Hawaii Employment Law Cases June 4, 2017 to June 10, 2017 – Jeffrey S. Harris

U.S. Supreme Court

ERISA exempts church affiliated nonprofits running hospitals and other health care facilities from its otherwise comprehensive regulation of employee benefit plans.  Advocate Health Care Network v. Stapleton, 198 L.Ed. 2d 296, 2017 U.S. LEXIS 3554 (June 5, 2017).

U.S. Ninth Circuit Court of Appeals

District Court properly granted summary judgment against FMLA interference claim, because employee did not offer enough evidence to create a genuine issue whether her leave caused her demotion, and the employer met its burden of establishing legitimate reasons for the demotion.  District Court properly granted summary judgment against ADA claim, because employee did not show person responsible for her demotion knew of her disability, the employer met its burden of establishing legitimate reasons for the demotion, and the employee failed to offer evidence the reasons were pretext for discrimination.  Floyd v. Cty. Of Maricopa, 2017 U.S. App. LEXIS 10231 (9th Cir. June 8, 2017).

District Court properly granted summary judgment against ADA claim, because evidence showed termination resulted from conditions imposed as part of a deferred prosecution that interfered with employee’s ability to perform functions of the job.  Thoma v. City of Spokane, 2017 U.S. App. LEXIS 9928 (9th Cir. June 5, 2017).

U.S. District Court for District of Hawaii

Former employee did not timely file charge claiming employer retaliated by failing to promote employee.  Charge claiming employer denied her leave for family emergency and suspended her for inappropriate comments did not cover the claim.  She did not file lawsuit claiming employer failed to promote her within 90 days of receiving right to sue letter.  Former employee failed to show legitimate non-discriminatory reason for her termination and suspension were pretext for retaliation.  Wilson v. Hawaii, 2017 U.S. Dist. LEXIS 89299 (D. Haw. June 9, 2017).

Note: We analyze cases to learn rules the courts will follow or disappoint us if they do not. Rules that the courts follow allow us to behave and provide explanations they accept. However, competent advocates may limit the rules to the facts of the case they discuss, or expand rules by showing that differences in other cases are irrelevant.