Justia U.S. 6th Circuit Court of Appeals Opinion Summaries

Daniel Paris, an employee of MacAllister Machinery Company and member of the International Union of Operating Engineers, Local 324, was terminated following a series of disciplinary issues, including performance deficiencies, attendance problems, and violations of company policy. After signing a “last chance” agreement, Paris’s employment was terminated when he violated its terms. Paris claimed he was discriminated against due to his union affiliation and age, and that he was subjected to harsher scrutiny than his peers. He also alleged that after reporting harassment and requesting information about taking leave for mental health issues, he was not properly supported by the Union and ultimately lost his job.Following his termination, Paris filed suit in the United States District Court for the Eastern District of Michigan, asserting claims under the Family and Medical Leave Act (FMLA), the Labor Management Relations Act (LMRA), and the Michigan Elliott-Larsen Civil Rights Act (ELCRA) against both MacAllister and the Union. The district court dismissed the LMRA claims against both defendants for failure to state a claim, finding Paris had not plausibly alleged that the Union breached its duty of fair representation. The court also declined to exercise supplemental jurisdiction over the ELCRA claims. After discovery, the district court granted summary judgment for MacAllister on the remaining FMLA claims.The United States Court of Appeals for the Sixth Circuit affirmed the district court’s decisions. The court held that Paris failed to establish a “serious health condition” under the FMLA because he did not seek treatment or provide required documentation. While it concluded that Paris’s inquiry about FMLA leave was a protected activity, it found MacAllister had legitimate, nondiscriminatory reasons for his termination, unconnected to FMLA retaliation or interference. The appellate court also affirmed dismissal of the LMRA claims, finding Paris did not plausibly allege breach of the Union’s duty or properly preserve related arguments on appeal. View "Paris v. MacAllister Machinery Co." on Justia Law

An art teacher with progressive hearing and vision loss, caused by Usher syndrome, sought approval from her Ohio school district to use paid sick leave for a mandatory three-week out-of-state training course required to obtain a guide dog. The district denied her request for paid leave, reasoning that the training did not qualify as “personal illness” under its sick-leave policy, but allowed her to take unpaid leave as an accommodation under the Americans with Disabilities Act (ADA). She attended the training using unpaid leave, obtained the guide dog, and then, after unsuccessful further communication with the district, brought suit alleging violations of the ADA and the Family and Medical Leave Act (FMLA).The United States District Court for the Southern District of Ohio granted summary judgment for the school district. The court found that her ADA disparate treatment claim failed due to a lack of evidence that nondisabled employees were treated more favorably in similar circumstances. The court also found that the district’s offer of unpaid leave constituted a reasonable accommodation under the ADA, as the law does not require the employer to provide the employee’s preferred accommodation if another reasonable one is offered. Regarding the FMLA claim, the district court concluded that paid sick leave was not required because the school district would not “normally” provide paid sick leave for this type of absence under its policy.The United States Court of Appeals for the Sixth Circuit affirmed. It held that the plaintiff could not prevail on her ADA disparate treatment claim because she failed to show that similarly situated nondisabled employees received paid sick leave for comparable non-illness-related absences. Her failure-to-accommodate claim failed because unpaid leave was a reasonable accommodation, and the ADA does not mandate provision of the employee’s preferred form of leave. The FMLA claim failed because the district’s policy did not normally allow paid sick leave for guide dog training, and the plaintiff did not sufficiently challenge the district court’s interpretation of the policy. View "Tumbleson v. Lakota Local Sch. Dist." on Justia Law

The plaintiff worked as a Project Director and participated in her employer’s long-term disability (LTD) plan, which was administered by Matrix Absence Management on behalf of the Federal Reserve Bank of Cleveland. After taking leave due to ongoing symptoms from long-haul COVID-19, the plaintiff applied for LTD benefits under the plan, which required proof of total disability. Matrix reviewed the medical evidence—including opinions from both treating and independent physicians—and denied her claim, concluding that as of her leave date, she was not totally disabled under the plan’s terms. The plaintiff appealed this denial, but Matrix upheld its decision after additional review.The United States District Court for the Northern District of Ohio heard the plaintiff’s subsequent lawsuit against the Bank, Matrix, and the plan, asserting breach of contract and breach of fiduciary duty. The district court denied the plaintiff’s requests for discovery beyond the administrative record and granted judgment on the administrative record in favor of the defendants. The court found that New York contract law, not ERISA, applied, and review was limited to whether Matrix’s decision was arbitrary, made in bad faith, or the result of fraud, given the plan’s broad delegation of discretionary authority to Matrix.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the district court correctly applied New York contract law and the arbitrary-and-capricious standard of review. The appellate court found no abuse of discretion in denying discovery beyond the administrative record, as the plaintiff did not establish a colorable claim of conflict of interest or procedural defect. The Sixth Circuit concluded that Matrix’s denial had a reasonable basis in the administrative record and thus was not arbitrary or capricious. The judgment for the defendants was affirmed. View "Martin v. Fed. Rsrv. Bank of Cleveland" on Justia Law

A community hospital in western Michigan, previously operating under a different name, was acquired by a nationwide health system in June 2022. The hospital’s collective bargaining agreement with its employee union expired shortly before the acquisition, and the union affiliated with the SEIU. Negotiations for a new contract stalled, and an employee, Jamie Quinn, initiated a decertification petition to remove the union. After sufficient signatures were gathered, a formal decertification election was held in September 2023. The union attempted to block the ballot count with pending unfair labor practice charges, but eventually withdrew the blocking request. The next day, Quinn submitted a “disaffection petition” to hospital management, claiming majority support for removing the union, though the petition had multiple defects. Despite these issues, hospital management immediately withdrew recognition from the union, but the official election results, announced soon after, showed the union still had majority support.The National Labor Relations Board’s Regional Director filed a formal complaint against the hospital for unfair labor practices. An Administrative Law Judge found the hospital’s withdrawal of recognition unjustified, citing the petition’s defects and lack of objective evidence. The Board certified the union as the bargaining representative. While the Board’s review was pending, the Regional Director petitioned the United States District Court for the Western District of Michigan for a preliminary injunction under § 10(j) of the NLRA. The district court granted the injunction, ordering the hospital to resume bargaining with the union.The United States Court of Appeals for the Sixth Circuit reviewed the district court’s decision. While agreeing that the Director was likely to succeed on the merits, the appellate court found that the Director failed to show a clear likelihood of irreparable harm as required by Supreme Court precedent. The Sixth Circuit reversed the district court and vacated the injunction, holding that a § 10(j) injunction requires a clear showing of irreparable harm, which was not demonstrated here. View "Kerwin v. Trinity Health Grand Haven Hosp." on Justia Law

A construction company with a longstanding union relationship entered into negotiations for a new collective bargaining agreement in 2018, following the union’s withdrawal from a multiemployer contract. This led to protracted disputes, including strikes, litigation, and unfair labor practice charges. Amid negotiations, some employees sought to decertify the union, but the National Labor Relations Board (NLRB) dismissed these decertification petitions, finding a causal nexus between the company's alleged unfair labor practices and employee dissatisfaction. During ongoing litigation, the company unilaterally raised employee wages in 2021 and 2022 without bargaining with the union, then later refused to bargain with the union or provide requested information, instead claiming a right to judicial review of the decertification petition dismissals.Administrative proceedings before an Administrative Law Judge (ALJ) resulted in findings that the company had committed several unfair labor practices: granting unilateral wage increases, withdrawing recognition from the union, refusing to bargain, and failing to provide information. The ALJ ordered the company to recognize and bargain with the union, cease unfair labor practices, and provide the requested information. The NLRB affirmed these findings and the remedial order.The United States Court of Appeals for the Sixth Circuit reviewed the case, applying de novo review to legal conclusions and substantial evidence review to factual findings. The court held that the company failed to prove the union waived its right to bargain over wage increases, that the company's actions constituted an unlawful withdrawal of union recognition, and that the refusal to bargain and provide information were not justified as a “technical refusal to bargain” because the decertification petition dismissals did not alter the company's bargaining obligations. The court denied the company’s petition for review and enforced the NLRB’s order. View "Rieth-Riley Constr. Co., Inc. v. NLRB" on Justia Law

A construction company operating in Michigan employed operating engineers represented by a union. Since at least 1993, collective bargaining occurred through a multiemployer association. In early 2018, with the expiration of their collective bargaining agreement approaching, the union gave notice that it wished to withdraw from multiemployer bargaining in order to negotiate individual contracts with employers, including the company at issue. Tensions rose when the company unilaterally stopped making benefit contributions, gave wage increases, and later sought to recover those payments directly from employees, all without bargaining with the union. The employer also participated in a lockout after the union refused to bargain on a multiemployer basis. Subsequently, the union organized a strike, citing the employer’s alleged unfair labor practices.An administrative law judge for the National Labor Relations Board (NLRB) found that the union’s withdrawal from multiemployer bargaining was timely and lawful, and that the company committed several unfair labor practices, including the lockout and unilateral changes to wages and benefits. The judge concluded, however, that the strike was economic in nature rather than an unfair labor practice strike. On appeal, the NLRB affirmed most of the administrative law judge’s findings but reversed on the nature of the strike, determining it was motivated at least in part by the company’s unfair labor practices. The NLRB issued an order requiring the company to bargain in good faith and temporarily prohibiting decertification attempts.The United States Court of Appeals for the Sixth Circuit reviewed the case. It held that the union’s withdrawal from multiemployer bargaining was timely under Supreme Court and Board precedent, that the company committed unfair labor practices by insisting on multiemployer bargaining, making unilateral wage and benefit changes, and implementing a lockout, and that substantial evidence supported the Board’s conclusion that the 2019 strike was partly an unfair labor practice strike. The court denied the company’s petition for review and granted enforcement of the NLRB’s order. View "Rieth-Riley Constr. Co. v. National Labor Relations Board" on Justia Law

A Tennessee-based commercial bakery, which provides a self-funded health benefits plan governed by ERISA for its employees, structured its prescription drug benefits through a pharmacy benefit manager (PBM) and created an in-house pharmacy offering lower copays to employees. Tennessee enacted laws targeting PBMs, requiring pharmacy network access for any willing provider and prohibiting cost-sharing incentives to steer participants to certain pharmacies, including those owned by the plan sponsor. The bakery and its PBM excluded a pharmacy from their network after an audit, and after the pharmacy filed administrative complaints under the new Tennessee law, the bakery sought declaratory and injunctive relief in federal court, claiming ERISA preempted these PBM-focused state laws.The United States District Court for the Eastern District of Tennessee found that the bakery, as plan fiduciary, had standing to bring a pre-enforcement challenge. The court concluded that the Tennessee PBM laws were preempted by ERISA because they required specific plan structures, governed central aspects of plan administration, and interfered with uniform national plan administration. The district court granted summary judgment in favor of the bakery, permanently enjoining the Tennessee Commissioner from enforcing the PBM laws against the bakery’s health plan or its PBM.On appeal, the United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court agreed with the district court’s analysis, holding that the challenged Tennessee PBM statutes have an impermissible connection with ERISA plans and are therefore preempted. The court found that the laws mandated network structure and cost-sharing provisions, interfering directly with ERISA plan administration. The Sixth Circuit also held that the ERISA saving clause did not preserve these laws from preemption due to the deemer clause’s application to self-funded plans. The judgment of the district court was affirmed. View "McKee Foods Corp. v. BFP Inc." on Justia Law

A construction company and several employee plaintiffs were involved in a labor dispute with a group of union-affiliated fringe benefit funds and their trustees. The company had employed members of a local union and, under a collective bargaining agreement (CBA), was required to contribute to a set of employee benefit funds for each hour worked. When the CBA expired and was mutually terminated, the company and union failed to negotiate a new agreement. The company continued attempting to make contributions to the funds, but the funds’ trustees eventually refused to accept them unless the company provided written confirmation of its agreement to abide by the funds’ governing documents. The company declined, arguing that federal labor law required the funds to continue accepting contributions during negotiations. The funds then stopped accepting contributions, and the company placed the rejected payments into escrow.The company and employees filed suit in the United States District Court for the Eastern District of Michigan, asserting that the funds’ trustees had breached their fiduciary duties under the Employee Retirement Income Security Act (ERISA) by refusing the contributions, and seeking declaratory and injunctive relief. The district court dismissed the complaints, finding that the ERISA claims were preempted by the Garmon doctrine, which generally requires courts to defer to the National Labor Relations Board (NLRB) on matters arguably subject to sections 7 or 8 of the National Labor Relations Act (NLRA). The district court also denied motions for a preliminary injunction and for leave to amend the complaint.On appeal, the United States Court of Appeals for the Sixth Circuit affirmed the district court’s judgment. The Sixth Circuit held that the plaintiffs’ ERISA claims were preempted under the Garmon doctrine because they were inextricably linked to labor law questions subject to the NLRB’s primary jurisdiction. The court also found that the district court properly denied the requests for preliminary injunctive relief and for leave to amend the complaint, as any amendment would have been futile. View "Rieth-Riley Construction Co. v. Operating Engineers Local 324" on Justia Law

Americare Healthcare Services, Inc., a third-party home care provider in Ohio, and its owner, Dilli Adhikari, hired live-in workers—most of whom cared for their own family members—to provide services to elderly or disabled clients. Between October 2018 and October 2021, Americare failed to pay overtime wages to these employees, claiming entitlement to exemptions under the Fair Labor Standards Act (FLSA): the “Companionship Services Exemption” and the “Live-In Exemption.” The Department of Labor, however, had promulgated a 2013 regulation that prohibited third-party employers from relying on these exemptions.The United States District Court for the Southern District of Ohio granted summary judgment to the Department of Labor, finding Americare and Adhikari liable for willful violations of the FLSA’s overtime requirements. The district court further held that the 2013 Third-Party Regulation was valid, and that Americare and Adhikari lacked standing to challenge a related regulatory definition that narrowed the scope of “companionship services.” Americare and Adhikari appealed only the district court’s rulings on the regulation’s validity and their lack of standing.The United States Court of Appeals for the Sixth Circuit reviewed the case, applying the framework for agency rulemaking authority post-Loper Bright Enterprises v. Raimondo. The Sixth Circuit held that the FLSA’s express statutory delegation allowed the Department of Labor to define and delimit the applicability of the companionship and live-in exemptions, including excluding third-party employers from their reach. The court further held that Americare and Adhikari lacked standing to challenge the definition of companionship services because the bar to their use of the exemption arose from the third-party regulation, not from the definition itself. The judgment of the district court was therefore affirmed. View "Department of Labor v. Americare Healthcare Services" on Justia Law

Retired employees of two companies, who participated in their employers’ defined benefit pension plans, brought class action lawsuits alleging violations of the Employee Retirement Income Security Act (ERISA). These plaintiffs, all married, claimed that their plans calculated joint and survivor annuity benefits using mortality tables based on outdated data from the 1960s and 1970s. Because life expectancies have increased since then, the plaintiffs asserted that using such outdated mortality assumptions improperly reduced their benefits, resulting in joint and survivor annuities that were not the actuarial equivalent of the single life annuities to which they would otherwise be entitled, as required by ERISA.Each group of plaintiffs filed suit in federal district court—one in the Eastern District of Michigan against the Kellogg plans and one in the Western District of Tennessee against the FedEx plan—asserting that the use of obsolete actuarial assumptions violated 29 U.S.C. § 1055(d) and constituted a breach of fiduciary duty under ERISA. The district courts in both cases dismissed the complaints for failure to state a claim, holding that ERISA does not require use of any particular mortality table or actuarial assumption in calculating benefits for married participants, and thus the allegations, even if true, did not establish a violation.The United States Court of Appeals for the Sixth Circuit reviewed the dismissals de novo. The court held that, under ERISA’s statutory requirement that joint and survivor annuities be “actuarially equivalent” to single life annuities, plans must use actuarial assumptions, including mortality data, that reasonably reflect the life expectancies of current participants. The court concluded that plaintiffs had plausibly alleged that the use of outdated mortality tables was unreasonable and could violate ERISA. Accordingly, the Sixth Circuit reversed the district courts’ judgments and remanded both cases for further proceedings. View "Reichert v. Kellogg Co." on Justia Law