In this case, plaintiff Ronald Johnson, an African-American member of the International Brotherhood of Electrical Workers Local 1, sued the union after being expelled for working for a contractor that had a contract with a rival union rather than Local 1. Johnson alleged in Count I that the expulsion violated his rights to union speech and assembly under 29 U.S.C. § 411, and in Count II that it constituted racial discrimination under 42 U.S.C. § 1981 because white members were not similarly disciplined and the union had encouraged hiring non-African-American members. The court granted the union's motion to dismiss Count I, reasoning that Johnson had not alleged any protected union activity such as discussing union matters or attending meetings. The court denied the motion as to Count II, finding that Johnson's factual allegations of disparate treatment and racial motivation were sufficient to state a plausible claim. The decision applied the Twombly/Iqbal pleading standards to evaluate the sufficiency of the complaint.
This case involves Stephanie Woods' appeal of the Social Security Administration's denial of her application for supplemental security income benefits, claiming disability due to manic depression and paranoid schizophrenia. The district court reviewed the Administrative Law Judge's decision upholding the denial and found that the ALJ's assessment of Woods' residual functional capacity was not supported by substantial evidence. The court reversed the decision and remanded the case because the ALJ improperly discounted the consistent medical opinions of Woods' treating physicians regarding her limitations in maintaining a work schedule due to her bipolar disorder. The ALJ's reliance on Woods' daily activities and ability to handle one-time stresses did not adequately justify disregarding those opinions.
In Flynn v. AT & T Yellow Pages, plaintiff Richard Flynn, an African-American artist over age 55, sued his former employer after being terminated in 2007, alleging racial and age discrimination, failure to promote, retaliation, and a hostile work environment under federal and Missouri law. The employer had fired Flynn following an investigation that uncovered his extensive personal use of his work computer to create and sell comic books, download hundreds of music files and videos, and surf the internet during work hours, in violation of the company's Code of Business Conduct that he had agreed to annually. The district court granted summary judgment to the employer, holding that the undisputed facts established a legitimate, non-discriminatory reason for the termination and that Flynn failed to show any similarly situated younger or non-minority employees were treated differently or that the stated reason was pretextual.
This case involves a dispute between Automation Service, a company that remanufactures used process control equipment made by Emerson, and defendants including Emerson, Factory Mutual Insurance, and FM Approvals. Automation alleged that Emerson's refusal to enter an OEM agreement prevented it from obtaining FM safety certification, and that Emerson's advertisements claiming superior safety for its own remanufactured products violated antitrust laws, the Lanham Act, and Missouri laws on tortious interference and defamation. The court granted the defendants' motions to dismiss the federal and state antitrust claims, finding that Automation failed to plausibly allege monopoly power or a properly defined relevant market. However, the court denied the motion to dismiss the Lanham Act and state-law claims, concluding that Emerson's statements about its own products could support those causes of action. The court also granted an unopposed motion to intervene by Fisher Controls.
The case concerned members of the Westboro Baptist Church who challenged three successive versions of a Manchester, Missouri city ordinance that restricted picketing and protesting within 300 feet of funerals or burial services. The plaintiffs sued under 42 U.S.C. § 1983, alleging violations of their First Amendment free speech rights. The court granted summary judgment to the plaintiffs, declaring all versions of the ordinance unconstitutional and permanently enjoining its enforcement. The core reasoning was that the ordinance was a content-based restriction on speech that failed to satisfy applicable First Amendment standards for such regulations.
In Taylor v. American Airlines, Inc., former TWA flight attendants sued their employer American Airlines, its parent AMR, and their union the Association of Professional Flight Attendants, challenging the 2001 seniority integration agreement that placed them at the bottom of the seniority list after the merger and alleging resulting harms from furloughs and route reductions. The plaintiffs sought a declaratory judgment and brought claims for breach of contract, breach of the duty of fair representation, and fraudulent misrepresentation under the Railway Labor Act and state common law. The court dismissed all claims with prejudice, ruling that the state-law claims were preempted by the RLA, the RLA claims were untimely under the six-month limitations period because plaintiffs had notice of potential breaches by 2003 at latest, and no claim was stated against AMR. The core reasoning was that the disputes required interpretation of collective bargaining agreements and related documents, matters exclusively reserved for RLA arbitration procedures, and that no new violations restarted the limitations clock.
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