What happened in 2018? Sara J. Ackermann, Esq. [email protected] 1 Agenda Recent Wisconsin and Federal Cases. Nationwide legislation (marijuana/paid leave). Ask questions ANYTIME! 2 Sex, Gender, Sexual Orientation
3 2018-2019 (U.S. Supreme Court-Pending) Whether the prohibition in Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2(a)(1), against employment discrimination because of . . . sex encompasses discrimination based on an individuals sexual orientation. Altitude Express Inc. v. Zarda (Title VII does protect pending petition 2nd Cir.). Bostock v. Clayton County, Georgia (Title VII does not protect pending petition 11th Cir.).
Note: Wisconsin law does prohibit discrimination on the basis of sexual orientation: Having a preference for heterosexuality, homosexuality or bisexuality, having a history of such a preference or being identified with such a preference. 4 2018-2019 (U.S. Supreme Court-Pending) Whether the word sex in Title VIIs prohibition on discrimination because of . . . sex, 42 U.S.C. 2000e-2(a)(1), meant gender identity and included transgender status when Congress enacted Title VII in 1964
and whether Price Waterhouse v. Hopkins prohibits employers from applying sex-specific policies according to their employees sex rather than their gender identity. R.G. & G.R. Harris Funeral Homes Inc. v. Equal Opportunity Employment (Title VII does protect pending petition 6th Cir.). Note: Wisconsin law does not prohibit discrimination on the basis of gender identity. Just Last Week: 5Th Circuit Court of Appeals in Wittmer v. Phillips dismissed a case where a transgender woman sued under Title VII
claiming she was denied a job because of her transgender status. 5 2018-2019 (U.S. Supreme Court-Pending) Whetherwhen the Equal Pay Act permits employers to pay men and women different wages for the same work where such payment is made pursuant to (i) a seniority system, (ii) a merit system, (iii) a system which measures earnings by quantity or quality of production, or (iv) a differential based on any other factor other than sex, 29 U.S.C. 206(d) (1)a prior salary is a factor other than sex. Yovino v. Rizo (Prior salary is not-pending petition 9th Cir.).
Status of pending petitions: Conference scheduled February 15. 6 Equal Rights Division vs. EEOC Wisconsin Equal Rights Division: Employee files claim. Employer files position statement (or parties mediate). ERD investigator determines Probable Cause or No Probable Cause that discrimination occurred. If Cause found, ERD sends to Hearing Division. Hearing scheduled (mini-trial).
Administrative law judge issues opinion (not published). Either party can appeal to Labor Industry Review Commission. LIRC reviews and issues opinion (published). Either party can appeal to Wisconsin local county court, court of appeals, supreme court. NOTE: Even if No Cause found, employee can still appeal to a hearing. 7 Equal Rights Division vs. EEOC Equal Employment Opportunity Commission: Employee files claim. Employer files position statement (or parties mediate).
EEOC investigator determines Reasonable Cause or No Reasonable Cause that discrimination occurred. If Cause found, EEOC attempts to conciliate (settle). If conciliation fails, EEOC issues right to sue letter or can sue on behalf of the employee if no counsel. Complaint filed in Wisconsin E/W District Court (Milwaukee/Madison). Trial scheduled. Jury trial issues verdict. Either party can appeal to Seventh Circuit (either after trial or if certain motions are denied) then to U.S. Supreme Court. NOTE: Even if No Cause found, employee can still file in federal court but less likely they will find attorney to assist them. 8
Why did HE get the job? Krueger v. County of Waupaca (WI LIRC 2018). Debra Krueger applied for promotion to captain. Male co-worker, Adam, also applied. Krueger did not get the job. Reason provided: Adam was a go getter and great with people. Debra was poor communicator. Debra files ERD charge for sex discrimination. A few months later, Debra suspended by Adam as part of citizen complaint. Three other male officers were part of the citizen complaint, only Debra suspended. Debra adds retaliation to her charge.
9 Why did HE get the job? At hearing, ALJ reviews promotion and retaliation claims: Promotion: Evidence showed Adam previously disciplined for harassment/friend with member of selection committee. This not evidence of sex discrimination. At hearing, several witnesses testified negative, angry, sharp tongue, thought everyone out to get her. Selection committee unaware of Adams previous conduct. ALJ: This might be unfair, but not discriminatory.
10 Why did HE get the job? Retaliation: PDs explanation of why Debra suspended but not male officers unpersuasive. Citizen might have only mentioned Debra by name, but that was because only name she knew. Reason for suspension was pretext for discrimination. Ruling: Disciplinary report removed from file. Pay for two days plus 12 percent interest. Attorneys fees $30,000.00. Moral of the Story?
11 Why is it only the men who are getting harassed around here? Smith v. Rosebud Farm, Inc. (7th Cir. 2018). 2003: Robert Smith worked at meat counter at grocery store. Within three weeks, male co-workers began grabbing genitals and buttocks. Smith complained repeatedly. January 2008: Filed EEOC charge. After notice of charge, co-workers advised by supervisor to cease horseplay. Co-workers commenced threatening behavior with knives
behind counter/his tires slashed in parking lot. 12 Why is it only the men who are getting harassed around here? June 2008 quits. EEOC issued right to sue. Federal jury awarded $2.2 Million (Title VII cap max is $300,000 so total reduced to $470,000). Smiths attorney: $611,388.50 in fees. Rosebud appeals to 7th Circuit. Rosebud: This is not harassment because of sex. Court: We agree that this conduct, had it been towards all
sexes, would not have constituted harassment based on sex, however, Smith offered direct evidence that only men, not women experienced the harassment. 13 Train, train, train! By January 1, 2020, California employers with at least five employees must provide sexual harassment prevention training and education to all supervisory employees and non-supervisory employees in California. (Currently 50 employees.) By October 9, 2019, employers must provide sexual harassment training to all employees located in New York State, and implement a policy with specific provisions required under law.
Connecticut and Maine have had training laws several years. Many states have laws encouraging training. Wisconsin: No mandatory law. (But we recommend it!!!) 14 Sexual Harassment Investigations Tips Interview complainant and pin down all allegations. Allow complainant to work from home or take paid leave pending outcome of the investigation. Interview witnesses, if any. Interview alleged harasser. Place alleged harasser on leave pending outcome of investigation (paid/unpaid?).
Determine if the allegations are substantiated. Determine disciplinary action if needed. Follow up with complainant for several weeks/months. 15 Sexual Harassment Investigations Tips HE SAID/SHE SAID IS NOT A FINDING. This is not criminal court beyond reasonable doubt. This is HR courtdoes the investigation deem it likely that the conduct occurred or unlikely that it occurred? Rememberyou will never know what REALLY happened! (If you did, no investigation would be needed.)
You get to decide based on your view of the evidence, so long as you can base it on reasonable factors. 16 DISABILITY 17 Didnt you know I was disabled? Dahl v. Kewaunee Care Center, LLC (WI LIRC 2018). April Dahl had diverticulitis (doctors care since 2012). April has performance issues in 2017. Progressive disciplinary action taken.
Terminated for performance. Sues for disability discrimination. ALJ finds the following: Dahl has not presented evidence of disability because it is not clear from medical file whether her doctor considered her diverticulitis to be a long-term condition. Dahl has no evidence that termination is due to disability. Case dismissed. 18 Didnt you know I was disabled? April appeals to LIRC. LIRC finds: April is disabled. She had diverticulitis (doctors care
since 2012) and that is enough. BUT, April cannot show that the decision-maker knew about the disability. Employer might have known she had stomach issues but no evidence that decisionmaker had any idea of the diverticulitis. Employer wins! Moral of this story? 19 I am not sure when I will be back Tilson v.Safilo/Solstice Sunglass Boutiques (WI LIRC 2018). Cynthia Tilson had back pain. Provided SSB multiple doctors notes excusing her from work for treatment.
Notes indicated she was prevented from gainful employment. Cynthia not eligible for FMLA. Solstice terminated her after she was out for three consecutive months with no evidence of a return date. Cynthia sued for failure to accommodate. 20 I am not sure when I will be back Cynthia alleged: She could have worked had Solstice provided her with a chair. She was wrongfully terminated.
ALJ: Complainant presented no evidence showing a request for a chair had been made. No evidence that extending her medical leave would have been a reasonable accommodationan employer cannot be expected to hold open a job indefinitely with no foreseeable return to work date. What is moral of the story? 21 Be interactiveNOT reactive! Frederick Oldenburg v. Triangle Tool Corporation (WI LIRC 2018).
Fred Oldenburg hired in February 2013 to design drawings for TTC. Fred had previous brain injury. Fred struggling to learn drawing software system though had experience with similar systems in past. Supervisor spoke to him about his lack of speed and performance deficiencies. Fred provided letter from his doctor explaining disability and suggesting accommodations. (What should TTC have done next? Hint, they did not do it.) 22 Be InteractiveNot Reactive!
In response to the letter, the supervisor fired Fred. Fred sued for disability discrimination and failure to accommodate. ALJ: The letter triggered TTCs duty to engage in the interactive process. Freds requests (more time to learn software, written reference materials, a note taker) could have assisted him in performing his job duties. While TTC can argue these accommodations wont work, how will they know until they try? 23
Be InteractiveNot Reactive! The complainant was able to work in other employment since sustaining the brain injury, and there is no reason to believe that with the right assistance he could not have managed to do the job at hand. Damages awarded: Immediate reinstatement with seniority. Backpay at 12% interest commencing April 8, 2013. Unemployment received by complainant will be repaid by TTC to the UI fund. $56,000 in attorneys fees. What is moral of this story? 24
Interactive Process Guidelines What does the employee want? What does the employees doctor say? Talk with the employee about what they want and what their doctor says. Does employee agree? Disagree? Why? Are there alternatives to what employee is requesting? (A reasonable accommodation is NOT always what the employee wants.) Document the interactive process (discussion) in writing to the employee Do not make assumptions! Never say never!
25 RELIGION 26 Didnt you get the memo? I cannot work on Sundays! Pierre v. Park Hotels and Resort (S.D. Fla. 2018). Marie Jean Pierre worked for hotel ten years. Always had Sundays off based on her religion. 2015: New kitchen manager demanded she work on Sundays. Submitted letter from pastor.
Found co-workers to swap with her but management reprimanded her. Eventually terminated for absenteeism. Jury found retaliated for exercising beliefs. Verdict $21 Million. 27 Dont fire meIll use a scrunchy! EEOC vs. United Parcel Service (E.D.N.Y.2018). Complaints go back several years. UPS Appearance Guidelines: Male employees in customer contact roles no beards long hair. EEOC files suit in 2016.
Muslim who applied for a driver helper position in Rochester, N.Y., who wears a beard as part of his religious observance, was told he had to shave to get the position. He was also told, God would understand if he shaved his beard to get a job and that he could apply for a lower-paying job if he wanted to keep his beard. 28 Dont fire meIll use a scrunchy!
Muslims and Christians at other facilities were forced to shave their beards in violation of their religious beliefs while they waited months or years for UPS to act on their requests for religious accommodation. A Rastafarian part-time load supervisor in Fort Lauderdale, who does not cut his hair as part of his religious beliefs, asked for an accommodation of the appearance policy. His manager told him he did not want any employees looking like women on (his) management team. Settlement: $4.9 Million (200 men). 29
AGE 30 You are over-qualified for this position! Kleber v. CareFusion Corp., 433 F.3d 537 (2018). CareFusion sought candidates with three to seven years of legal experience. Dale Kleber (age 58) applied - did not get interview. CF hired a 29-year-old for the position as Senior Counsel, Procedural Solutions. Sued under ADEA in federal court stating the cap on experience had a disparate impact on age.
Illinois District Court dismissed. 31 You are over-qualified for this position! Appealed to Seventh Circuit. Dismissed. Disparate impact claim under the ADEA is available only to employees, not to job applicants.
32 POTPOURRI 33 It is the staffing agencys fault! Doughty v. Kelly Services, Inc. (WI LIRC 2018) Kelly has Hiring Agreement with FedEx. The Agreement states that Kelly agrees not to hire applicants with conviction records. Butit also states that Kelly will comply with all state and federal non-discrimination laws, and in event of a conflict, the law will control.
Matt Doughty completed job application with Kelly. 34 It is the staffing agencys fault! Matt indicates on the application he has no convictions for past seven years. Kelly forwards application to FedEx. Matt does not get the job. Matt sues Kelly based on language in Hiring Agreement. Matt states Kelly is in cahoots with FedEx because FedEx has asked it to violate the law. ALJ: Language not illegal, no evidence that Kelly acted with discriminatory intent.
35 It is the staffing agencys fault! While we do not disagree that a staffing firm that discriminates against a clients employees or prospective employees may be found liable for discrimination under the Act, that did not occur in this case. Kelly did not discriminate against the complainant based upon his record, nor did it pressure FedEx to do so. FedEx made the hiring decision and Kellys only role was to forward applications so FedEx could consider them. What is moral of this story? 36
What is the real reason for my termination again? Archibald v. All Green Corporation (WI LIRC 2018). Michael A. filed wage and hour claim against AG on April 9, 2012. AG resolved the matter April 30. AG fired Michael two months later telling him it had no more work (this was not true). Michael sued, asserting retaliation for filing wage claim. 37 What is the real reason for my termination
again? Elements of retaliation. Protected activity (filed wage claim); Adverse action (was fired); and Causal connection between the two??? ALJ found that AG untruthfully and erroneously told him at discharge that it had no work available. Such dishonesty could be evidence that the employer was attempting to disguise a discriminatory motive, in this case it appears to be in keeping with a general pattern of less than open communication with employees. BUT 38
What is the real reason for my termination again? Respondent has now provided reasons for terminating the complainants employment that differ from the one it gave complaint on his last day of work and that constitute credible nondiscriminatory reasons for its actions. Evidence showed not meeting expectations. Cashed his paycheck early. Testimony by supervisors convinced judge that decision to discharge was unrelated to fact that he filed a wage claim. What is moral of this story? 39
Can I get one more Last Chance??? Cisewski v. City of Marshfield (WI LIRC 2018). Patrick Cisewskis job includes driving heavy equipment. Patrick on a last chance agreement that stated any alcohol abuse on/off job would warrant termination. (That agreement was 16-years old.) On January 7, 2012, Patrick arrested for DWI. Marshfield learned about this on February 6 and interviewed Patrick the same day. 40 Can I get one more Last Chance??? Patrick admitted to going to a bar at 5:30 p.m. the night he
was arrested. He admitted to drinking at the bar and then driving home. After interviewing Patrick, Marshfield terminated him on February 7, 2012, in violation of the last chance agreement. Patrick sued, asserting violation of Wisconsins arrest and conviction statute. 41 Can I get one more Last Chance??? Wisconsin law prevents employers from ever terminating an employee with pending charges. Only unpaid suspension IF substantially related to the job. HOWEVER, there is an exception if the employer
conducts its own investigation and terminates employee for workplace violation based solely on that investigation. 42 Can I get one more Last Chance??? ALJ: The employer contended that the complainant was in violation of his last chance agreementthough the complainant may quibble about the decision to rely upon a 16-year-old last chance agreement as a basis to terminate his employment, the commission is not permitted to second guess the respondents business decision provided they are not undertaken as pretext for discriminationwe do not sit
as a superpersonnel department that reexamines an entity's business decisionour only concern is whether the legitimate reason provided by the employer is the true one. What is moral of this story? 43 My boyfriend made me do it! Staten v. Holton Manor (WI LIRC 2018). 2013: Kynesha Staten applies for job with Manor. Fills out application regarding convictions and states: 2006 Milwaukee: expunged misdemeanor for theft. 2003 Brookfield: municipal ordinance disorderly conduct.
2011 Shorewood: disorderly conduct. Manor asked her about each incident. She said: 2006: produced an expungement order. 2003: cousin took money from store, and she was charged for being with her and driving car. 2011: self-defense domestic situation. 44 My boyfriend made me do it! Manor investigated the 2011 incident and confirmed it took place in a grocery store. Kynesha was with boyfriend, and another female approached her and said informed Kynesha she was sleeping with her boyfriend. Kynesha struck him over
a dozen times. Manor contacts Kynesha and advises not getting job due to conviction record. Kynesha sues for violation of arrest/conviction statue. 45 My boyfriend made me do it! ALJ: Should Manor have considered the expunged offense? No. An expunged conviction cannot be used as basis to deny employment even if it is substantially related. Is the disorderly conduct charge for driving cousin who stole jar of money substantially related? No. She did not
engage in theft, the act of driving not related to CNA position. Is the disorderly conduct charge for punching boyfriend substantially related? Yes. A CNA will be working with a vulnerable population of sick, children, and elderly. (While usually a domestic is not substantially related, in this case she admitted to losing it and striking out in anger in a public place which is different than other domestic type assault charges.) 46 Hi, funny story about why I wont be in today Pending Charge Reporting Policies:
Requires current employees to report pending charges with 24 hours. Not arrests! Must be charged with crime. Gives HR opportunity to determine whether substantially related to the job If not, no action. If yes, unpaid suspension until conviction/dismissal. Pros/cons? 47 I am SICK of SICK leave! 2011 Walker signed law that prohibits municipalities from
passing local sick leave ordinances in Wisconsin. Other states do not have similar laws! Nationwide movement. Eleven states: Arizona, California, Connecticut, Maryland, Massachusetts, Michigan, New Jersey, Rhode Island, Oregon, Vermont, Washington, plus the District of Columbia. 48 I am SICK of SICK leave! More than 30 local jurisdictions in California, Illinois, Texas, Maryland, New York, Minnesota, Pennsylvania, Washington. Most recent: Michigan state-wide, effective in April of 2019. Federal contractors.
Some PTO policies comply, some do not. Other unpaid leave (bone marrow, organ donor, school activity, etc.). 49 All I need are some tasty waves, a cool buzz, and Im fine! Medicinal marijuana: Alaska, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, DC, Florida, Georgia, Hawaii, Illinois, Indiana, Iowa, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, Tennessee, Utah, Vermont,
Virginia, Washington, and West Virginia. Recreational: Alaska, California, Colorado, DC, Maine, Massachusetts, Michigan, Nevada, Oregon, Vermont, and Washington. 50 All I need are some tasty waves, a cool buzz, and Im fine!
Law is rapidly evolving regarding medicinal use. Whitmire v. Wal-Mart Stores (D. Az, 2/7/2019). Whitmire suffered wrist injury at work. Wal-Mart has policy testing that indicates the presence of illegal drugs, in any detectable amount employee is terminated. Test revealed marijuana metabolites at a value greater than 1000 ng/ml. Wal-Mart fired Whitmire for positive test. 51 All I need are some tasty waves, a cool buzz, and Im fine!
AZ Med. Marijuana Act: An employer may not discriminate against a person in hiring, terminationupon registered users positive drug test for marijuanaunless the patient used, possesses or was impaired by marijuana on the premises of employment or during the hours of employment. Whitmire sued. Walmart argued she was impaired by marijuana. Court: The presence of metabolites alone not enough. Proving
impairment based on the results of a drug screen is a scientific matter which requires expert testimony. 52 What are our neighbors doing?? Minnesota: Law is similar to Arizona (no litigation yet). Michigan: Employers not required to accommodate employees use of medicinal marijuana (Casius v. Wal-Mart 2012) (but be careful).
Iowa: Cannabidiol with prescription(like Wisconsin). 53 Tips/Traps-Drug Testing Do you want to win in litigation or AVOID litigation?? To avoid litigation, check state law before disciplining, discharging, or refusing to hire due to positive drug test in state
where medicinal use lawful. Start thinking about medicinal marijuana as any other prescription drug. In general, law where employee lives or spends substantial time working will protect employee. (Employers not required to take action that would cause loss of federal funding/contract.) 54 What is going on with this DOL OT thing anyway? DOL intends to issue a new proposed rule in 2019. Reports are that it will be $32,000-$33,000 range (current is
$23,660). Stay tuned! 55 What can you report on the status of the new EEO-1 Report? Opening of the EEO-1 has been postponed until early March 2019. Deadline to submit EEO-1 data will be extended to May 31, 2019. 56
NLRB has changed its mind AGAIN? June 6, 2018 Memorandum: Lawful rules: Civility, prohibition on photos and recording, protecting specific confidential information, defamation, loyalty. Questionable: Broad conflict of interest, broad confidentiality, criticism of employer, banning off-duty conduct that may harm employer. Unlawful: Confidentiality regarding wages, anti-union policies. Caution: Before discipline/termination, check status of the law! 57
Give me a break! Federal DOL regulations state that short breaks, 5-20 minutes, must be counted as hours worked. 2018-DOL issued opinion letter stating breaks that the employee is requesting for reasonable accommodation (15 minutes/hour) could be unpaid. Under FLSA breaks for nursing mothers unpaid. Wisconsin law: Employer-provided breaks must be 30 minutes to be unpaid. Does not address if situation where employee needs the break as an accommodation or expressing. 58
Dads are important too!! July 2018 EEOC settled sex discrimination claim against Este Lauder. $1.1 million for 210 male employees. EL violated federal law by providing male employees who are new fathers lesser parental leave benefits than are provided to female employees who are new mothers. In addition to paid leave provided to new mothers to recover from childbirth, Este Lauder provided new mothers six additional weeks of paid parental leave for child bonding. New fathers received two weeks of paid leave for child bonding.
59 Dads are important too!! New mothers were also provided with flexible return-to-work benefits that were not similarly provided to new fathers. Maternity leave and paternity leave are obsolete! Parental leave better term. Check your policies! 60 What if he just wants to retire? Manitowoc Co. v. Lanning (WI 2018). I agree I will not encourage any employees to terminate their
employment with Manitowoc. Lanning quit job and met with several former coworkers. Evidence showed e-mails and conversations where Lanning encouraged employees to come to new employer. District court held Lanning to have violated agreement. Awarded Manitowoc $100,000 in damages, $1million in attorneys fees!!! 61 What if he just wants to retire? Lanning appealed. WI Court of Appeals: Employee non-solicitation clause too broad.
What if Lanning is a friend of an employee and wants to encourage him to retire? Why does it apply to ALL employees? Why should they care if he calls the janitor/receptionist? Lower court ruling overturned. WI Supreme Court affirmed (2018). No damages or fees for Manitowoc. Bottom line: Consider revising your employee nonsolicitation agreements. 62 QUESTIONS? 63
500 First Street, Suite 8000 P.O. Box 8050 Wausau, WI 54402-8050 715.845.4336 715.845.2718 Fax 402 Graham Avenue P.O. Box 187 Eau Claire, WI 54702-0187 715.834.3425 715.834.9240 Fax 222 Cherry Street
Green Bay, WI 54301 920.435.9393 920.435.8866 Fax www.ruderware.com 64 2019 Ruder Ware, L.L.S.C. Accurate reproduction with acknowledgment granted. All rights reserved. This document provides information of a general nature regarding legislative or other legal developments. None of the information contained herein is intended as legal advice or opinion relative to specific matters, facts, situations, or issues, and additional facts and information or future
developments may affect the subjects addressed. 65
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