Justia U.S. 4th Circuit Court of Appeals Opinion Summaries

The plaintiff, a long-term employee at a private aviation services provider, was diagnosed with breast cancer during the COVID-19 pandemic. Initially, she was permitted to work entirely from home as business slowed, with her in-person duties reassigned to another employee. As business returned to normal, management repeatedly asked her to resume a hybrid work schedule to address essential accounting functions that required physical presence. Although she verbally agreed to return on a part-time basis, she failed to attend in person as promised, communicated sporadically about her schedule, and ultimately missed multiple days of work without proper notice. After this pattern continued for several months, she was discharged for job abandonment.The United States District Court for the Western District of North Carolina granted summary judgment for the employer. The court found that the plaintiff failed to establish a prima facie case of discrimination, retaliation, or failure to accommodate under the Americans with Disabilities Act (ADA). The court determined that, even if such a case were made, the employer had provided legitimate business reasons for its decisions and had made substantial efforts to accommodate the plaintiff’s medical condition.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the decision de novo. The appellate court held that the plaintiff did not qualify as a “qualified individual” under the ADA because she could not perform the essential functions of her position, even with reasonable accommodation. The court emphasized that the employer’s repeated attempts to accommodate her were sufficient, and her failure to cooperate or consistently communicate precluded liability. The court also rejected her retaliation claim, finding no causal connection between her protected activity and her termination. The judgment of the district court was affirmed. View "Haggins v. Wilson Air Center, LLC" on Justia Law

Osvaldo Figueroa worked as a night-shift turkey loader for a poultry company. His main duties included catching and loading turkeys onto trucks, and sometimes fueling, sanitizing, and washing the trucks before the loading process. Employees recorded their work hours using a punch clock, and paystubs included entries for overtime hours, load trips (base pay per trip), and attendance hours. Figueroa alleged that he and other turkey loaders were not paid promised hourly wages and overtime, claiming violations of both the North Carolina Wage and Hour Act (NCWHA) and the Fair Labor Standards Act (FLSA).The United States District Court for the Eastern District of North Carolina first dismissed Figueroa’s amended complaint, concluding that he was paid under a piece-rate system rather than an hourly wage system, and that he failed to sufficiently allege entitlement to unpaid overtime or hourly wages. The district court also found that he received adequate notice of his compensation structure under the NCWHA. After Figueroa amended his complaint again, the district court dismissed his NCWHA claims but allowed the FLSA claim to proceed to discovery. On summary judgment, the district court found that Figueroa was a piece-rate employee, that overtime was properly calculated according to FLSA regulations, and that Butterball kept accurate records. The court rejected Figueroa’s assertions of improper hour-shifting and unpaid pre-shift work due to lack of supporting evidence for his own situation.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s rulings. The appellate court held that Figueroa was properly classified as a piece-rate employee, not an hourly worker, and that Butterball correctly calculated and paid overtime according to FLSA provisions. The court also found that Figueroa did not establish a viable claim under the NCWHA, as any error in dismissal was harmless in light of the record, and that Butterball provided sufficient notice of pay terms. The district court’s orders were affirmed. View "Osvaldo Figueroa v. Butterball, LLC" on Justia Law

A coal miner was employed at the Burke Mountain Mine Complex until October 2019, when he was told the mine was “shut down” and his job was terminated without receiving advance notice. He brought a class action lawsuit on behalf of himself and other similarly situated employees against five related mining companies, alleging they failed to provide notice of termination as required by the Worker Adjustment and Retraining Notification Act (WARN Act). Evidence at trial showed that the companies shared common officers, directors, ownership, and business addresses, and that personnel and equipment were regularly exchanged among them. Employees testified that the companies operated interchangeably and were managed collectively by the same family.The United States District Court for the Southern District of West Virginia certified the class, denied summary judgment to both sides, and submitted the matter to a jury. The jury found the companies liable under the WARN Act, determining that they operated as a single employer and that at least 50 employees suffered an employment loss through termination or reduction in hours. The district court entered judgment for the plaintiff and, after trial, denied the defendants’ renewed motion for judgment as a matter of law or, alternatively, for a new trial. The companies appealed, challenging both the sufficiency of the evidence and the jury instructions.The United States Court of Appeals for the Fourth Circuit reviewed the case and affirmed the district court’s judgment. The court held that the jury had sufficient evidence to conclude the companies were a single employer under the WARN Act and that the district court’s instruction regarding the definition of employment loss was correct. The court also found that the companies forfeited any argument regarding an inconsistent jury verdict by failing to object before the jury was discharged. View "Gautier v. Tams Management, Inc." on Justia Law

A group of current and former battalion chiefs employed by the City of Alexandria Fire Department alleged that the City failed to pay them overtime wages as required by the Fair Labor Standards Act (FLSA). The battalion chiefs’ compensation was based on a complex pay structure. Chiefs worked either operational or administrative schedules. Operational chiefs rotated through 24-hour shifts within a nine-day cycle, and administrative chiefs worked a standard 40-hour week. The City paid the chiefs a predetermined amount per pay period, corresponding to either 80 administrative hours or 106 operational hours, regardless of the exact number of hours worked, with additional compensation for hours worked beyond their scheduled shifts.The United States District Court for the Eastern District of Virginia granted summary judgment for the City. The district court found that the chiefs were exempt from the FLSA’s overtime requirements under the “highly compensated employee” exemption. Specifically, the court held that the chiefs were paid on an hourly basis and applied the salary basis test found in 29 C.F.R. § 541.604(b). The court concluded the chiefs received guaranteed pay that satisfied the regulatory requirements and that the pay had a reasonable relationship to their usual earnings.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s judgment but for different reasons. The appellate court held that the district court applied the wrong salary basis test, finding that the appropriate test was under 29 C.F.R. § 541.602(a), which applies to employees paid on a weekly or less frequent salary basis. The court concluded that, despite the complexity of the pay system, the chiefs received a predetermined salary not subject to improper deductions and, therefore, were compensated on a salary basis. As a result, the chiefs were correctly deemed exempt from overtime requirements, and the district court’s decision was affirmed. View "Kelly v. City of Alexandria" on Justia Law

A Black woman who had worked for a community college for nearly two decades applied for a promotion to Assistant Dean of Workforce Solutions after serving as Director of Special Populations. The position required significant experience in workforce development, including knowledge of specific funding and grant-writing. The applicant pool included her and a Hispanic male colleague who had overseen larger programs and had more direct experience with the job’s requirements. A search committee interviewed candidates, with the final hiring decision made by the Vice President of Enrollment and Outreach Initiatives.The United States District Court for the District of Maryland initially dismissed her claims of race and gender discrimination under Title VII. On appeal, the United States Court of Appeals for the Fourth Circuit reversed and remanded in part, allowing her to pursue a disparate treatment claim focused on the college’s failure to promote her and its issuance of a corrective action letter for a payroll error. Following discovery, the district court granted summary judgment for the college, finding that the plaintiff did not present sufficient evidence of intentional discrimination, and that the employer’s stated reason—selecting the more qualified candidate—was not shown to be pretextual.Reviewing the case de novo, the United States Court of Appeals for the Fourth Circuit affirmed the district court’s grant of summary judgment. The court assumed that the plaintiff established a prima facie case of discrimination but held that she did not meet her burden to show the employer’s justification was pretext. The court found that the selected candidate’s qualifications aligned more closely with the position, and that neither evidence of preselection, circumstantial evidence of discriminatory comments, nor disparate discipline sufficed to demonstrate intentional discrimination or pretext. The court thus affirmed the judgment in favor of the college. View "Hood-Wilson v. Board of Trustees, Community College of Baltimore" on Justia Law

After divorcing in 2010, a former employee and his ex-spouse entered into a court-approved domestic relations order in North Carolina that divided his employer-sponsored retirement plan benefits. The order stipulated that the ex-spouse would be treated as a surviving spouse, entitling her to survivor benefits under the plan, and stated that her portion of the benefit "may be reduced as necessary" to cover the cost of the survivor annuity. Years later, when the employee retired and began receiving benefits, he argued that the plan administrator improperly reduced his monthly payment by factoring the cost of the survivor annuity into his share, rather than allocating the cost solely to his ex-spouse’s portion. He also claimed that the plan administrator failed to timely provide all requested plan documents, warranting statutory penalties.The United States District Court for the Western District of North Carolina granted summary judgment for the employer and plan administrator. The court found that the plan administrator correctly interpreted the qualified domestic relations order (QDRO) to permit, but not require, allocating the cost of the survivor annuity to the ex-spouse’s share, and that the benefit calculation was consistent with the plan terms and not an abuse of discretion. Additionally, the court held that the plaintiff was not prejudiced by any delay in receiving plan documents and denied statutory penalties.On appeal, the United States Court of Appeals for the Fourth Circuit affirmed. The Fourth Circuit concluded that de novo review was appropriate for interpreting the QDRO, while the plan administrator’s benefit calculations were reviewed for abuse of discretion. The court held that the QDRO’s language was unambiguous and permissive, not mandatory, regarding who should bear the cost of the survivor annuity. The court also upheld the denial of statutory penalties, finding no prejudice or bad faith. The district court’s summary judgment for the defendants was affirmed. View "Gasper v. EIDP, Inc." on Justia Law

An employee of a company specializing in training security officers raised concerns to management about unsafe working conditions, including the handling of weapons and a hazardous firing range where bullet ricochets had resulted in injuries. The employee, along with other instructors, formally complained to supervisors about these dangers, especially during the onset of the COVID-19 pandemic, when he also questioned restrictions on personal protective equipment. After voicing these safety concerns, the employee was suspended and later terminated, allegedly for insubordination.The employee filed a charge with the Regional Director of the National Labor Relations Board (NLRB), asserting that his termination was unlawful retaliation for engaging in protected concerted activity under the National Labor Relations Act (NLRA). After investigation, an NLRB administrative law judge (ALJ) held a hearing and determined that the employee was not a managerial employee and was therefore protected by the NLRA. The ALJ found that the primary reason for the suspension and termination was the employee’s repeated advocacy regarding workplace safety, not insubordination. The ALJ concluded that the employer had committed unfair labor practices. The employer appealed, and the NLRB affirmed the ALJ’s decision with minor modifications.The United States Court of Appeals for the Fourth Circuit reviewed the NLRB’s order. Applying the substantial evidence standard, the court held that the Board’s conclusion—that the employee was not a managerial employee—was supported by the record. The court found that the employee lacked authority to formulate or implement management policy and did not possess the discretion characteristic of managerial status. Therefore, the employee was entitled to the NLRA’s protections. The court granted the NLRB’s application for enforcement of its order and denied the employer’s cross-petition for review. View "National Labor Relations Board v. Constellis, LLC" on Justia Law

During the COVID-19 pandemic, an employer instituted a company-wide vaccine mandate that applied to all employees, including those working remotely. Two remote employees requested religious exemptions from the vaccine requirement. One objected on the basis of her Christian beliefs regarding the use of fetal cell lines in vaccine development, while the other cited her conscience and faith, referencing Catholic teachings. Both exemption requests were denied, and the employees were subsequently terminated.After their terminations, the two employees initiated a lawsuit in the United States District Court for the District of Maryland. Their claims included religious discrimination under Title VII of the Civil Rights Act and two disability discrimination claims under the Americans with Disabilities Act (ADA): one for unlawful medical inquiry and one for being “regarded as” disabled due to their unvaccinated status. The district court dismissed all claims, concluding that the plaintiffs had not sufficiently pleaded that their objections were based on religious beliefs and finding that neither ADA theory was viable because vaccination status is not equivalent to a disability.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s decision de novo. The Fourth Circuit held that the plaintiffs’ complaints plausibly alleged that their opposition to the vaccine mandate was an essential part of their religious faith and that their refusal to be vaccinated was connected to those beliefs. Therefore, the court found that the district court erred in dismissing the Title VII religious discrimination claims at the pleading stage. However, the Fourth Circuit affirmed the dismissal of both ADA claims, holding that an inquiry into vaccination status is not a disability-related inquiry and that being unvaccinated does not constitute a physical or mental impairment under the ADA. The case was affirmed in part, vacated in part, and remanded for further proceedings on the Title VII claims. View "Finn v. Humane Society of the United States" on Justia Law

The plaintiff worked as an Admissions Coordinator at a Maryland hospital’s Center for Eating Disorders, where her duties required frequent in-person contact with medically vulnerable patients and other staff. During the COVID-19 pandemic, the hospital implemented a vaccine mandate for all employees, following state health directives and public health guidance. The hospital allowed employees to request religious or medical exemptions, evaluating each on a case-by-case basis. The plaintiff requested a religious exemption, which was denied after the hospital determined her role could not be performed remotely and that accommodating her would pose risks to patient safety. She was terminated after refusing vaccination.After her termination, the plaintiff filed a discrimination charge with the EEOC and then sued the hospital in the United States District Court for the District of Maryland, alleging a violation of Title VII for failure to accommodate her religious beliefs. The district court granted summary judgment to the hospital, finding that exempting the plaintiff from the vaccine requirement would have created an undue hardship by jeopardizing patient safety and increasing the risk of COVID-19 outbreaks in a sensitive healthcare environment.On appeal, the United States Court of Appeals for the Fourth Circuit reviewed the district court’s summary judgment ruling de novo. The Fourth Circuit held that, under the standard clarified by the Supreme Court in Groff v. DeJoy, the hospital met its burden to show that granting the requested religious accommodation would have resulted in substantial increased costs and significant health and safety risks, both to patients and staff. The court also found that the hospital properly considered alternative accommodations and the aggregate impact of granting similar exemptions. The Fourth Circuit affirmed the district court’s judgment in favor of the hospital. View "Hall v. Sheppard Pratt Health System" on Justia Law

A professor was hired by a university in 2014 as a tenure-track Assistant Professor with a starting salary at the lowest end of the pay scale for her department. Over the next several years, she was denied promotions, demoted to at-will status, and claims she was paid less than male colleagues. She alleges that these actions were motivated by sex discrimination and retaliation for her complaints, including derogatory statements allegedly made by a department chair about her gender and sexual orientation. She filed charges with the Equal Employment Opportunity Commission (EEOC) and, after leaving the university, brought suit alleging violations of federal and state anti-discrimination laws.The United States District Court for the District of Maryland granted summary judgment to the university and individual defendants on all claims. The court found that her Title VII claims regarding the 2019 and 2020 promotion denials were procedurally barred—one as untimely and the other for failure to exhaust administrative remedies. The court also found that the evidence did not support her claims of sex discrimination, wage discrimination, or retaliation, concluding that the university’s stated reasons for its actions were legitimate and not pretextual.The United States Court of Appeals for the Fourth Circuit reviewed the case de novo. It affirmed the district court’s ruling that the Title VII claims related to the 2019 and 2020 promotion denials were procedurally barred. However, it reversed the grant of summary judgment on the remaining claims, holding that genuine disputes of material fact existed regarding sex discrimination in the 2016 promotion denial, retaliation, and wage discrimination. The court also held that the procedural bars of Title VII did not apply to the plaintiff’s claims under Title IX, Section 1983, or Maryland state law for the 2019 and 2020 promotion denials. The case was remanded for further proceedings on those claims. View "Hollis v. Morgan State University" on Justia Law