Chapter 2 The Employment Law Toolkit: Resources for Understanding the Law and Recurring Legal Concepts Copyright 2015 McGraw-Hill Education. All rights reserved. No reproduction or distribution without the prior written consent of McGraw-Hill Education. Learning Objectives (1) Understand the structural setting of employment law: the court systems, the role of stare decisis (precedent) and the processes of the EEOC Examine the nature and implications of employment-at-will, vs. other employment relationships (e.g., civil service, or per defined contract, collective bargaining agreement) Understand the exceptions to employment-atwill 2-2 Learning Objectives (2) Understand concepts of retaliation and wrongful discharge. Recognize the background of Civil Rights Act, and the common features and distinctions among claims, depending on which protected characteristic(s) form the basis of the claim. Distinguish between disparate treatment and disparate impact discrimination claims, and know the common employer defenses. 2-3 Stare Decisis and Precedent (1) Stare decisis (the thing decided) Elements, role of Opinions (maj/concurrence/dissent) Balances stability/predictability and evolution of law Liberal v. Conservative as applied to judging Federal court system Reverse funnel: trials, appeal 1(right), appeal 2 (cert.) 100 district courts, 13 circuit courts of appeal, 1 Supreme Court Reasons to grant “cert” (certiorari) 2-4 Stare Decisis and Precedent (2) State court system – same template Trial court intermediate court of appeals state supreme court Interplay between states and feds Hierarchy: Constitution > statutes > common law Bill of Rights + 14A State decisions on state law final, unless US Constitution violated US Supreme Court decisions are final 2-5 Understanding the Case Parties Key Terms Meaning Plaintiff One who brings a civil action in court Defendant One against whom a case is brought Appellant One who brings an appeal Appellee One against whom an appeal is brought Petitioner One who appeals a case to the Supreme Court Respondent One against whom a case is appealed at the Supreme Court 2-6 Understanding the Case: Information Key Terms Meaning Case citation The book volume, case reporter and page where the court opinion can be found, and decision date. Motion to dismiss Request for court to dismiss plaintiff’s case before trial, based on any of various defects in Complaint Motion for summary judgment Request for the court to rule on plaintiff’s case based on the documents submitted, alleging that facts are not in-dispute, only application of law to them Per curiam A ruling made by an appellate court as a group, rather than individual opinion (usually unanimous) 2-7 Prima Facie Case (“on the face of it”) Cause of action: Right provided by law for a party to sue for remedies when that right is violated Prima facie case: Presentation of evidence that fits each element of a cause of action Demonstrates plaintiff’s claim to a cause of action Requires defendant to answer and defend claim(s). 2-8 Employment-at-Will Concepts (1) At-will employment: Employment relationship where there is no contractual obligation to continue for an agreed time. Agreement renews itself every second, until it doesn’t Either party may terminate, without liability to the other Other types of employment relationships include government employment, terms of a collective bargaining agreement, or individual contracts that define terms and duration. 2-9 Employment-at-Will Concepts (2) Key concept and general rule: either Party may terminate the employment relationship, at any time, for a good reason (incompetence, better offer), or no-reason-at-all (including many stupid reasons) – just not a bad reason = one that falls within one of the few exceptions to the doctrine (next). Most private-sector employment is at-will 2-10 Exceptions to the At-Will Doctrine Violation of employment law: e.g., race discrimination or retaliation motivated the termination Bad faith or malicious termination may violate public policy (other law, legal right) Breach of some other implied contract term (e.g., handbook terms that limit employer discretion) Breach of the implied covenant of good faith and fair dealing (CA and a few other states) Termination in violation of the doctrine of “promissory estoppel” 2-11 Public Policy Exception Public policy: Legal concept intended to ensure that no ‘person’ lawfully do that which may injure the public or damage the public good Whistle-blowing Federal Whistleblower Statute Whistleblowers Protection Act State protection 2-12 Retaliatory Discharge Terminations in response to an employee exercising rights provided by law E.g., filing a claim charging discrimination Limited constitutional protections (recurring theme) State action – no free speech in the private sector(!) A government employer is prohibited from terminating a worker or taking other adverse employment action against a worker on the basis of the worker’s engaging in constitutionally protected activities 2-13 Retaliatory Discharge: Prima Facie Case Participation in a protected activity An adverse employment action Causal connection between the protected activity and the adverse action Burlington Northern & Santa Fe Railway Co. v. White 2-14 Implied Contract Exception Implied contract: An unexpressed contract term created by words or conduct of the parties Employee Handbook statements may imply termination only for ‘just cause’ Other provable conduct that suggests limitation on employer’s at-will discretion. Melott v. ACC Operations, Inc. 2-15 ‘Implied Covenant of Good Faith and Fair Dealing’ Exception Implied contractual obligation to act in good faith in the fulfillment of each party’s reasonable contractual expectations The court examines the parties’ actions to ascertain whether termination demonstrated bad faith (e.g., termination to avoid paying bonus earned, but due if employed at year-end). Narrowly construed – most risks do not qualify, and only a few states recognize this claim Case: Guz v Bechtel National, Inc. 2-16 Promissory Estoppel Exception: Prima Facie Case; other statutes of note The employer made a promise On which the worker reasonably relied To the employee’s detriment Promissory estoppel proof problems abound – definiteness of the promise is important Other statutory exceptions to employment at-will Occupational Safety and Health Act Fair Labor Standards Act Pregnancy Discrimination Act 2-17 Constructive Discharge Constructive discharge: Occurs when conditions so intolerable the employee has no reasonable alternative but to end the employment relationship Employer may be seeking to make worker leave ‘voluntarily’ to avoid wrongful discharge claim Courts require new burdens to be substantial Paloni v. City of Albuquerque Police Department (no) Nassar v. Univ. of Texas Southwestern Medical Center at Dallas (yes) 2-18 Other Restrictions on At-Will Doctrine The Worker Adjustment and Retraining Notification Act (WARN) Requires that employers with over 100 employees must give 60 days’ advance notice of a plant closing or ‘mass layoff’ (as defined in statute) to affected employees Exceptions for faltering business seeking capital; sudden, dramatic, unexpected business changes; or certain natural calamities Co’s. ‘sabotage’ fear may 60-days severance 2-19 Other Exceptions to At-Will Doctrine Wrongful Discharge Based on Other Tort Liability Tort of outrageous conduct Tort claim for emotional distress Tort action of defamation Wrongful invasion of privacy 2-20 Employment Discrimination Concepts: Disparate Treatment (1) Concepts common to most discrimination claims: analyses are similar. Protected characteristics also have unique features or issues (covered in specific future chapters) Generally two types of discrimination claims: Disparate treatment: Treating similarly-situated employee or applicant differently because of a characteristic covered by Title VII. Intentional acts: e.g., “Mexicans need not apply” 2-21 Employment Discrimination Concepts, Disparate Treatment: Prima Facie Case Employee belongs to a class protected under Title VII Employee applied for and was qualified for a job for which the employer was seeking applicants Employee was rejected and, after the rejection, the position remained open Employer continued to seek applicants with the rejected applicant’s qualifications 2-22 Employment Discrimination Concepts, Disparate Treatment: Defenses Employer’s defense Legitimate, Nondiscriminatory Reason Defense Employee’s counter – legitimate, nondiscriminatory reason is a mere pretext for the employer to discriminate. The Bona Fide Occupational Qualification Defense: Permissible discrimination if legally necessary for employer’s particular business Very limited application – and Never in Race cases Case: Wilson v. Southwest Airlines Company 2-23 Employment Discrimination Concepts, Disparate Impact Disparate impact: Discriminatory effect of a facially neutral policy on a Title VII group Facially neutral policy: specific workplace policy that applies equally to all employees Key distinction: needn’t prove Intent to discriminate; key consideration is differential effect on protected group Case: Griggs v. Duke Power Co.: “built-in headwinds;” test results as servants, not masters 2-24 Employment Discrimination Concepts: Disparate Impact Screening device: Mechanism used to separate applicants from the general pool of candidates Four-fifths rule: Minority must do at least 80 percent (four-fifths) as well as majority on screening device or presumption of disparate impact arises (see business necessity defense, next slide) Subjective or objective criteria may qualify 2-25 Employment Discrimination Concepts: Disparate Impact Pre-employment interviews Employment applications The business necessity defense: Defense to a disparate impact case based on the employer’s need for the policy/device as a legitimate requirement for the job Test validation Employee rejoinder: less discriminatory policy or screening alternatives exist 2-26 Other Defenses to Employment Discrimination Claims The employee’s evidence is not true – Plaintiff burden of proof to establish > 50% probability (No) The employer’s “bottom line” comes out correctly Statute aimed at individuals, not groups Case: Connecticut v. Teal 2-27 Other Common Concepts Reasonable Accommodation: employer duty in Title VII religious discrimination claims, and under Americans With Disabilities Act (ADA) Upper limit: ‘undue burden’ on employer Extent of duty varies between religious and disability accommodations Exhaustion of Administrative Remedies: must complete EEOC administrative process before seeking judicial review of agency decision 2-28 Exhibit 2.9 - Employment Discrimination Remedies 2-29 Employment Discrimination Remedies Key Terms Meaning Back pay Money awarded for time employee was not working because of illegal discrimination Front pay Equitable remedy of money awarded to claimant when reinstatement is not possible or feasible Retroactive seniority Seniority that dates back to the time the claimant was treated illegally 2-30 Employment Discrimination Remedies Key Terms Meaning Make-whole relief Attempt to put the claimant in position he or she would have been in, absent proven discrimination Compensatory Money awarded to compensate the injured party for damages direct losses Punitive damages Money over and above compensatory damages, to punish employer or deter future acts 2-31 Management Tips Most employment relationships begin and end without legal implications But when they don’t, it’s expen$ive Prevention beats cure Employers are always allowed to hire the best person for a job Claimants must always be qualified for the job Employees must not face retaliation from their employers 2-32