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

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

A police officer with over thirty-three years of experience, including seventeen years with the Blue Ash Police Department, was terminated at age sixty-one. The officer alleged that his performance record was nearly perfect until a new police chief took over, after which he faced increased scrutiny and discipline. The officer was assigned a traffic study, typically not given to patrol officers, and disciplined multiple times for minor infractions, including failing to turn on his microphone during traffic stops and not responding promptly to a noise complaint. The final incident leading to his termination involved a delayed response to a medical emergency, which led to an investigation uncovering multiple policy violations, including untruthfulness.The United States District Court for the Southern District of Ohio granted summary judgment to the defendants on all claims. The court concluded that the officer failed to provide sufficient evidence that his termination was due to age discrimination. The court also found that the officer abandoned his other claims by not addressing them in his brief opposing summary judgment.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court affirmed the district court's decision regarding the age discrimination claim, holding that the officer could not show that age was the "but-for" reason for his termination. However, the court reversed the district court's decision on the hostile work environment claim. The appellate court found that the officer presented enough evidence to create a genuine dispute of material fact regarding whether he was subjected to a hostile work environment based on age. The court noted that the officer's allegations of increased scrutiny, disproportionate discipline, and demeaning assignments could support a hostile work environment claim. The case was remanded for further proceedings on this claim against the City of Blue Ash. View "McNeal v. City of Blue Ash" on Justia Law

Quickway Transportation, Inc. (Quickway) petitioned the United States Court of Appeals for the Sixth Circuit to review a National Labor Relations Board (NLRB) order in an unfair labor practice proceeding. The NLRB cross-petitioned for enforcement of its order. The case involved Quickway's cessation of operations at its Louisville terminal, which the NLRB found violated the National Labor Relations Act (NLRA). Quickway argued that the NLRB's findings were not supported by substantial evidence and that the Board's remedial order was overly burdensome.The Administrative Law Judge (ALJ) initially found that Quickway violated the NLRA by ceasing operations at the Louisville terminal due to anti-union animus, failing to bargain over the cessation and its effects, and engaging in coercive and retaliatory actions against employees. The NLRB affirmed the ALJ's findings and ordered Quickway to reopen the Louisville terminal, reinstate employees, and compensate them for lost earnings and benefits.The Sixth Circuit reviewed the NLRB's decision under a substantial evidence standard and found that the Board's conclusions were supported by substantial evidence. The court noted that Quickway's decision to close the Louisville terminal was motivated by anti-union animus and aimed at chilling unionization efforts at other terminals. The court also upheld the Board's finding that Quickway failed to bargain in good faith over the decision and its effects.The court affirmed the NLRB's remedial order, including the requirement for Quickway to reopen the Louisville terminal and reinstate employees. The court found that the Board did not abuse its discretion in ordering these remedies and that Quickway failed to demonstrate that the restoration order would be unduly burdensome. The court denied Quickway's petition for review and granted the NLRB's cross-application for enforcement of its order in full. View "Quickway Transp., Inc. v. NLRB" on Justia Law

In March 2020, Metro Man IV, LLC, which operates a nursing home, faced a severe staff shortage due to the COVID-19 pandemic. To address this, the company implemented temporary hazard pay and hired non-certified nursing aides. The National Labor Relations Board (NLRB) found that while the emergency excused Metro Man from initially bargaining with the union, the company failed to bargain with the union regarding the effects of these unilateral decisions once the emergency subsided.An administrative law judge (ALJ) determined that Metro Man violated the National Labor Relations Act by not bargaining with the union before increasing and then decreasing wages and hiring non-certified aides. The ALJ ordered Metro Man to pay back wages but did not require reinstating the wage increase. The NLRB amended this order, agreeing that the exigent circumstances excused initial bargaining but still required Metro Man to notify and bargain with the union about the changes and their effects once the emergency ended. The NLRB ordered Metro Man to reinstate the wage increase and to bargain with the union before making future changes.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the implementation and rescission of the hazard pay were part of a single decision, excused by the exigent circumstances of COVID-19, and thus not subject to separate bargaining obligations. However, the court upheld the NLRB's finding that Metro Man failed to engage in effects-bargaining regarding the hiring of non-certified aides. The court affirmed the NLRB's decision in part, reversed it in part, and remanded the case for further proceedings consistent with its opinion. View "NLRB v. Metro Man IV, LLC" on Justia Law

Meng Huang, a former Ph.D. student at The Ohio State University (OSU), alleged that her advisor, Professor Giorgio Rizzoni, sexually harassed and assaulted her during her studies. Huang filed a lawsuit against OSU and Rizzoni, claiming Title VII quid pro quo sexual harassment and retaliation against OSU, and a due process violation against Rizzoni under 42 U.S.C. § 1983.The United States District Court for the Southern District of Ohio granted summary judgment to OSU on Huang’s Title VII claims, concluding she was not an "employee" under Title VII until August 2017. The court also ruled that Huang’s retaliation claim failed because her first protected activity occurred after the alleged adverse actions. Huang’s § 1983 claim against Rizzoni proceeded to trial, where the court trifurcated the trial and excluded evidence of Rizzoni’s alleged manipulation and coercion. The jury found in favor of Rizzoni.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the district court erred in determining Huang was not an employee under Title VII before August 2017, as her research work and the control Rizzoni exerted over her indicated an employment relationship. The court also held that Huang’s resistance to Rizzoni’s advances constituted protected activity under Title VII, and she presented sufficient evidence of adverse employment actions linked to her resistance.The Sixth Circuit reversed the district court’s summary judgment on Huang’s Title VII claims, vacated the trial verdict in favor of Rizzoni on the § 1983 claim, and remanded for a new trial. The court emphasized that the district court’s exclusion of relevant evidence regarding Rizzoni’s power and manipulation was an abuse of discretion, which prejudiced Huang’s ability to present her case. View "Huang v. Ohio State University" on Justia Law

James Moyer and other captive insurance agents sued GEICO, claiming they were misclassified as independent contractors and denied benefits under the Employee Retirement Income Security Act of 1974 (ERISA). They argued that GEICO should have classified them as employees, making them eligible for various benefits plans. The agents did not attach the relevant benefits-plan documents to their complaint, which are integral to their claims.The United States District Court for the Southern District of Ohio ordered the parties to provide the relevant plan documents. GEICO submitted documents it claimed governed the dispute, but the agents argued that the court could not rely on these documents without converting the motion to dismiss into a summary judgment motion and requested additional discovery. The district court disagreed, relied on the documents provided by GEICO, and dismissed the complaint, finding that the agents lacked statutory standing as they were not eligible for the benefits under the plan documents.The United States Court of Appeals for the Sixth Circuit reviewed the case and found that there were legitimate questions about whether GEICO had provided a complete set of the relevant plan documents. The court noted issues with the authenticity and completeness of the documents, including redlines, handwritten notes, and missing pages. The court held that the district court should not have relied on these documents to dismiss the complaint without allowing the agents to conduct discovery. Consequently, the Sixth Circuit reversed the district court's decision and remanded the case for further proceedings. View "Moyer v. GEICO" on Justia Law

The case involves Ariel Schlosser, who was hired by VRHabilis, LLC (VRH) to perform unexploded ordnance (UXO) remediation. Schlosser, the only female diver, faced several incidents of alleged discrimination and harassment. She was singled out for a knot-tying test, prohibited from diving and driving the company vehicle, and subjected to verbal abuse by her supervisor, Tyler Sanders, and co-worker, Aaron Brouse. Schlosser reported the harassment, but VRH's response was inadequate, leading her to resign after ten weeks.The United States District Court for the Eastern District of Tennessee denied VRH's motion for summary judgment, allowing the case to proceed to trial. After a four-day trial and three days of deliberations, the jury found that Schlosser was subjected to a hostile work environment based on her sex or gender, in violation of Title VII of the Civil Rights Act of 1964. The jury awarded Schlosser $58,170 in back pay. VRH filed a renewed motion for judgment as a matter of law, arguing that the evidence did not support the jury's verdict. The district court denied this motion, holding that the jury could reasonably conclude that Schlosser experienced severe and pervasive harassment based on her gender.The United States Court of Appeals for the Sixth Circuit reviewed the district court's denial of VRH's renewed motion for judgment as a matter of law de novo. The court affirmed the district court's judgment, finding that the jury could reasonably determine that Schlosser was subjected to a hostile work environment based on her sex or gender. The court held that the harassment was severe and pervasive, and that VRH was liable for the actions of Schlosser's supervisor and co-worker. The court emphasized the substantial deference owed to the jury's verdict and concluded that VRH had not overcome this deference. View "Schlosser v. VRHabilis, LLC" on Justia Law