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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

McConnell v. Chauffeurs, Teamsters & Helpers Local 445

Plaintiff William McConnell filed a lawsuit against Chauffeurs, Teamsters and Helpers Local 445, alleging the Union retaliated against him for his criticism of their contract policies. McConnell claimed he was removed from hiring lists and faced false charges leading to his dismissal as a business agent. He asserted violations of his free speech and due process rights under the Labor-Management Reporting and Disclosure Act (LMRDA). Although his initial grievance with the NLRB was dismissed, the court found it did not bar the LMRDA action. However, the court ultimately granted the defendants' motion to dismiss, ruling that McConnell's LMRDA claims were time-barred by the six-month statute of limitations applicable to unfair labor practices.

LMRDA claimsUnion retaliationFree speech rights (Union)Due process (Union discipline)Statute of limitationsNational Labor Relations Act (NLRA)Unfair labor practicesExclusive NLRB jurisdictionFair representation suitsLabor-Management Reporting and Disclosure Act
References
19
Case No. MISSING
Regular Panel Decision

Nardolillo v. Sovinsky

Plaintiffs, members of the Tile, Marble and Terrazzo Helpers Subordinate Union No. 8, sought to recover funds contributed by their employer to a trust fund. They argued that the discontinuation of employer contributions rendered them ineligible for benefits, making the trust's purpose impossible and leading to unjust enrichment by the fund. Defendants countered that such payments would violate the trust agreement and IRS provisions, maintaining that plaintiffs remained eligible. The court determined that the fund was a common trust, not individual escrowed accounts, and upheld the trustees' interpretation that ensured plaintiffs' continued eligibility, preventing a forfeiture of rights. Consequently, the plaintiffs' motion was denied, and the defendants' motion to dismiss was granted.

Union Trust FundEmployee BenefitsEmployer ContributionsTrust AgreementBenefit EligibilityFund AdministrationBreach of TrustFiduciary DutyDismissal MotionLabor-Management Relations Act
References
6
Case No. 2016-08-0669
Regular Panel Decision
Nov 30, 2016

Holyfield, Eve v. Senior Helpers

Eve Holyfield, a caregiver, filed a Request for Expedited Hearing seeking medical and temporary disability benefits for scabies she claimed developed while caring for a client. Her employer, Senior Helpers, and their insurance carrier, Travelers Commercial Casualty Co., denied the claim, asserting a lack of work-related causation. The Court of Workers' Compensation Claims at Memphis, presided over by Judge Jim Umsted, conducted a file review. The Court weighed conflicting medical opinions, siding with dermatologist Dr. James Turner who discounted a work-related cause, over Nurse Practitioner Floyd Gresham. Consequently, the Court denied Holyfield's request for benefits, finding her unlikely to prevail on the issue of causation.

ScabiesOccupational InjuryCausation DisputeMedical Expert TestimonyWorkers' Compensation LawExpedited ProceedingsFile Review DecisionDermatological ConditionEmployer ResponsibilityInsurance Claim Denial
References
2
Case No. MISSING
Regular Panel Decision
Jun 17, 1977

Prate v. Freedman

This case involved white applicants who sued the City of Rochester, New York, alleging reverse discrimination in police officer hiring practices that favored minority applicants. The plaintiffs challenged a prior consent decree from Howard v. Freedman, which had established affirmative action measures. Chief Judge Curtin dismissed the consolidated actions, ruling it an impermissible collateral attack on the Howard decree due to the plaintiffs' failure to intervene timely. The court also held that the Constitution permits limited preferences for previously discriminated groups and dismissed pendent state law claims as superseded by federal law. Finally, the court awarded attorney fees to the defendant-intervenors, finding the plaintiffs' suit unreasonable and vexatious.

Reverse DiscriminationAffirmative ActionPolice RecruitmentEmployment LawCollateral Attack DoctrineConsent DecreeJudicial ReviewAttorney Fee AwardSubject Matter JurisdictionState Law Preemption
References
15
Case No. MISSING
Regular Panel Decision

Transit-mix Concrete Corp. v. Local Union No. 282, International Brotherhood of Teamsters, Chauffeurs, Warehousemen & Helpers of America

Transit-Mix Concrete Corporation and Local Union No. 282, parties to collective bargaining agreements, had a dispute regarding seniority rights of former Colonial Sand and Stone Co. Inc. drivers after Transit-Mix acquired Colonial's assets. An arbitrator's 1979 award on employee seniority was later found by the NLRB and Second Circuit to have been improperly communicated by Local 282, leading to a breach of its duty of fair representation. Consequently, Local 282 was ordered to request reopening the arbitration to provide notice and a retroactive grace period for affected employees. Transit-Mix sought to stay this arbitration, arguing against reopening a final award and raising procedural defenses like statute of limitations and laches. The court, emphasizing the broad arbitration clause in their agreements, denied Transit-Mix's petition to stay and granted Local 282's cross-petition to compel arbitration, deferring the merits and procedural questions to the arbitrator.

ArbitrationCollective Bargaining AgreementSeniority DisputeDuty of Fair RepresentationNLRB OrderLabor-Management DisputesArbitration EnforcementJudicial Review of ArbitrationFederal Labor LawUnion Liability
References
20
Case No. MISSING
Regular Panel Decision

Dallas General Drivers, Ware-Housemen & Helpers v. Wamix, Inc.

Wamix, Inc. initiated a suit for damages and sought a temporary injunction against Dallas General Drivers, Warehousemen & Helpers, Local Union 745 and several individuals. The core of the dispute involved allegations of unlawful secondary picketing by the defendants, which interfered with Wamix's business by causing its customers' employees to stop work. The trial court granted the temporary injunction, concluding that the defendants' actions violated Texas state anti-trust and anti-monopoly laws, and noting that the National Labor Relations Board had declined jurisdiction. The appellate court reviewed the decision and affirmed the trial court's order, asserting state court jurisdiction over the damage suit and the power to grant injunctive relief to maintain the status quo.

Labor DisputeTemporary InjunctionSecondary PicketingUnlawful ConspiracyDamagesTexas LawState JurisdictionNational Labor Relations BoardFreedom of SpeechAnti-trust
References
7
Case No. MISSING
Regular Panel Decision

Informal Opinion No.

The opinion addresses whether Rockland County can mandate that 50% of public works project hires be county residents. It analyzes various constitutional clauses, finding the Commerce Clause not an impediment due to the 'market participant' doctrine and congressional authorization for federal funds. It distinguishes a local law from a state law concerning the Privileges and Immunities Clause, suggesting a local law targeting non-county residents (including other state residents) might be valid. The opinion also examines the Equal Protection Clause and bona fide residency requirements, concluding they generally pass the rational basis test. However, it cautions that such a local law must not violate General Municipal Law § 103 competitive bidding requirements, which would be a factual determination on a case-by-case basis.

Public Works ProjectsResident Hiring RequirementsLocal Law AuthorizationCommerce ClausePrivileges and Immunities ClauseEqual Protection ClauseCompetitive BiddingGeneral Municipal LawHome Rule LawMarket Participant Doctrine
References
17
Case No. MISSING
Regular Panel Decision

Boss v. International Brotherhood of Boilermakers, Iron Shipbuilders, Blacksmiths, Forgers & Helpers

In this class action, plaintiffs alleged that the International Brotherhood of Boilermakers, Iron Shipbuilders, Blacksmiths, Forgers and Helpers breached its duty of fair representation and collective bargaining agreements under the Labor Management Relations Act. Plaintiffs, who are New York residents qualified as 'boilermakers', claimed they were denied employment due to actions of local unions acting as agents of the International. The central issue was whether the International could be held vicariously liable for the local unions' acts based on agency principles. The court reviewed federal case law, particularly emphasizing the 'control' and 'autonomy' of local unions, citing Carbon Fuel Co. v. United Mine Workers. Finding no evidence that the International instigated or ratified the complained-of acts, and noting the locals retained autonomy despite the International being the sole signatory, the court granted the defendant's motion for summary judgment and denied the plaintiffs' motion for class certification.

Labor LawAgency LawDuty of Fair RepresentationCollective Bargaining AgreementsVicarious LiabilitySummary JudgmentClass ActionLocal UnionsInternational UnionsLabor Management Relations Act
References
10
Case No. MISSING
Regular Panel Decision

United Brotherhood of Carpenters Joiners v. Tile Helpers Union Local 88

This case involves the disaffiliation of Tile Finishers Union Local No 88 (old Local 88) from its parent, TMT International Union, to join the Bricklayers. Subsequently, TMT International merged into United Brotherhood of Carpenters and Joiners of American (the Carpenters). The Carpenters, as successor to TMT International, sued the new local (Tile Helpers Union Local 88), a Mortuary Fund, and former officers, seeking damages and asset transfer, claiming old Local 88 improperly transferred assets into a mortuary account to evade forfeiture to TMT International. The court found the Carpenters' attempt to establish a trusteeship over old Local 88 invalid. However, it upheld the validity of establishing the mortuary fund by old Local 88, despite the intention to evade forfeiture, as the local's by-laws implicitly permitted such funds. Claims regarding other asset expenditures and return of books and records were referred to a Magistrate Judge.

DisaffiliationUnion AssetsMortuary FundTrusteeshipLabor-Management Relations ActLabor-Management Reporting and Disclosure ActSummary JudgmentLocal UnionInternational UnionBreach of Contract
References
3
Case No. MISSING
Regular Panel Decision

O'Neil v. Roman Catholic Diocese

A student worker at St. Ephrem’s Church (the plaintiff) experienced sexual harassment from a visiting priest. After a particularly egregious incident, she informed other parish priests who promptly referred her to law enforcement. The plaintiff subsequently sued the Roman Catholic Diocese of Brooklyn and St. Ephrem’s Church for sexual harassment, negligence, negligent hiring, and negligent supervision, arguing they should have known of the priest's propensity. The Supreme Court, Kings County, granted summary judgment to the Diocese defendants, dismissing the plaintiff's claims, finding they lacked actual or constructive knowledge. The appellate court affirmed this decision, concluding that the defendants met their burden in demonstrating no prior knowledge of the visiting priest's conduct and acted diligently once informed.

Sexual HarassmentHostile Work EnvironmentNegligenceNegligent HiringNegligent SupervisionSummary JudgmentEmployer LiabilityConstructive KnowledgeDiscriminationNew York City Human Rights Law
References
8
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