling. Spivack appealed the decision.The United States Court of Appeals for the Third Circuit reviewed the case and found that there were disputes of material fact that needed to be resolved by a jury. Specifically, the court noted that it was unclear whether Spivack’s exemption request was evaluated under the August 2021 policy, which allowed for individualized, discretionary religious exemptions, or the January 2022 policy, which categorically denied religious exemptions. Additionally, the court found that comments made by Krasner during his deposition could be interpreted as showing hostility toward religious beliefs, which would undermine the neutrality of the policy.The Third Circuit vacated the District Court’s order and remanded the case for trial, instructing that a jury must resolve these factual disputes to determine the applicable standard of scrutiny. If the policy is found to be neutral and generally applicable, it would be subject to rational basis review. If not, it would be subject to strict scrutiny. View "Spivack v. City of Philadelphia" on Justia Law

The New Jersey Staffing Alliance, the American Staffing Association, and the New Jersey Business and Industry Association sought to enjoin a New Jersey law designed to protect temporary workers. The law, known as the Temporary Workers’ Bill of Rights, mandates recordkeeping, disclosure requirements, and state certification procedures for staffing firms. It also imposes joint and several liability on clients hiring temporary workers and requires staffing firms to pay temporary workers wages equivalent to those of permanent employees performing similar work.The United States District Court for the District of New Jersey denied the preliminary injunction, concluding that the Staffing Associations were unlikely to succeed on the merits of their claims. The court found that the law did not discriminate against out-of-state businesses, as it imposed the same burdens on both in-state and out-of-state firms. The court also rejected the void-for-vagueness claim, reasoning that the law provided sufficient guidance on its requirements. Additionally, the court determined that the law was a reasonable exercise of New Jersey’s police power, as it was rationally related to the legitimate state interest of protecting temporary workers.The United States Court of Appeals for the Third Circuit affirmed the District Court’s decision. The Third Circuit agreed that the Staffing Associations failed to show a likelihood of success on their claims. The court held that the law did not violate the dormant Commerce Clause, as it did not favor in-state businesses over out-of-state competitors. The court also found that the law was not unconstitutionally vague, as it provided adequate notice of its requirements. Finally, the court upheld the law as a permissible exercise of state police power, as it was rationally related to the goal of protecting temporary workers. View "New Jersey Staffing Alliance v. Fais" on Justia Law

Cephia Hayes, an employee of the New Jersey Department of Human Services (NJDHS) since 2004, alleged that her supervisor began sexually harassing her in 2016 and retaliated against her when she rebuffed his advances. In October 2019, Hayes filed a charge of discrimination with the Equal Employment Opportunity Commission (EEOC). The EEOC decided not to pursue her case and communicated this decision to Hayes's lawyer via email on March 11, 2020, stating that a right-to-sue letter would be issued. The EEOC also posted the right-to-sue letter to its online portal on the same day.The United States District Court for the District of New Jersey granted summary judgment in favor of NJDHS, ruling that Hayes's Title VII claims were time-barred. The court determined that the 90-day filing period began either when the EEOC emailed Hayes's lawyer or when the right-to-sue letter was posted to the EEOC's online portal. Consequently, the court found that Hayes's lawsuit, filed on November 24, 2020, was untimely.The United States Court of Appeals for the Third Circuit reviewed the case and vacated the District Court's decision. The Third Circuit held that the March 11 email from the EEOC to Hayes's lawyer did not start the 90-day clock because it was not equivalent to a right-to-sue letter. The court also ruled that the posting of the right-to-sue letter to the EEOC's online portal did not suffice to start the 90-day period without direct communication to Hayes or her lawyer. The court found that Hayes had presented sufficient evidence to rebut the presumption that she received the right-to-sue letter three days after it was mailed, creating a genuine issue of material fact regarding the timeliness of her lawsuit. The case was remanded for further proceedings. View "Hayes v. New Jersey Department of Human Services" on Justia Law

In 2019, several college athletes from NCAA Division I schools filed a complaint alleging violations of the Fair Labor Standards Act (FLSA) and various state wage laws. They argued that they were entitled to federal minimum wage compensation for the time spent representing their schools in sports. The NCAA and member schools moved to dismiss the complaint, asserting that the athletes, as "amateurs," were not considered employees. The District Court denied the motion to dismiss, finding that the athletes had sufficiently pleaded facts that might allow them to be classified as employees under the FLSA.The United States District Court for the Eastern District of Pennsylvania applied the multifactor test from Glatt v. Fox Searchlight Pictures, Inc., to determine whether the athletes could be considered employees. The court concluded that the athletes had plausibly pleaded that they might be employees and denied the motion to dismiss. The NCAA and member schools appealed, and the District Court certified an interlocutory appeal to the United States Court of Appeals for the Third Circuit.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed in part the District Court’s decision denying the motion to dismiss. However, the Third Circuit vacated the District Court’s application of the Glatt test, directing it to apply an economic realities analysis grounded in common-law agency principles. The Third Circuit held that college athletes might be employees under the FLSA if they perform services for another party, primarily for that party’s benefit, under that party’s control, and in return for compensation or in-kind benefits. The court also rejected the argument that the tradition of amateurism alone could bar athletes from asserting FLSA claims. The case was remanded for further proceedings consistent with this opinion. View "Johnson v. The National Collegiate Athletic Association" on Justia Law

Allied Painting & Decorating, Inc. withdrew from the International Painters and Allied Trades Industry Pension Fund in 2005. Twelve years later, the Fund demanded $427,195 from Allied, claiming it was owed for the withdrawal. The key issue was whether the Fund's delay in sending the demand violated the Multiemployer Pension Plan Amendments Act of 1980 (MPPAA), which requires that such demands be made "as soon as practicable" after withdrawal.The United States District Court for the District of New Jersey reviewed the case after Allied contested the demand, arguing that the delay caused significant prejudice. The Arbitrator initially found that the Fund did not act "as soon as practicable" but concluded that Allied failed to prove severe prejudice, thus rejecting Allied's laches defense. The District Court, however, found that Allied was prejudiced by the delay and vacated the Arbitrator's Award.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's order vacating the Arbitrator's Award. The Third Circuit held that the Fund's failure to send the demand "as soon as practicable" after Allied's withdrawal violated the MPPAA. The court clarified that the "as soon as practicable" requirement is a statutory mandate independent of any laches defense, meaning that the Fund's delay alone was sufficient to invalidate the demand, regardless of whether Allied could prove prejudice. Consequently, the Fund could not recover the claimed withdrawal liability from Allied. View "Allied Painting & Decorating Inc v. International Painters and Allied Trades Industry Pension" on Justia Law

StoneMor, Inc. operates cemeteries and funeral homes, with maintenance workers at two cemeteries unionized under the International Brotherhood of Teamsters, Local 469. The Union and StoneMor negotiated a collective bargaining agreement (the "Agreement"), which was ratified on October 5, 2020. The Agreement included a grievance procedure requiring the Union to file grievances within ten days of a dispute. After ratification, StoneMor sent drafts of the Agreement with a clarified wage provision, which the Union contested. The Union did not file a grievance until January 5, 2021, after the Agreement was executed on December 29, 2020.The United States District Court for the District of New Jersey reviewed the case and vacated the arbitrator's award. The District Court held that the Agreement was enforceable upon ratification on October 5, 2020, and that the grievance provision was triggered by October 30, 2020, when paychecks were issued without the salary increase. The court found that the arbitrator's decision, which allowed the Union to wait until January to file a grievance, was contrary to the Agreement's plain meaning.The United States Court of Appeals for the Third Circuit reviewed the case and affirmed the District Court's judgment. The Third Circuit held that the arbitrator exceeded her powers by disregarding the Agreement's clear terms, which made the Agreement binding upon ratification. The court emphasized that the grievance procedure was mandatory from the ratification date, and the arbitrator's decision to allow a delay in filing the grievance was not supported by the Agreement. The court concluded that the arbitration award reflected a manifest disregard of the Agreement and was correctly vacated. View "Stonemor Inc v. International Brotherhood of Teamsters Local 469" on Justia Law

Samantha Peifer, an employee of the Pennsylvania Board of Probation and Parole, filed a lawsuit against her employer alleging pregnancy discrimination and retaliation under Title VII of the Civil Rights Act of 1964 and the Pregnancy Discrimination Act. Peifer, who was diagnosed with multiple sclerosis and later became pregnant, requested accommodations from her employer due to her inability to perform certain tasks. Her requests were initially denied, but later granted after she filed a charge with the Equal Employment Opportunity Commission (EEOC). However, she was not allowed to work from home as requested due to her high-risk pregnancy and exposure to COVID-19. Peifer eventually resigned, citing discriminatory treatment, and filed additional charges with the EEOC.The United States District Court for the Eastern District of Pennsylvania granted the Board's motion for summary judgment, concluding that Peifer could not establish a prima facie case for any of her claims. Peifer appealed this decision.The United States Court of Appeals for the Third Circuit affirmed in part and vacated in part the District Court's decision. The Court of Appeals agreed with the lower court that Peifer's claims partly failed but concluded that the District Court was best situated to analyze the impact of the Supreme Court’s recent holding in Muldrow v. City of St. Louis on whether Peifer makes out a prima facie case under an adverse employment action theory. The Court of Appeals also concluded that Peifer makes out a prima facie case of pregnancy discrimination based on the Board’s denials of her light-duty requests under a failure to accommodate theory. The case was remanded for further analysis on Peifer’s adverse employment theory and failure to accommodate theory, while the District Court’s decisions on Peifer’s constructive discharge allegation and retaliation claim were affirmed. View "Peifer v. Pennsylvania Board of Probation and Parole" on Justia Law

The case involves two American Airlines pilots, James P. Scanlan and Carla Riner, who sued their employer for failing to pay them and provide certain benefits while they were on short-term military leave. They claimed that the airline violated the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA), which provides employees on military leave the right to receive the same employment benefits as other similarly situated employees. They also claimed that the airline breached their profit-sharing plan by failing to account for imputed earnings during periods of military leave.The District Court granted summary judgment for the airline on all claims. It held that the pilots could not prevail on their USERRA claims because short-term military leave is not comparable to jury-duty or bereavement leave when comparing duration, frequency, control, and purpose. It also concluded that, under Texas law, the profit-sharing plan unambiguously excludes imputed income from periods of military leave.The United States Court of Appeals for the Third Circuit affirmed the judgment for the airline on the breach of contract claim. However, it reversed the judgment for the airline on the USERRA claims, stating that a reasonable jury could find that short-term military leave is comparable to jury-duty leave or bereavement leave based on the three factors mentioned in the implementing regulation, and any other factors it may consider. The case was remanded for further proceedings on the USERRA claims. View "Scanlan v. American Airlines Group Inc." on Justia Law