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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

Rhodes v. Bedford County, Tenn.

This case involves an action brought by employees of the Bedford County Ambulance Service against Bedford County, Tennessee, alleging violations of Sections 7 and 8 of the Fair Labor Standards Act (FLSA), specifically regarding minimum wage and overtime provisions. The dispute arose following the Supreme Court's Garcia decision, which made FLSA applicable to state and municipal employees, and subsequent Congressional amendments aimed at easing the transition for local governments. Plaintiffs argued that the county failed to pay proper minimum wage and overtime from April 15, 1986, to June 30, 1986, and that the subsequent change from salaried to hourly pay on July 1, 1986, constituted a scheme to avoid overtime requirements by artificially deflating the regular rate. The court found that the county’s failure to provide proper overtime payments was a continuous violation, thus plaintiffs’ action was not barred by the statute of limitations. The court granted summary judgment for the plaintiffs on the issue of liability under Section 7 of the FLSA, finding both periods of violation. Liquidated damages were awarded for the initial period, but a question of material fact remained for the later period. The defendant's motion for summary judgment was denied.

Fair Labor Standards ActOvertime CompensationMinimum Wage LawPublic Agency EmploymentMunicipal Government LiabilitySummary Judgment MotionsContinuing Violation DoctrineStatute of Limitations FLSAWage and Hour DisputeAntidiscrimination in Employment
References
7
Case No. MISSING
Regular Panel Decision

In re Voll

The debtors, Patrick L. Voll and Linda P. Voll, filed for Chapter 13 bankruptcy. The New York State Department of Taxation and Finance ("Tax Department") willfully violated the automatic stay by continuing to garnish Mrs. Voll's wages post-petition, despite receiving notice of the bankruptcy filing. The garnishment ceased, and the improperly deducted funds were returned after the Debtors filed a motion for sanctions. The court found that the Tax Department willfully violated the automatic stay. However, the court denied the Debtors' claim for emotional distress damages, finding they failed to provide clear and convincing evidence of significant emotional harm distinct from the general stressors of bankruptcy and other life events. The court awarded the Debtors $13,625.00 in attorneys' fees as actual damages for the willful violation of the stay.

Bankruptcy LawAutomatic Stay ViolationWage GarnishmentSanctions MotionAttorneys' Fees AwardChapter 13 BankruptcyTaxation and FinanceActual DamagesEmotional Distress ClaimsWillful Violation
References
28
Case No. MISSING
Regular Panel Decision

McKinney v. Eastman Kodak Co.

Barbara M. McKinney, a pro se plaintiff, sued Eastman Kodak Co. for employment discrimination. She later moved to amend her complaint to include claims for age discrimination under ADEA and New York State Human Rights Law, sex discrimination under Title VII, FMLA violations, and retaliation under ADEA. The court partially granted and partially denied the motion. The court denied leave to amend for sex discrimination, FMLA violations, and the disparate impact theory of age discrimination, finding them not reasonably related to her original EEOC complaint. The motion was granted only to allow McKinney to restate her disparate treatment age discrimination claim and her retaliation claim under the ADEA, specifically for events occurring on or after April 28, 1995, while denying claims based on earlier events that did not constitute a continuing violation.

Age DiscriminationRetaliationDisparate TreatmentMotion to Amend ComplaintEEOC ExhaustionContinuing Violation DoctrineEmployment LawFederal Rules of Civil Procedure Rule 15Title VIIADEA
References
34
Case No. MISSING
Regular Panel Decision

Chicca v. St. Luke's Episcopal Health System

Plaintiff Michael Chicca sued St. Luke's Episcopal Health System alleging violations of the Fair Labor Standards Act (FLSA) due to alleged misclassification as an exempt employee, denying him overtime pay. The central issue was whether Chicca's duties as an Information Protection Analyst qualified for the FLSA's professional (computer employee) or administrative exemptions. Chicca described his role as limited to data entry and facilitating reviews, while St. Luke's contended he performed systems analysis, documented procedures, identified risks, and led change management meetings, implying discretion and independent judgment. The court found genuine issues of material fact concerning Chicca's primary duties under both exemptions, thus denying summary judgment on the exemption status for both parties. However, the court granted part of the defendant's motion, ruling that the applicable statute of limitations is two years, rejecting the plaintiff's arguments for a three-year period based on willful violation or a continuing violation theory.

FLSAFair Labor Standards ActEmployee MisclassificationOvertime ExemptionSummary JudgmentProfessional ExemptionAdministrative ExemptionComputer ProfessionalInformation Protection AnalystData Entry
References
30
Case No. MISSING
Regular Panel Decision

Spicer v. Beaman Bottling Co.

This case addresses the applicability of the "continuing violation doctrine" to a sexual harassment claim filed under the Tennessee Human Rights Act. Plaintiff Judy G. Spicer alleged sexual harassment and retaliatory discharge by her supervisor, Don Hollingshead, and employer, Beaman Bottling Company. The Supreme Court adopted the continuing violation doctrine, allowing a plaintiff to challenge a series of discriminatory acts if one falls within the one-year statute of limitations. However, the Court found that all acts of sexual harassment against Spicer occurred more than one year before she filed suit, and the alleged retaliatory actions did not constitute a continuing violation or discrimination based on gender. Therefore, the plaintiff's action was deemed time-barred, and the Court of Appeals' judgment affirming dismissal was affirmed.

Sexual HarassmentEmployment DiscriminationContinuing Violation DoctrineStatute of LimitationsTennessee Human Rights ActRetaliatory DischargeHostile Work EnvironmentSupervisory LiabilityWorkplace DiscriminationAppellate Review
References
19
Case No. MISSING
Regular Panel Decision
Aug 11, 2014

In re Haemmerle

The debtor, Thomas Haemmerle, moved to hold Wells Fargo Bank, N.A. in civil contempt for violating his Chapter 7 bankruptcy discharge injunction. Haemmerle's personal liability on a mortgage loan was discharged in 2006, despite Wells Fargo not being initially scheduled as a creditor. After the loan defaulted in 2011, Wells Fargo pursued collection efforts. Despite being notified of the discharge in 2013, Wells Fargo continued to make numerous phone calls and send letters asserting Haemmerle's personal liability. The court ruled that Haemmerle's personal liability was discharged by operation of law and that Wells Fargo knowingly and willfully violated the discharge injunction, awarding attorneys' fees and $69,500 in punitive damages.

Bankruptcy LawDischarge InjunctionCivil ContemptCreditor NotificationNo-Asset BankruptcyPersonal LiabilityIn Rem RightsPunitive DamagesAttorneys' FeesEmotional Distress Claims
References
37
Case No. MISSING
Regular Panel Decision

Xue Ming Wang v. Abumi Sushi Inc.

Plaintiff Xue Ming Wang sued Abumi Sushi Inc. and Qing Zhong Li for Fair Labor Standards Act (FLSA), New York Labor Law (NYLL), and New York General Business Law § 349 violations, stemming from his employment as a delivery worker. The core legal dispute centered on whether the defendants, who acquired the restaurant's assets in June 2015, were liable for violations predating the sale under successor liability doctrines. The Court considered both traditional common-law and federal common-law 'substantial continuity' tests. It concluded that the traditional test did not apply due to lack of ownership continuity, and under the 'substantial continuity' test, the plaintiff failed to prove the defendants had notice of the alleged pre-sale violations. Consequently, the Court granted the defendants' motion for partial summary judgment, denied the plaintiff's motion, and dismissed claims related to pre-June 2, 2015 conduct against the appearing defendants.

Successorship LiabilityFair Labor Standards ActNew York Labor LawGeneral Business Law § 349Wage and Hour ViolationsAsset SaleConstructive NoticeSummary JudgmentEmployment LawLabor Dispute
References
45
Case No. MISSING
Regular Panel Decision

Arredondo v. Estrada

Plaintiffs, Ricardo Arredondo, Jr., Richard Rabino, and Mario Torrez, all former employees of Weatherford International, LLC, filed suit for damages arising out of abusive treatment and sexual harassment by their supervisor, Joey Estrada. The abuse included physical assaults, referred to as “nubbings,” and demeaning vulgarities. Plaintiffs brought federal claims under Title VII of the Civil Rights Act of 1964 for discrimination based upon sex, sexual harassment, hostile work environment, constructive discharge, and retaliation, as well as state law claims for assault, intentional infliction of emotional distress, and negligent hiring, supervision, training, and retention against Weatherford. The Court granted Weatherford’s motion for summary judgment on the Title VII retaliation claims, intentional infliction of emotional distress claims, and negligent hiring, supervision, training, and retention claims. The Court denied summary judgment on Plaintiffs’ Title VII sex discrimination (including sexual harassment, hostile work environment, and constructive discharge) and assault claims, ordering them to proceed to trial. The decision addressed issues of administrative remedies exhaustion, the “continuing violation” theory for limitations, proof of sex discrimination in same-sex harassment cases (including gender stereotyping), the severity and pervasiveness of the conduct, Weatherford’s Ellerth/Faragher affirmative defense, constructive discharge, and employer liability for assault (including course and scope and ratification theories), as well as the application of the Texas Workers’ Compensation Act’s exclusive remedy bar.

Sexual HarassmentHostile Work EnvironmentTitle VIISummary JudgmentEmployment DiscriminationAssault and BatteryRetaliation ClaimConstructive DischargeEmployer LiabilityWorkers' Compensation Act
References
34
Case No. MISSING
Regular Panel Decision
Mar 01, 1999

Ruiz v. Johnson

This Memorandum Opinion addresses motions to terminate the court's jurisdiction over an ongoing civil action concerning conditions in Texas prisons, Ruiz v. Estelle, initiated in 1972. The court rules that the termination provisions of the Prison Litigation Reform Act (PLRA) are unconstitutional, violating the separation of powers and due process clauses, and thus cannot be applied retroactively to the 1992 Final Judgment. Alternatively, the court finds systemic constitutional violations in three key areas: administrative segregation, inmate safety, and excessive force. Conditions in administrative segregation units (Levels II and III) are found to inflict cruel and unusual psychological suffering and inappropriately house mentally ill inmates. Prison officials are deemed deliberately indifferent to widespread inmate-on-inmate violence, sexual assault, and extortion, failing to provide reasonable protection. A pervasive culture of malicious and sadistic excessive force by correctional officers is also found unconstitutional. However, while medical and psychiatric care are deemed inadequate and often negligent, they do not meet the "deliberate indifference" standard required for an Eighth Amendment violation under current law. The court concludes that despite significant policy improvements, the Texas prison system's practices continue to violate constitutional standards in critical areas, ensuring continued judicial oversight.

Prison ConditionsEighth AmendmentCruel and Unusual PunishmentSeparation of PowersDue ProcessPrison Litigation Reform ActInmate SafetyExcessive ForceAdministrative SegregationMental Health Care
References
15
Case No. MISSING
Regular Panel Decision

Petrosky v. New York State Department of Motor Vehicles

Plaintiff Sherry Petrosky sued the New York State Department of Motor Vehicles (DMV) and individual defendants for sex and disability discrimination under Title VII, ADA, and New York State Human Rights Law. She alleged continuous sexual harassment and discrimination from 1981 to 1994, including unwelcome sexual advances, offensive comments, and physical humiliation. Additionally, she claimed discrimination due to her diabetes, including ignored requests for accommodation and abusive comments. Defendants moved to dismiss the claims, arguing they were time-barred and that plaintiff did not satisfy the continuing violation exception. The court denied the motion to dismiss, finding the plaintiff adequately pleaded a continuing violation and that her federal claims were not time-barred because a discriminatory event occurred on October 20, 1994, within the 180-day filing period. The court also retained jurisdiction over state law claims.

Workplace discriminationSex discriminationDisability discriminationSexual harassmentHostile work environmentStatute of limitationsContinuing violation doctrineMotion to dismissFederal Rule of Civil Procedure 12(b)(6)EEOC
References
15
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