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

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

Alvin Moore, a Black man, worked at Coca-Cola Bottling Company (CCBC) from 2015 to 2018. In March 2017, after a workplace accident, Moore tested positive for marijuana at a level below the company's threshold. Despite this, he signed a Second Chance Agreement (SCA) requiring random drug testing for 24 months. In June 2017, Moore was fired for insubordination but was reinstated under a Last Chance Agreement (LCA), which he signed under pressure. In 2018, Moore tested positive for marijuana again and was terminated. He sued CCBC for racial discrimination and retaliation under Title VII and Ohio law.The United States District Court for the Southern District of Ohio granted summary judgment in favor of CCBC, finding that Moore had waived his pre-LCA claims by signing the LCA and failed to establish that CCBC's reasons for his termination were pretextual. The court presumed Moore had made a prima facie case for racial discrimination and retaliation but concluded that Moore did not show that CCBC's reasons for his termination were a pretext for discrimination.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court found that there was a genuine dispute of material fact regarding whether Moore voluntarily waived his pre-LCA claims by signing the LCA. The court noted that Moore's union representative had advised him to sign the LCA, suggesting he could still pursue his claims. The court also found that Moore had shown enough evidence to suggest that CCBC's reasons for his termination could be pretextual, particularly in light of the different treatment of similarly situated white employees.The Sixth Circuit reversed the district court's summary judgment and remanded the case for further proceedings, allowing Moore to pursue his claims of racial discrimination and retaliation. View "Moore v. Coca-Cola Consolidated, Inc." on Justia Law

Aimee Sturgill, a registered nurse and devout Christian, objected to the American Red Cross's COVID-19 vaccination mandate, citing her religious beliefs. She requested a religious exemption, explaining that her faith required her to treat her body as a temple and avoid defiling it with the vaccine, which she believed could cause harm due to her blood clotting disorder. The Red Cross denied her request, stating that her objections were medically, not religiously, based and terminated her employment.The United States District Court for the Eastern District of Michigan dismissed Sturgill's complaint under Federal Rule of Civil Procedure 12(b)(6). The court held that she did not plausibly allege a prima facie case for a failure-to-accommodate claim under Title VII of the Civil Rights Act of 1964. The court also concluded that Sturgill did not set forth a separate disparate-treatment claim.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that the district court erred by requiring Sturgill to establish a prima facie case at the pleading stage, which is not necessary under the plausibility standard set by Twombly and Iqbal. The appellate court found that Sturgill's complaint plausibly alleged that her refusal to take the COVID-19 vaccine was an aspect of her religious observance or belief. However, the court agreed with the district court that Sturgill's complaint did not set forth a standalone disparate-treatment claim. Consequently, the Sixth Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings. View "Sturgill v. American Red Cross" on Justia Law

Two employees, Tanika Parker and Andrew Farrier, participated in 401(k) plans managed by subsidiaries of Tenneco Inc. The plans were amended to include mandatory individual arbitration provisions, which required participants to arbitrate disputes individually and barred representative, class, or collective actions. Parker and Farrier alleged that the fiduciaries of their plans breached their fiduciary duties under ERISA by failing to prudently manage the plans, resulting in higher costs and reduced retirement savings. They sought plan-wide remedies, including restitution of losses and disgorgement of profits.The United States District Court for the Eastern District of Michigan denied the fiduciaries' motion to compel individual arbitration. The court found that the arbitration provisions limited participants' substantive rights under ERISA by eliminating their ability to bring representative actions and seek plan-wide remedies, which are guaranteed by ERISA.The United States Court of Appeals for the Sixth Circuit reviewed the case and affirmed the district court's decision. The Sixth Circuit held that the individual arbitration provisions were unenforceable because they acted as a prospective waiver of the participants' statutory rights and remedies under ERISA. The court emphasized that ERISA allows participants to sue on behalf of a plan and obtain plan-wide relief, and the arbitration provisions' restrictions on representative actions and plan-wide remedies violated these statutory rights. Consequently, the arbitration provisions were invalid, and the district court's judgment was affirmed. View "Parker v. Tenneco, Inc." on Justia Law

Joel M. Guy, Jr. murdered his parents in 2016 with the intent to collect the proceeds from his mother’s insurance plans. His mother had life insurance and accidental death and dismemberment insurance through her employer, naming Guy and his father as beneficiaries. Guy was convicted of first-degree premeditated murder, felony murder, and abuse of a corpse by a Tennessee jury.The United States District Court for the Eastern District of Tennessee determined that Guy would be entitled to the insurance proceeds if not disqualified. However, the court ruled that Guy was disqualified under Tennessee’s slayer statute or federal common law, which prevents a murderer from benefiting from their crime. The court granted summary judgment in favor of Guy’s family members, who argued that Guy was not entitled to the benefits. Guy appealed, arguing that ERISA preempts Tennessee’s slayer statute and that no federal common-law slayer rule applies.The United States Court of Appeals for the Sixth Circuit reviewed the case de novo. The court held that ERISA does not explicitly address the issue of a beneficiary who murders the insured, and thus, either Tennessee law or federal common law must apply. The court found that both Tennessee’s slayer statute and federal common law would disqualify Guy from receiving the insurance proceeds. The court affirmed the district court’s decision, concluding that Guy’s actions disqualified him from benefiting from his mother’s insurance plans under both state and federal law. View "Standard Insurance Co. v. Guy" on Justia Law

Next Century Rebar, LLC (NCR) worked on a project in Detroit, Michigan, within the jurisdiction of Local Union Number 25 (Local 25). Due to a shortage of Local 25 iron workers, NCR hired workers from out-of-state unions, Local 416 and Local 846. NCR made benefits contributions to the funds associated with these out-of-state unions. In 2021, Local 25 Funds conducted an audit and found that NCR had not made contributions to the Local 25 Funds for these out-of-state employees. NCR contested this, arguing that it had already made contributions to the out-of-state funds.The Local 25 Funds filed a lawsuit under 29 U.S.C. § 1145, seeking unpaid contributions. The United States District Court for the Eastern District of Michigan granted summary judgment in favor of the Local 25 Funds, awarding them $1,787,300.75 in unpaid contributions, $143,075.41 in interest, and $288,598.80 in liquidated damages. The court also awarded $18,233.15 in costs and $99,812.25 in attorney fees. NCR appealed, arguing that the district court applied the wrong summary-judgment standard, improperly granted summary judgment despite genuine disputes of material fact, and abused its discretion by not awarding a setoff for contributions made to out-of-state funds.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court found that the Local 25 CBA required contributions based on the specific employee’s gross earnings for the vacation fund and base wages for the pension fund. However, it was unclear whether the audit used the correct wage rates. The court also found that the Local 25 Funds' request for contributions violated the International Agreement’s prohibition on double payments. Consequently, the court affirmed the district court’s decision in part, reversed it in part, and remanded the case for further proceedings. View "Trustees of Iron Workers Defined Contribution Pension Fund v. Next Century Rebar, LLC" on Justia Law

The case involves an unfair labor practice dispute between Rieth-Riley Construction Co., a highway construction contractor in Michigan, and Local 324, International Union of Operating Engineers, AFL-CIO. The dispute centers on subcontracting and employee wages. The last collective-bargaining agreement expired on May 31, 2018, and despite multiple bargaining sessions, no successor agreement has been reached. The Union went on strike on July 31, 2019, and picketing incidents ensued, including an altercation where a striking union member, Michael Feighner, assaulted a truck driver, Karl Grinstern.The National Labor Relations Board (NLRB) General Counsel issued complaints against both parties: against the Union for picketing misconduct and against Rieth-Riley for failing to provide requested subcontracting and employee information. An Administrative Law Judge (ALJ) found that Rieth-Riley violated the National Labor Relations Act (NLRA) by not providing the requested information and that the Union violated the NLRA when Feighner assaulted Grinstern. The ALJ ordered Rieth-Riley to provide the requested information and the Union to cease and desist from such misconduct. The NLRB affirmed the ALJ’s decision with a slight modification.The United States Court of Appeals for the Sixth Circuit reviewed the case. The court held that President Biden lawfully removed the NLRB General Counsel, and the General Counsel had unreviewable prosecutorial discretion. The court found substantial evidence supporting the ALJ’s conclusions that the requested information was relevant to the Union’s bargaining responsibilities and that Rieth-Riley’s refusal to provide it violated the NLRA. The court also upheld the finding that the Union’s assault on Grinstern was an unfair labor practice. The court denied Rieth-Riley’s petition for review and granted the NLRB’s cross-application for enforcement of its order in full. View "Rieth-Riley Construction Co. v. National Labor Relations Board" on Justia Law

During the COVID-19 pandemic, Kalitta Air, LLC implemented a vaccine mandate for all its employees. Employees who could not receive a vaccination due to a disability or a sincerely held religious belief could request an accommodation and would be placed on unpaid leave. If they remained unvaccinated after the leave period, they could either voluntarily resign or be terminated. Eleven employees, including five pilots, sued Kalitta under Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act, claiming that the mandate discriminated against them based on their religious beliefs and/or disabled status.The district court found that the Railway Labor Act precluded it from hearing certain claims by the pilots, who were subject to a collective bargaining agreement. These claims had to first go through arbitration as minor disputes. The pilots appealed this decision.The United States Court of Appeals for the Sixth Circuit affirmed the district court's decision. The court found that the pilots' claims under Title VII and the Americans with Disabilities Act required interpretation of the collective bargaining agreement, and thus were minor disputes that had to be resolved through arbitration. The court also held that the pilots' claim of discrimination based on perceived disability would require interpretation of the collective bargaining agreement, and was therefore also precluded by the Railway Labor Act. View "Odell v. Kalitta Air, LLC" on Justia Law