Chp 1 -Employment Law Cases

Warner v. United Natural Foods, Inc. (2021)

Federal district court held that an employee terminated after reporting COVID-19 violations could not sue for wrongful discharge because executive orders alone do not establish a public policy exception to employment-at-will.

OTO, L.L.C. v. Kho (2019)

California Supreme Court held that a mandatory arbitration agreement was unenforceable as unconscionable where employee was pressured to sign immediately without explanation and the agreement imposed litigation-style procedures that eliminated the benefits of the streamlined wage claim process.

EEOC v. AutoZone (2012)

Sixth Circuit held that an employer who repeatedly ignored an employee's accommodation requests despite ADA training was liable for $100,000 in compensatory damages, $200,000 in punitive damages, $115,000 in back pay, and injunctive relief.

Chevron U.S.A., Inc. v. National Resources Defense Council (1984)

The Supreme Court held that courts must defer to reasonable agency interpretations of ambiguous statutes.

West Virginia v. EPA (2022)

The Supreme Court held that agencies cannot claim expansive regulatory authority on major questions without clear congressional authorization.

Faragher v. City of Boca Raton (1998)

The Supreme Court held that employers may avoid liability for supervisor harassment if the employee unreasonably failed to use the employer's complaint procedure.

Gilmer v. Interstate/Johnson Lane Corporation (1991)

The Supreme Court held that mandatory arbitration agreements for statutory employment claims are enforceable under the Federal Arbitration Act.

Circuit City Stores v. Adams (2001)

The Supreme Court held that the Federal Arbitration Act applies to employment contracts except for transportation workers.

New Prime Inc. v. Oliveira (2019)

The Supreme Court held that transportation workers, whether employees or independent contractors, are exempt from the FAA's mandatory arbitration provisions.

EEOC v. Waffle House, Inc. (2002)

The Supreme Court held that an employee's arbitration agreement does not prevent the EEOC from filing suit and seeking victim-specific relief on the employee's behalf.

14 Penn Plaza LLC v. Pyett (2009)

The Supreme Court held that union-negotiated arbitration provisions can waive individual employees' rights to litigate statutory claims only if the contract language "clearly and unmistakably" requires it.

Alden v. Maine (1999)

The Supreme Court held that state sovereign immunity under the Eleventh Amendment bars state employees from suing states in state court for FLSA violations.

University of Alabama v. Garrett (2001)

The Supreme Court held that state governments are immune from ADA lawsuits by employees under the Eleventh Amendment.

Nevada Department of Human Resources v. Hibbs (2003)

The Supreme Court held that state employees can sue states for FMLA family-care leave violations despite state sovereign immunity.

Coleman v. Court of Appeals of Maryland (2012)

The Supreme Court held that state employees cannot sue states for FMLA self-care leave violations.

Walters v. Metropolitan Educational Enterprises, Inc. (1997)

The Supreme Court held that the "payroll method" counts employees for each full week between hire and termination regardless of hours worked to determine employer coverage under Title VII.

National Railroad Passenger Corporation v. Morgan (2002)

The Supreme Court held that hostile environment claims can include acts outside the limitations period if at least one act occurred within the period, but discrete discriminatory acts must occur within the limitations period.

Green v. Brennan (2016)

The Supreme Court held that the limitations period for constructive discharge claims begins when the employee gives notice of resignation, not when the last discriminatory act occurred.

Ledbetter v. Goodyear Tire & Rubber Co. (2007)

The Supreme Court held that pay discrimination is a discrete act occurring when the discriminatory pay decision is made, not with each paycheck (later overturned by the Lilly Ledbetter Fair Pay Act).

Wal-Mart Stores v. Dukes (2011)

The Supreme Court held that a class cannot be certified where plaintiffs cannot show a common policy affecting all members, and decentralized decision-making is the opposite of the uniform practice required for commonality.

Mach Mining, LLC v. EEOC (2015)

The Supreme Court held that the EEOC must inform the employer of its discrimination finding, offer to conciliate, and provide opportunity to remedy, but has considerable discretion in how it conducts conciliation.

BMW of North America, Inc. v. Gore

The Supreme Court held that punitive damages violate due process if "grossly excessive" based on reprehensibility of conduct, ratio to actual harm, and comparison to civil penalties.

AT&T Mobility LLC v. Concepcion (2011)

The Supreme Court held that arbitration agreements prohibiting class-wide arbitration are enforceable under the FAA even when individual claims would be cost-prohibitive.

American Express v. Italian Colors Restaurant (2013)

The Supreme Court held that class waivers in arbitration agreements are enforceable even when the cost of individual arbitration exceeds potential recovery.

Epic Systems Corp. v. Lewis (2018)

The Supreme Court held that arbitration agreements can require employees to bring claims individually and waive their collective action rights under the NLRA.

Lamps Plus v. Varella (2019)

The Supreme Court held that ambiguous arbitration agreements do not authorize class-wide arbitration absent clear contractual language.

Mercado v. The Ritz Carlton San Juan Hotel, Spa & Casino (1st Cir. 2005)

The First Circuit held that equitable tolling may apply to excuse late filing when the employer actively misled the employee or failed to post required workplace notices.

Harris v. Boyd Tunica Inc. (5th Cir. 2010)

The Fifth Circuit held that equitable tolling does not apply when an attorney's clerical error causes late filing.

Granger v. Aaron's Inc. (5th Cir. 2011)

The Fifth Circuit held that equitable tolling applies when the employee's attorney diligently filed with the wrong agency and the agency failed to correct the obvious error.

Morrison v. Wal-Mart Stores (6th Cir. 2003)

The Sixth Circuit held that procedural unconscionability factors include time given to consider the contract, pressure to sign, document complexity, employee education level, and access to legal counsel.

McMullen v. Meijer (6th Cir. 2004)

The Sixth Circuit held that an arbitration agreement is unenforceable where the employer has effective control over arbitrator selection.

Blair v. Scott Specialty Gases (3d Cir. 2002)

The Third Circuit held that cost-splitting provisions in arbitration agreements are evaluated based on whether the costs would deter employees from bringing claims.

Ingle v. Circuit City Stores (9th Cir. 2003)

The Ninth Circuit held that arbitration agreements are unenforceable when they unreasonably limit remedies or impose unreasonably short limitations periods.

Lee v. Red Lobster Inns of America (6th Cir. 2004)

The Sixth Circuit held that an arbitration provision in an employee handbook is unenforceable absent a written agreement demonstrating employee assent.

Campbell v. General Dynamics (1st Cir. 2005)

The First Circuit held that email notification of an arbitration policy is insufficient when the message doesn't clearly alert employees to its legal significance and the employer doesn't track access or obtain acknowledgments.

Tillman v. Macy's (6th Cir. 2013)

The Sixth Circuit held that an arbitration agreement can be enforceable despite no signed acknowledgment where multiple indicators showed adequate notice, including mailings, brochures, videos, and opt-out opportunities.

Ealy v. Pinkerton Government Services (4th Cir. 2013)

The Fourth Circuit held that class certification was properly denied in a discrimination case following the strict commonality standards from Wal-Mart v. Dukes.

Davis v. Cintas (6th Cir. 2013)

The Sixth Circuit held that class certification should be denied where individual circumstances vary too much to establish commonality.

Brown v. Nucor Corp. (4th Cir. 2015)

The Fourth Circuit held that class certification is more likely when the class is limited to a smaller group of employees from the same establishment.

Ibarra v. UPS (5th Cir. 2012)

The Fifth Circuit held that a collective bargaining agreement's arbitration provision doesn't waive individual litigation rights unless it clearly identifies specific statutes or explicitly refers to statutory claims.

Aburto v. Verizon California (C.D. Cal. 2012)

The Central District of California held that wage and hour class certification is subject to the strict commonality requirements from Wal-Mart v. Dukes.

Leyva v. Medline Industries (9th Cir. 2013)

The Ninth Circuit held that the commonality standards from Wal-Mart v. Dukes apply to wage and hour class action claims.

DoorDash arbitration case (Judge William Alsup)

The federal district court held that DoorDash must honor its arbitration agreement's terms requiring payment of filing fees even when thousands of individual arbitrations are filed.

Rodriguez v. Windermere Real Estate/Wall Street, Inc. (Wash. Ct. App. 2008)

The Washington Court of Appeals held that an arbitration agreement is unenforceable where the arbitrator selection process gives the employer undue control or requires arbitrators with business ties to the employer.

Clark v. DaimlerChrysler Corp. (Mich. Ct. App. 2005)

The Michigan Court of Appeals held that shortened limitations periods in arbitration agreements are sometimes substantively unconscionable.

Virginia Duncan v. Cigar City Motors (EEOC 2021)

A jury awarded $500,000 in punitive damages for sex discrimination where a qualified female sales manager was denied promotion to general manager because she was deemed "too motherly."

Chicago Meat Processing Company (EEOC settlement)

The EEOC secured a settlement over $1 million for systemic racial harassment in hiring, hostile work environment, and retaliation against Black employees who complained.