Justia U.S. 2nd Circuit Court of Appeals Opinion Summaries

Robert Guthrie, a former employee of Rainbow Fencing Inc. (RFI), filed a lawsuit seeking unpaid wages and statutory damages for RFI's failure to provide wage notices and wage statements as required by New York law. Guthrie worked as a welder for RFI from 2014 to 2021 and claimed he was not paid for overtime hours. The district court entered a default judgment for the unpaid wages but dismissed Guthrie's claim for statutory damages, ruling that he lacked standing because he did not allege an injury-in-fact resulting from the failure to provide the required notices and statements.The United States District Court for the Eastern District of New York initially reviewed the case. The court granted a default judgment for Guthrie's unpaid wages but dismissed his claim for statutory damages due to lack of standing. The court concluded that Guthrie did not allege a concrete injury-in-fact caused by the absence of wage notices and statements, which is necessary to meet the case-or-controversy requirement of Article III.The United States Court of Appeals for the Second Circuit reviewed the case on appeal. The court affirmed the district court's decision, agreeing that Guthrie lacked standing to pursue statutory damages. The appellate court held that a plaintiff must allege a concrete injury-in-fact resulting from the statutory violation to have standing. Guthrie's general claims about potential harms did not suffice, as he failed to link these potential harms to any actual injury he experienced. Therefore, the court concluded that Guthrie did not meet the requirements for Article III standing and affirmed the dismissal of his claim for statutory damages. View "Guthrie v. Rainbow Fencing Inc." on Justia Law

Plaintiff Joseph Pessin, representing himself and others similarly situated, sued JPMorgan Chase & Company (JPMC), the JPMorgan Chase Retirement Plan, and its fiduciaries under the Employee Retirement Income Security Act of 1974 (ERISA). Pessin alleged that the Defendants failed to provide adequate disclosures to pension plan participants after converting the retirement plan from a traditional defined benefit plan to a cash balance plan. Specifically, Pessin claimed that the Defendants did not properly inform participants about the "wear-away" effect, which could freeze their benefits until the cash balance exceeded the previously accrued benefits.The United States District Court for the Southern District of New York dismissed Pessin’s amended complaint for failure to state a claim. The court found that the Defendants had provided sufficient disclosures explaining the retirement plan's workings and did not mislead participants about the conversion's impact on their accrued benefits. The court concluded that the summary plan descriptions (SPDs) and benefit statements were adequate and that the Defendants did not breach their fiduciary duties under ERISA.The United States Court of Appeals for the Second Circuit reviewed the case. The court agreed with the district court that the Defendants sufficiently disclosed the wear-away effect and that the SPDs clearly explained how benefits would be calculated. However, the appellate court disagreed with the district court's finding that the Defendants complied with ERISA § 105(a) regarding annual pension benefit statements. The court held that the benefit statements did not properly indicate the total benefits accrued, as they only included the cash balance amount and not the higher minimum benefit from the prior plan. Consequently, the court found that Pessin adequately alleged a breach of fiduciary duty by the JPMC Board for failing to monitor the JPMC Benefits Executive's performance regarding the benefit statements.The Second Circuit affirmed the district court's decision in part, reversed it in part, and remanded the case for further proceedings consistent with its opinion. View "Pessin v. JPMorgan Chase" on Justia Law

In this case, the plaintiff, Patricia Olivieri, alleged that her employer, Stifel, Nicolaus & Company, Incorporated, and her manager, Neil Isler, subjected her to sexual harassment and a hostile work environment. Olivieri claimed that Isler sexually assaulted and harassed her, and that after she reported his behavior, she faced retaliation and continued harassment from Stifel and other defendants. Olivieri's allegations included inappropriate comments, physical contact, and retaliatory actions such as changes in her job responsibilities and work environment.The United States District Court for the Eastern District of New York initially granted the defendants' motion to compel arbitration based on an arbitration agreement in Olivieri's employment contract. However, after the enactment of the Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act of 2021 (EFAA), Olivieri moved for reconsideration. The district court vacated its earlier decision, concluding that Olivieri's claims accrued after the EFAA's effective date, making her arbitration agreement voidable under the new law.The United States Court of Appeals for the Second Circuit reviewed the district court's decision. The appellate court agreed with the lower court, applying the continuing violation doctrine to determine that Olivieri's hostile work environment claims accrued after the EFAA's effective date of March 3, 2022. The court held that the EFAA applied to Olivieri's claims, rendering her arbitration agreement invalid and unenforceable. Consequently, the Second Circuit affirmed the district court's order denying the motion to compel arbitration. View "Olivieri v. Stifel, Nicolaus & Company, Inc." on Justia Law

Scott Lupia, a locomotive engineer for New Jersey Transit Rail Operations, Inc. (NJT), was injured when the air conditioning (A/C) unit in his cab malfunctioned, causing the temperature to rise to 114 degrees Fahrenheit. Despite notifying his supervisors, Lupia was instructed to operate the train, leading to his collapse from heat exhaustion and subsequent permanent injuries. Lupia filed a lawsuit under the Federal Employers’ Liability Act (FELA), alleging that NJT violated the Locomotive Inspection Act (LIA) by failing to maintain the locomotive's parts and appurtenances, including the A/C unit, in safe operating condition.The United States District Court for the Southern District of New York denied NJT's motion for summary judgment, holding that a temperature control system, including an A/C unit, is considered a "part and appurtenance" of a locomotive under the LIA. The court found sufficient evidence that NJT's failure to maintain the A/C unit in proper condition posed an unnecessary danger of personal injury. During the trial, the court allowed Lupia to introduce a report to impeach NJT’s witness and permitted arguments regarding noneconomic damages. The jury awarded Lupia significant damages for lost earnings and pain and suffering.The United States Court of Appeals for the Second Circuit reviewed the case and affirmed the District Court's judgment. The appellate court agreed that a temperature control system is an integral part of a locomotive and that NJT was required to maintain the A/C unit in safe operating condition once it chose to use it as part of its temperature control system. The court also found no abuse of discretion in the District Court's evidentiary rulings and its decision to allow arguments on noneconomic damages. View "Lupia v. New Jersey Transit Rail Operations, Inc." on Justia Law

Manoucheka Francois, a train conductor for Metro-North Commuter Railroad Company, was injured in a car crash while being transported by a taxi hired by her employer. The taxi driver, Michael Cellante, had consumed four to five shots of alcohol before picking her up. As a result, the taxi crashed, and Francois sustained injuries.Francois sued Metro-North under the Federal Employers’ Liability Act (FELA), alleging both direct liability for negligently hiring the impaired taxi driver and vicarious liability for the driver’s negligence. The United States District Court for the Southern District of New York granted summary judgment in favor of Metro-North on both theories. The court found no evidence that Metro-North could have foreseen the driver’s intoxication, thus negating direct liability. It also concluded that the driver’s act of drinking removed him from the scope of his agency, precluding vicarious liability.The United States Court of Appeals for the Second Circuit reviewed the case. The court affirmed the district court’s decision regarding direct liability, agreeing that Metro-North had no reason to foresee the driver’s intoxication. However, the court vacated the summary judgment on vicarious liability. It held that whether the driver acted within the scope of his agency while driving Francois, despite being impaired, presented a triable issue of fact. The court emphasized that in FELA cases, plaintiffs enjoy a relaxed burden of proof, and issues of agency and foreseeability should generally be decided by a jury.The Second Circuit thus affirmed the district court’s ruling on direct liability, vacated the ruling on vicarious liability, and remanded the case for further proceedings. View "Francois v. Metro-North Commuter Railroad Co." on Justia Law

Broadway producer Garth Drabinsky alleged that the Actors’ Equity Association, a union representing theater actors and stage managers, unlawfully boycotted, defamed, and harassed him during his production of the musical Paradise Square. Drabinsky brought antitrust claims and New York state tort claims against the union.The United States District Court for the Southern District of New York held that Drabinsky’s antitrust claims were barred by the statutory labor exemption derived from the Clayton Antitrust Act of 1914 and the Norris-LaGuardia Act of 1932. The court also held that his tort claims were barred under Martin v. Curran, a New York state case that requires a plaintiff seeking to hold a union liable for tortious wrongs to allege the individual liability of every single member.The United States Court of Appeals for the Second Circuit affirmed the lower court's decision. The court concluded that an antitrust plaintiff suing a union bears the burden of proving that the statutory labor exemption does not apply. The court found that Drabinsky failed to meet this burden, as the union was acting in its self-interest and did not combine with non-labor groups. The court also agreed with the lower court that Drabinsky's state-law tort claims were barred by the Martin v. Curran rule. View "Drabinsky v. Actors' Equity Association" on Justia Law

The case involves Amazon.com Services LLC and the National Labor Relations Board (NLRB). The NLRB alleged that Amazon committed an unfair labor practice by discharging an employee for engaging in protected concerted activity. While the charge was pending before the Board, the Board sought temporary injunctive relief, including the employee’s reinstatement. The district court found "reasonable cause" to believe Amazon committed an unfair labor practice in terminating the employee. However, it concluded that ordering Amazon to cease and desist from committing certain violations of the Act was "just and proper," but that ordering Amazon to reinstate the employee was not.The district court's decision was appealed to the United States Court of Appeals for the Second Circuit. The appellate court found that the district court did not adequately explain why the cease-and-desist order was just and proper, particularly in light of its conclusion that the employee’s reinstatement was not. Therefore, the injunction was vacated in part. The court noted that the district court's lack of explanation for granting the cease-and-desist order, coupled with its explicit, undisputed findings in rejecting the request to order the employee's reinstatement, cast serious doubt on the propriety of the cease-and-desist order. View "Poor v. Amazon.com Services LLC" on Justia Law

The case involves Roman Sharikov, an employee of Philips Medical Systems MR, Inc., who was terminated after refusing to comply with the company's COVID-19 health and safety policies, including a vaccination mandate. Sharikov alleged that Philips discriminated against him because it regarded him as having a disability or a record of a disability and retaliated against him after he objected to the measures.The United States District Court for the Northern District of New York dismissed Sharikov's claims, stating that he failed to state a claim upon which relief could be granted. The court found that Philips' company-wide COVID safety and vaccine policies did not infringe on Sharikov's rights under the Americans with Disabilities Act (ADA). The court also concluded that Sharikov failed to plead a plausible retaliation claim because the company-wide policies that he failed to comply with, resulting in the termination of his employment, were in place before he began his alleged protected activity.On appeal, the United States Court of Appeals for the Second Circuit affirmed the lower court's decision. The court agreed that Philips' company-wide COVID-19 health and safety measures did not discriminate against Sharikov under the ADA. The court also found that Sharikov failed to establish a causal connection between his protected activity and his termination, thus failing to state a plausible retaliation claim. View "Sharikov v. Philips Medical Systems MR, Inc." on Justia Law

The Trustees of the New York State Nurses Association Pension Plan (the Trustees) and White Oak Global Advisors, LLC (White Oak) entered into an investment management agreement, which included an arbitration clause. The Trustees later brought several fiduciary duty claims against White Oak under the Employee Retirement Income Security Act (ERISA), which were resolved through arbitration. The arbitrator issued an award in favor of the Trustees, which the Trustees sought to confirm in the United States District Court for the Southern District of New York.White Oak appealed the confirmation, arguing that the district court lacked jurisdiction and that the court erroneously interpreted the award. The United States Court of Appeals for the Second Circuit affirmed the district court's jurisdiction, finding that the Trustees' petition to confirm the award was cognizable under ERISA § 502(a)(3). The court also affirmed the district court's interpretation of the award regarding the disgorgement of pre-award interest and the "Day One" fees. However, the court vacated and remanded the district court's confirmation of the disgorgement of White Oak's "profits," finding the award too ambiguous to enforce. The court also vacated and remanded the district court's order for White Oak to pay the Trustees' attorneys' fees and costs, finding the district court's findings insufficiently specific. View "Trustees of the NYSNAPP v. White Oak Glob. Adv." on Justia Law

The case involves Ramon Dejesus Cedeno, an employee of Strategic Financial Solutions, LLC, and a participant in its Strategic Employee Stock Ownership Plan. Cedeno sued the company, its trustee Argent Trust Company, and other defendants under the Employee Retirement Income Security Act (ERISA), alleging that a transaction caused the Plan to incur substantial losses and that Argent breached fiduciary duties owed to Plan participants. The defendants moved to compel arbitration under the Federal Arbitration Act (FAA), pointing to a provision in the Plan’s governing document that required Plan participants to resolve any claims related to the Plan in arbitration.The United States District Court for the Southern District of New York denied the motion, reasoning that the agreement was unenforceable because it would prevent Cedeno from effectuating rights guaranteed by Congress through ERISA, namely, the plan-wide relief available under Section 502(a)(2) to enforce the rights established in ERISA Section 409(a).On appeal, the United States Court of Appeals for the Second Circuit affirmed the district court's decision. The court held that the arbitration provision is unenforceable because it would prevent Cedeno from pursuing the Plan-wide remedies Sections 409(a) and 502(a)(2) unequivocally provide. The court concluded that the entire arbitration provision is null and void due to a non-severability clause in the Plan. View "Cedeno v. Sasson" on Justia Law