Justia Government & Administrative Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals concluding that the Industrial Commission of Ohio did not abuse its discretion in denying Appellant's request for a violation of specific safety requirements (VSSR) award, holding that there was no error.Appellant suffered a work-related hand injury while working for Employer and requested an award in addition to her workers' compensation benefits, alleging that her injury was a result of Employer's VSSR violation. The Commission found that Appellant did not commit a VSSR and denied the request for an additional award. The Supreme Court affirmed and denied Appellant's motion for an oral argument, holding that some evidence in the record supported the Commission's decision. View "State ex rel. Levitin v. Industrial Commission" on Justia Law

The Supreme Court affirmed the judgment of the appeals officer limiting the reopening of Appellant's claim to the lumbar spine and affirmed the order of the district court denying Appellant's petition for judicial review, holding that the appeals officer properly determined that the reopening of Appellant's claim was warranted only as to the lumbar spine.Although Appellant was previously treated for injuries to several parts of her body, including her head and back, she sought to reopen her claim due to the worsening condition of her lumbar spine. The appeals officer ordered that Appellant's claim be reopened for the lumbar spine only, and Appellant sought judicial review. The district court denied the petition. The Supreme Court affirmed, holding that the appeals officer properly limited the reopening of the claim to the lumbar spine. View "Olvera v. Wynn Las Vegas" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Robyn Young's motion to dismiss this action brought by Granite School District regarding settlement proceeds Young had received for industrial injuries, holding that the Labor Commission had exclusive jurisdiction over the factual questions at the heart of this reimbursement dispute.Young, a special education teacher, sought workers' compensation for injuries she received at the hands of her students. An administrative law judge awarded Young benefits, finding that Young was permanently and totally disabled and that Young did not have to reimburse Granite with funds she received from a legal settlement she had obtained against medical debt collectors for violations of the Fair Debt Collection Practices Act. Granite then initiated suit for reimbursement from Young under the Utah Workers' Compensation Act. The district court granted Young's motion to dismiss. The Supreme Court affirmed, holding that the district court did not err when it dismissed Granite's complaint because the Workers' Compensation Act assigned the Commission exclusive jurisdiction over this dispute. View "Granite School District v. Young" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the Workers' Compensation Board determining that Richard Lane's notice to his former employer, Tennco Energy, Inc., that he was asserting a subsequent claim against it was timely, holding that there was no error.In 2019, Lane filed a coal workers' pneumoconiosis (CWP) claim against Tennco Energy, Inc. An administrative law judge dismissed the claim after determining that Lane had failed to give timely notice of the claim pursuant to Ky. Rev. Stat. 341.316(2). The Board reversed, concluding that a prior CWP claim that Lane had previously settled against a former employer had no bearing on Lane's duty to notice Tennco when he asserted a subsequent claim against it. The Supreme Court affirmed, holding that remand was required for additional findings of fact under this opinion. View "Tennco Energy, Inc. v. Lane" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the ruling of the Workers' Compensation Board affirming the denial of Francisco Rodarte's motion to reopen and reversing the ruling that Rodarte's shoulder claim was barred due to failure to join, holding that the court of appeals did not err.Rodarte sustained two work-related injuries while working for BlueLinx Corporation - a knee and ankle injury in 2016 and a shoulder injury in 2018. In Rodarte and BlueLinx ultimately entered into a settlement agreement for Rodarte's knee and ankle injuries. BlueLinx denied Rodarte's shoulder claim, however, concluding it was barred pursuant to Ky. Rev. Stat. 342.270 due to Rodarte's failure to join it to the 2016 claim. Rodarte moved to reopen the 2016 claim, which the chief administrative law judge denied. Thereafter, an administrative law judge dismissed the shoulder claim. The Board affirmed the denial of the motion to reopen and reversed the dismissal of the shoulder claim. The court of appeals affirmed the Board's ruling on the motion to reopen but reversed its determination that Rodarte's shoulder claim was not barred for failure to join. The Supreme Court affirmed, holding that the court of appeals did not err in its rulings. View "Rodarte v. Bluelinx Corp." on Justia Law

Appellant, a former employee of the City of La Habra Heights (City), pled no contest to a felony that arose out of the performance of her official duties. Under the terms of Appellant’s plea agreement, the conviction was later reduced to a misdemeanor under Penal Code section 17 and then dismissed under Penal Code section 1203.4. After Respondent California Public Employees’ Retirement System (CalPERS) determined that Appellant forfeited a portion of her retirement benefits as a result of her felony conviction, she filed a petition for writ of administrative mandate. The trial court denied her petition.   The Second Appellate District affirmed. The court concluded the trial court did not err in denying the petition because, consistent with the language and purpose of section 7522.72, Appellant’s retirement benefits were subject to forfeiture upon her no-contest plea to a job-related felony, notwithstanding the subsequent reduction to a misdemeanor and dismissal of the charge. Further, the court explained that Appellant asserts that section 7522.72 is unconstitutional, but she fails to present any cognizable argument or legal authority to support her claim. View "Estrada v. Public Employees' Retirement System" on Justia Law

Plaintiffs worked as detention officers for Glynn County under Sheriff Jump’s supervision. Although it is unclear from the record whether the Officers are formally deputy sheriffs, it is undisputed that they are, at minimum, direct employees of Sheriff Jump, in his official capacity, akin to deputies. The Officers brought a Fair Labor Standards Act (FLSA) collective action alleging that the County “illegally calculated their and other detention officers’ overtime wages.” The County moved to dismiss for failure to state a claim. In response, the Officers amended their complaint to include Sheriff Jump in his individual capacity. The County and Sheriff Jump then moved to dismiss the amended complaint for lack of subject-matter jurisdiction and for failure to state a claim, arguing that neither defendant was the Officers’ employer under the FLSA.   The Eleventh Circuit affirmed both the district court’s denial of the Officers’ motion for leave to amend and its ultimate dismissal of the amended complaint. The court held that the district court correctly dismissed the Officers’ complaint against Sheriff Jump in his individual capacity because he is not an “employer” under the FLSA. Further, the court agreed with the district court that Sheriff Jump would be entitled to Eleventh Amendment immunity when making compensation decisions for his employees. Further, the court held that Georgia “retained its Eleventh Amendment immunity” from suits in federal court for breach-of-contract claims because no statute or constitutional provision “expressly consents to suits in federal court. View "Langston Austin, et al. v. Glynn County, Georgia, et al." on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing a petition for judicial review challenging a decision by the Nevada Employment Security Division's (NESD) Board of Review, holding that, based on its plain language, Nev. R. Civ. P. 6(d)'s three-day mailing rule does not apply to extend the time period for filing a petition for judicial review under Nev. Rev. Stat. 612.531(1).After she was denied unemployment benefits Appellant filed a petition for judicial review in the district court. The district court granted NESD's motion to dismiss, concluding that it lacked jurisdiction over the petition because Appellant had filed it a day late. The Supreme Court affirmed, holding that Rule 6(d) did not apply in this case, and the district court correctly dismissed the untimely petition for lack of jurisdiction. View "Jorrin v. State, Employment Security Division" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting in part and denying in part a writ of mandamus, affirmed the court's award of statutory damages and court costs, and reversed the award of attorney fees, holding that the court of appeals erred in determining that the City of Cleveland acted in bad faith in this case.Cleveland Association of Rescue Employees and its president (collectively, the Union) submitted two public records requests to the City, which denied the requests. The Union then filed a complaint for writ of mandamus to compel production of the records and also sought statutory damages and attorney fees for the City's alleged violation of Ohio Rev. Code 149.43(B). The Union later notified the court of appeals that the City had sufficiently produced the requested records and sought summary judgment with respect to statutory damages and attorney fees. The court of appeals awarded the Union statutory damages of $1,000 and attorney fees of $4,672. The Supreme Court reversed in part, holding that the City's refusal to accept a certified-mail service of the complaint was not a legitimate basis on which to award attorney fees. View "State ex rel. Cleveland Ass'n of Rescue Employees v. City of Cleveland" on Justia Law

Plaintiff fell while stepping from a dock to a boat. He sued his employer—a yacht club in Long Beach—under federal admiralty law. The trial court sustained the club’s final demurrer to the second amended complaint. The court ruled there was no admiralty jurisdiction.   The Second Appellate District affirmed the court’s ruling without deciding about admiralty jurisdiction. The court explained that Congress in 1984 specified employees covered by state workers’ compensation law working at a “club” are covered by state workers’ compensation law and not federal law if they are eligible for state workers’ compensation. The court wrote that Plaintiff concedes the yacht club is a “club.” Federal law thus makes California state workers’ compensation law paramount, which means Plaintiff’s exclusive remedy is workers’ compensation. The court wrote that a core part of the state workers’ compensation bargain is that injured workers get speedy and predictable relief irrespective of fault. In return, workers are barred from suing their employers in tort. Thus, the trial court correctly dismissed Plaintiff’s tort suit against his employer. View "Ranger v. Alamitos Bay Yacht Club" on Justia Law