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Case Summaries

Labor & Employment Law

[11/21] Royall v. Nat'l Ass'n of Letter Carriers, AFL-CIO
In an employment-discrimination case, summary judgment for defendant is affirmed where there was no evidence from which a reasonable jury could find that defendant's reason for terminating plaintiff's employment was a pretext for unlawful discrimination.

[11/21] Martin v. Toledo Cardiology Consultants, Inc.
In a case brought by plaintiff-employee lab technician under the Age Discrimination in Employment Act (ADEA), and Title VII of the Civil Rights Act of 1964, grant of summary judgment in favor of defendant-employer cardiology office and dismissal of case is reversed and remanded where: 1) in addressing the plaintiff-employee's prima facie age discrimination case, the district court impermissibly made factual determinations and improperly drew inferences in favor solely of the defendant; and similarly 2) with the retaliation claim, the district court impermissibly made factual findings and did not view the evidence in the light most favorable to the plaintiff, the non-moving party.

[11/20] Artesia Dairy v. Agric. Labor Relations Bd.
Defendant-Labor Board's decision excluding certain persons employed by plaintiff-dairy from voting on the United Farm Workers of America's (UFW) petition to represent plaintiff's agricultural employees is reversed in part and affirmed in part where: 1) the nephews of plaintiff's owners did not fall under the regulation that excluded the owner's children from voter eligibility; 2) based on the evidence presented, defendant correctly concluded that the individual who maintained the lawn area around the dairy was not an agricultural employee; 3) it was appropriate for defendant to apply a substantiality test in determining whether an individual who engaged in childcare and cleaning was an agricultural employee; and 4) substantial evidence supported defendant's conclusion that the two individuals with supervisory duties were supervisors and thus ineligible to vote.

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