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

Kirstyn Paige Bashaw was employed as the Director of Social Services at Majestic Care of Whitehall, a skilled nursing home and residential facility in Ohio, from November 2021 until her termination in March 2022. Her role involved managing the Social Service department and attending daily meetings. During her tenure, Bashaw was frequently late or absent without authorization, and she raised concerns about resident care and alleged inappropriate behavior by her manager, Edward Beatrice. Bashaw also secretly recorded work meetings and discussed her intention to leave the job with a Human Resources representative.The United States District Court for the Southern District of Ohio granted summary judgment in favor of Majestic Care, finding that the company had provided three non-pretextual reasons for Bashaw’s termination: her surreptitious recording of work meetings, her attendance issues, and her expressed desire to leave the job. The court did not find it necessary to resolve whether a fourth reason, related to a resident's readmission, was pretextual.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court’s decision. The appellate court held that Majestic Care had legitimate, non-pretextual reasons for terminating Bashaw. Specifically, the court found that Bashaw’s secret recordings undermined trust and posed legal risks, her attendance issues were valid grounds for termination, and Majestic Care reasonably believed she no longer wished to work there. The court concluded that these reasons were sufficient to defeat Bashaw’s retaliation claim under Title VII and Ohio law. View "Bashaw v. Majestic Care of Whitehall" on Justia Law

Larry Smith worked for Newport Utilities for many years, primarily repairing downed powerlines during weather emergencies. He began experiencing seizures, which led to two on-the-job incidents within months. Newport Utilities placed him on leave and later forced him to retire. Smith sued under the Americans with Disabilities Act (ADA), claiming discrimination based on his disability.The United States District Court for the Eastern District of Tennessee granted summary judgment to Newport Utilities, finding that Smith posed a safety threat in his position and that the company could not reasonably accommodate him.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that Smith posed a direct threat of harm to himself and others due to his seizures, which could not be eliminated by reasonable accommodation. The court found that the essential functions of Smith's job as a bucket foreman included working extended hours and being on standby, which Smith could not perform safely. The court also determined that Newport Utilities had investigated potential alternative positions for Smith, but he did not qualify for any of them. The court affirmed the district court's grant of summary judgment to Newport Utilities. View "Smith v. Newport Utilities" on Justia Law

Derek Kramer, the plaintiff, joined American Electric Power Service Corporation (AEP) in 2018 and later participated in the AEP Executive Severance Plan. In 2020, AEP terminated Kramer’s employment due to his executive assistant’s misuse of a company credit card and Kramer’s alleged interference with an investigation into his company-issued cell phone. Kramer applied for severance benefits under the Plan, but AEP denied his claim, citing termination for cause. Kramer appealed the decision, but the Plan’s appeal committee upheld the denial.Kramer then filed an ERISA action in the United States District Court for the Southern District of Ohio, seeking benefits and alleging interference. He also demanded a jury trial. The district court struck his jury demand, limited discovery to procedural claims, and denied his motion to compel the production of documents protected by attorney-client privilege. The court ultimately granted judgment in favor of AEP and the Plan, finding that the denial of benefits was not arbitrary and capricious.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s rulings, holding that the Plan was a top-hat plan exempt from ERISA’s fiduciary requirements, thus the fiduciary exception to attorney-client privilege did not apply. The court also upheld the district court’s decision to strike Kramer’s jury demand, citing precedent that ERISA denial-of-benefits claims are equitable in nature and not subject to jury trials. Finally, the court found that the district court correctly applied the arbitrary-and-capricious standard in reviewing the denial of benefits and that the decision was supported by substantial evidence. The Sixth Circuit affirmed the district court’s judgment in favor of AEP and the Plan. View "Kramer v. American Electric Power Service Corp. Executive Severance Plan" on Justia Law

Broadgate, Inc. employed an H-1B visa holder who filed a complaint with the Department of Labor’s Wage and Hour Division in February 2018, alleging that Broadgate had not paid him the full wages required by the Immigration and Nationality Act. The Division’s investigation substantiated the claim and found additional violations, including failure to post required workplace notices. Consequently, the Division issued a determination letter in December 2018, finding Broadgate had willfully violated the Act, barring it from the H-1B program for two years, requiring payment of back wages, and assessing a civil penalty.Broadgate sought review before an Administrative Law Judge (ALJ), challenging only the determination regarding the workplace notices. The ALJ agreed with Broadgate, vacating the determination. However, the Department’s Administrative Review Board reversed this decision. On remand, Broadgate argued that the Division exceeded its authority by investigating violations not alleged in the original complaint. The ALJ rejected this argument, and the Review Board and the district court affirmed the Director’s imposition of fines and penalties.The United States Court of Appeals for the Sixth Circuit reviewed the case. Broadgate argued that the District Director lacked authority to issue the determination letter and that the Wage and Hour Division exceeded its authority by investigating the notice violations. The court held that the presumption of regularity applied, meaning the Director’s issuance of the letter was presumptive proof of her authority. The court also found that the Division was entitled to investigate the notice violations discovered during the investigation of the wage complaint. The court affirmed the district court’s judgment, rejecting Broadgate’s arguments. View "Broadgate, Inc v. Su" on Justia Law

Randell Shepherd, a career coal miner, filed a claim for benefits under the Black Lung Benefits Act (BLBA), invoking the Act’s presumption that he was entitled to benefits due to his over fifteen years of mining and total disability from chronic obstructive pulmonary disease (COPD), bronchitis, and emphysema. Incoal, Inc., Shepherd’s most recent employer, contested his entitlement, arguing that his disability was caused by smoking, not mining. An administrative law judge (ALJ) found Incoal’s expert opinions unpersuasive and inconsistent with the Act’s regulations and preamble, which recognize pneumoconiosis as a latent and progressive disease. The ALJ ruled that Incoal failed to rebut the presumption that Shepherd was entitled to benefits. The Benefits Review Board (BRB) affirmed the ALJ’s decision.Incoal petitioned the United States Court of Appeals for the Sixth Circuit for review, arguing that the ALJ improperly relied on the regulatory preamble over their evidence and that the presumption was effectively irrebuttable, violating the Constitution and the Administrative Procedure Act (APA). The court reviewed the case de novo, focusing on whether the ALJ’s decision was supported by substantial evidence and correctly applied the law.The Sixth Circuit held that the ALJ was entitled to reference the preamble to assess the credibility of expert opinions and found that the ALJ’s decision was supported by substantial evidence. The court noted that the BLBA’s rebuttable presumption is constitutional, as it is based on a rational relationship between the length of a miner’s career and the risk of pneumoconiosis. The court concluded that Incoal’s arguments were unpersuasive and that the ALJ applied the correct legal principles. Consequently, the court denied Incoal’s petition for review. View "Incoal, Inc. v. OWCP" on Justia Law

Celestia Chapman, a finance manager at Brentlinger Enterprises, requested leave under the Family and Medical Leave Act (FMLA) to care for her terminally ill sister. Her employer denied the request, stating that the FMLA did not cover leave to care for an adult sibling. When Chapman did not show up for work on a scheduled day, she was terminated. Subsequently, Brentlinger Enterprises falsely informed workers' compensation authorities that Chapman had quit and threatened her with Rule 11 sanctions if she pursued an FMLA lawsuit. Chapman sued, alleging violations of the FMLA, the Americans with Disabilities Act (ADA), and other statutes.The United States District Court for the Southern District of Ohio granted summary judgment to Brentlinger Enterprises on all claims except for the COBRA violation, for which it imposed a statutory penalty. Both parties appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court reversed the district court's grant of summary judgment on Chapman's FMLA interference claim, finding that an in loco parentis relationship could form between adults, including siblings, under the FMLA. The court also reversed the summary judgment on Chapman's FMLA retaliation claims related to her termination and the false statements made to the unemployment agency, as well as her ADA and Ohio law associational disability discrimination claims. The court affirmed the summary judgment on the FMLA retaliation claim related to the Rule 11 sanctions letter and upheld the district court's award of $85 per day in statutory penalties for the COBRA violation. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Chapman v. Brentlinger Enterprises" on Justia Law

Five current and former employees of Parker-Hannifin Corporation, representing a class of participants in the Parker Retirement Savings Plan, filed a lawsuit against Parker-Hannifin Corporation and related entities. They alleged that Parker-Hannifin violated the Employee Retirement Income Security Act of 1974 (ERISA) by imprudently retaining the Northern Trust Focus Funds, providing higher-cost shares, and failing to monitor its agents in their fiduciary duties.The United States District Court for the Northern District of Ohio dismissed the plaintiffs' claims. The court found that the plaintiffs did not state a viable claim of breach of fiduciary duty because they failed to identify meaningful benchmarks for comparison, and their evidence of high turnover rates and limited performance history was insufficient. The court also found the plaintiffs' allegations regarding higher-cost shares to be speculative and conclusory. Consequently, the court dismissed the failure-to-monitor claim as it was contingent on the success of the other claims.The United States Court of Appeals for the Sixth Circuit reviewed the case and reversed the district court's judgment. The appellate court held that the plaintiffs sufficiently pleaded facts to state a claim for imprudent retention of the Focus Funds, noting that the funds' high turnover rates and underperformance could indicate a flawed decision-making process. The court also found that the plaintiffs plausibly alleged that Parker-Hannifin failed to negotiate for lower-cost shares, which could constitute a breach of the duty of prudence. The court remanded the case for further proceedings consistent with its opinion. View "Johnson v. Parker-Hannifin Corp." on Justia Law

Michael Walden applied multiple times for a manufacturing job with General Electric (GE) but failed the required tests each time. He sued GE for age discrimination and his union for unfair representation in his challenges to GE's hiring decisions. The district court granted summary judgment for GE and the union, and Walden appealed.The United States District Court for the Western District of Kentucky granted summary judgment in favor of GE and the union. The court found that Walden failed to establish a prima facie case of age discrimination under the Age Discrimination in Employment Act (ADEA) because he did not meet the job qualifications, specifically failing the required tests. Additionally, the court found that the union did not breach its duty of fair representation.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision, holding that Walden did not qualify for the job as he failed the required tests, and thus could not establish a prima facie case of age discrimination. The court also held that issue preclusion barred Walden's claim against the union for unfair representation, as the National Labor Relations Board (NLRB) had already adjudicated and dismissed his unfair representation charge. The court concluded that Walden had a full and fair opportunity to litigate the issue before the NLRB, and thus, his section 301 claim under the Labor Management Relations Act (LMRA) failed as a matter of law. View "Walden v. General Electric International" on Justia Law

The plaintiff, Laurie DeVore, worked at the University of Kentucky from 1999 to 2022. She retired rather than comply with the University's COVID-19 test-or-vaccinate policy, which she claimed conflicted with her religious beliefs. DeVore filed a lawsuit alleging that the University violated Title VII of the Civil Rights Act of 1964 by failing to accommodate her religious beliefs. The University had denied her requests for a hybrid work schedule and religious exemptions from the testing policy, which required unvaccinated employees to undergo weekly COVID-19 testing.The United States District Court for the Eastern District of Kentucky granted summary judgment in favor of the University. The court found that DeVore did not establish a prima facie case of religious discrimination because she failed to demonstrate that the University's policy conflicted with her sincerely held religious beliefs. DeVore appealed the decision.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court examined whether DeVore had a sincere religious belief that conflicted with the University's testing policy. DeVore's objections to the nasal PCR tests were initially based on invasiveness, manipulation, and coercion. However, the University offered alternative testing methods, such as oral swab and saliva tests, which DeVore also rejected without providing evidence of a religious conflict with these alternatives.The Sixth Circuit affirmed the district court's decision, holding that DeVore failed to establish a conflict between her religious beliefs and the University's testing policy. The court noted that DeVore's objections were largely based on personal moral codes and secular concerns rather than religious principles. Consequently, DeVore's Title VII claim did not succeed. View "DeVore v. University of Kentucky Board of Trustees" on Justia Law

Art Iron, Inc. faced a lawsuit from the Board of Trustees of the Shopmen’s Local 499 Pension Plan seeking over one million dollars in withdrawal liability under ERISA. The key issue was whether Robert Schlatter, Art Iron’s sole shareholder, and his wife, Mary Schlatter, were personally liable for this withdrawal liability due to their operation of businesses allegedly under common control with Art Iron.The United States District Court for the Northern District of Ohio granted summary judgment in favor of the Board, finding both Robert and Mary Schlatter personally liable. The court determined that Robert’s consulting business and Mary’s jewelry-making activities were trades or businesses under common control with Art Iron, thus making them jointly and severally liable for the withdrawal liability.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court’s judgment regarding Robert Schlatter, agreeing that his consulting business was a trade or business under common control with Art Iron. The court applied the Groetzinger test, which considers whether the activity is continuous and regular and primarily for income or profit, and found that Robert’s consulting business met these criteria.However, the court reversed the district court’s judgment regarding Mary Schlatter. It found that her jewelry-making activities did not constitute a trade or business under the Groetzinger test, as her activities lacked the necessary continuity and regularity in 2017, the year of Art Iron’s withdrawal from the Plan. Consequently, Mary Schlatter was not personally liable for the withdrawal liability.The Sixth Circuit thus affirmed the district court’s judgment as to Robert Schlatter and reversed and remanded the judgment as to Mary Schlatter. View "Shopmen’s Local No 499, Bd of Trustees v. Art Iron, Inc." on Justia Law