OSHA Ends the Year With a Bang and a Black Corvette

It's as good a way to close the decade as any. When Brocon Petroleum failed to pay an agreed judgment that had been entered in a 2008 lawsuit against the firm by the Department of Labor, federal marshall's seized a 1992 black corvette at the home of Richard Kohler, president of the company. The suit had alleged that Brocon had terminated an OSHA whistleblower. See Howell firm ignored judgment; boss's car seized. The full press release from OSHA is here.

According to a report about the lawsuit when it was filed, Scott Shevlin was fired the same day that OSHA investigated an anonymous complaint about safety practices at the work site. Feds allege worker fired for complaint about firm .

Thanks to all who have been readers this year, and this decade for that matter.  It has been an interesting time to be a labor and employment lawyer.

And for 2010 forward? My prediction, if I am still writing this blog 10 years from today, I will be accurate in making the same statement.

Happy New Year.

Guess Who Is Crossing the 50% Line?

Although it is the holiday bowl season, I didn't mean 50 yard line. The 50% refers to an article in this week's Economist that within the next few months women will become a majority of the American workforce. See, We Did It!

When it actually happens it will only be the continuation of incremental change, but it is as good occasion as any to take note, and consciously reflect, on what it means.

Hat tip to JD Hull at What About Clients? for his post, Working U.S. Women Officially Rule.

Latest on NLRB Nominees

Jeffrey Hirsch at Workplace Prof Blog has the latest development on the nomination that is holding up the confirmation that would bring the NLRB to full strength (5 members) and make it officially an "Obama Board." The nomination of Craig Becker, a lawyer for the SEIU, has been "returned to the White House," according to some post-Christmas reporting, Becker's Nomination "Referred Back" to White House.

Hirsch doesn't know exactly what this means, nor do I, but it can't be a happy thing for organized labor, or Obama. As he also notes, it could turn what would have been an academic question, whether a 2 member Board can operate in the absence of a three member quorum, into something much more important. That case is currently pending before the Supreme Court.

Even if the 2 member power is upheld, at this particular time it really won't matter, since the two current members, who were nominated by Presidents of different parties, only act when they are in agreement, which means nothing too controversial is likely to occur until something gives on the appointment to the three vacancies.

Update: NAM's Shopwatch story from yesterday has even more details about the action. See, Senate to President: Reconsider NLRB Nominee.

Imperial Winter Series Boxing Day Race

A tradition far more wholesome and less controversial than the Boxing Day Hunts is the Imperial Winter Series Boxing Day Races which I took part in for the first time today.  A stiff wind down the backstraight made any breakaways virtually impossible though some (including my teammate for over a lap) had a good go.  Seemed faster than recent weeks but that must have been an effect of the wind, as was the dropping of a fair few this week.  I was finding it difficult to keep tabs on what was going on, mistaking two dropped riders at one point for a break.  I was there for the sprint but barely and got obstructed by a slower rider taking a racing line through the S bends oblivious to anyone behind.  That's racing: you have to be both strong and in the right place.
Average speed 23.1

Weighing In On Religion in the Workplace

Although Iowa's turn in the political sun won't roll around for at least another 18 months or so, there's an interesting post from Patrick Smith at the Iowa Employment Law Blog, Are Employee Religious Freedoms in Jeopardy? 

The jumping off point for his comment was a guest column in the Des Moines Register by Lake Lambert III, Professor of Religion at Wartburg College, in Waverly, Iowa. Dr. Lambert is advocating for the Workplace Religious Freedom Act. As the article notes, the Act has been kicking around for quite awhile, notwithstanding support on both sides of the aisle. Although it occasionally gets a push, the fact that it has not made much progress I think speaks volumes to the potential problems. Smith thinks the bill cuts too broadly and points out some of the issues:
In a country with so many different religious practices, however, an expanded duty to accommodate them all could create more problems than it solves.  What happens when the practices of different religions conflict?  What about situations where an employer's legitimate interest in safety or uniformity impacts an employee's desire to wear religious clothing or articles?  Under existing law, employers have more  flexibility to address these situations in the context of legitimate business needs.  The proposed RWFA tips the balance too far the other way.
I couldn't agree more. 

Still it has been a few years since I have written about it. My first post was in  2003 and things had not changed much when I wrote in 2005, Workplace Religious Freedom Act - Consensus On Neither the Right Nor Left.  It is not unheard of for legislation to languish year after year, only to make it to the forefront. The ADA and FMLA are two examples of statutes that were introduced in a number of Congresses before becoming law, ENDA (protection for sexual preference and more) may be the next.

And who knows, even though it doesn't seem to be making much progress, the Workplace Religious Freedom Act doesn't show any signs of going away either.




An Argument Against the Arbitration Fairness Act

Even as one segment of the employment community, defense contractors and sub-contractors with large contracts, have lost the right to have arbitration agreements as a condition of employment, a summary of a recent law review article makes what it calls the "not so popular" argument in favor of such clauses. See, Jonathan Adler's of New York Law School's comment at The Obiter Dictum, A Not So Popular Argument Supporting the Use of Mandatory Arbitration Clauses.

The longer article is Determining if Mandatory Arbitration is “Fair:” Asymmetrically-Held Information and the Role of Mandatory Arbitration in Modulating Uninsurable Contract Risks, by Paul Bennett Marrow.

Here's the money quote from the Obiter Dicta article: 
Passage of the Arbitration Fairness Act of 2009 (which seems unlikely given its current status in both House and Senate committees) will cause more problems than it will solve. For instance, without the availability of mandatory arbitration, many parties will be more vulnerable to potential litigation and its associated uncertainties. As a result, overall transaction costs will increase. These costs will be directly passed to borrowers and franchisees. Employers will also pass these costs to business customers, albeit indirectly.
Two comments, first I am not as optimistic as the writer that the Arbitration Fairness Act will not pass; secondly, I think saying that being for mandatory arbitration is not a popular position, may be the understatement of the year.

Imperial Winter Series Race 3 - Saturday 19th December 2009

Not quite so many on the start line this time around.  Perhaps the freezing temperature had something to do with that.  By the start time the worst of the ice had been chipped off the circuit or hidden under strategically placed cones.  After a lap or two the cold no longer mattered.  I felt good and at no time got trapped at the back, though the smaller field definitely helped there.  Unhappily there was a crash immediately ahead of me on the last lap coming out of the tight bend.  I had to stop for that but then restarted and about six of us passed the 3rd cats (who not only moved over but shouted encouragement) and sprinted for the line for who knows what lowly position (21st it turns out!)
Average speed 23.6mph.

The Helmet Debate Drags On

The Transport Research Laboratory has this week published a further paper on the effectiveness of cycle helmets.  A long report that concludes that
"Cycle helmets would be expected to be effective in a range of accident conditions particularly the most common accidents that do not involve a collision with another vehicle, often simply falls or tumbles over the handlebars and also when the mechanism of injury involves another vehicle glancing the cyclist or tipping them over causing their head to strike the ground."
It would, I suppose, be genuinely astonishing if it were found that helmets were of no use in protecting the head in any circumstance.  I have a clubmate who found his particularly helpful when caught unawares by a descending carpark barrier.  I sometimes have wished I was wearing mine in the kitchen when my head has contacted an open cupboard door.
The TRL report expressly says it does not deal with the vexed question of risk compensation, whereby people's behaviour changes as a consequence of seeing themselves or others as less vulnerable.  Nor does it deal with the questions whether the wearing of helmets should be encouraged or mandated, but its conclusions probably mean that we should not be expecting any change in the Highway Code's advice to cyclists to wear a helmet (accompanied by a vulnerable looking cyclist cowering in the gutter).
Whether this report will provide further impetus to motor insurers to blame cyclists for head injuries because they have not worn a helmet remains to be seen.  What I will say is that in no case yet has a Court determined that a cyclist both ought to have been wearing a helmet and that it would have made any difference.  No deduction for contributory negligence has therefore been made by a Court to date.  Cyclists and their lawyers should bear that in mind when a reduction is suggested.
I have already expressed my views on contributory negligence here.  Nothing in the latest paper changes my view.  It is so much more important that people cycle than that they cycle with helmets and the Australian experience demonstrates that you cannot encourage both.  It is so much more important that accidents are prevented than that we are forced to look to personal protection to hope to minimise their effect.
So when we see a famous footballer taking his children out for a bicycle ride let us applaud him for getting on a bike and not attack him because he has chosen not to wear a helmet.

So You Think Your Fantasy Football Team Is Doing Bad

Odds are that you have not been fired for it. Not the case for four employees at Fidelity Investments, whose office is apparently located in my neighborhood. Rob Radcliff at Smooth Transitions has the complete story, Fantasy Football Firing, complete with a poll of Fort Worth Star Telegram readers on whether they think the company over reacted. (No surprise how that one turned out.)

This is an interesting and timely story for me as I will be speaking at the Advanced Employment Law Seminar sponsored by the Texas State Bar in early January. My topic: "You're Not the Boss of Me: When and How Much Can an Employer Regulate Employee Conduct On and Off the Job."

Rob correctly points out that the key is likely to be that Texas is an employment at will state. I think the most interesting long term question is whether or not somewhere down the road, the expectations of the general public on what employers should do, as opposed to what they can legally do, becomes so at odds with employment at will, that the venerable doctrine is abandoned.

Of course that could never happen. And Lehman Brothers could never go bankrupt, Arthur Andersen could never fail, and Tiger Woods could never .... You get the point.

A Pre-Cursor to the Arbitration Fairness Act Takes Another Step

The Arbitration Fairness Act, which would ban the practice of making agreement to arbitration a condition of employment, is not likely to be voted on until sometime in the spring of 2010. However, those in favor of arbitration in the workplace can not be pleased by the survival of the Franken amendment to the Defense Appropriations Bill which bans such agreements by defense contractors.

After passing the Senate in October (the day before I was testifying in a Senate Judiciary Committee hearing involving arbitration where Senator Franken took the lead) it has now passed not only the House, but survived a conference committee. Franken Rape Amendment Included In Defense Spending Bill.

The amendment extends not only to first tier contractors, but also to sub-contractors, if either of them exceed $1,000,000. Although much of the publicity surrounding the Amendment has been focused on a rape that occurred against an employee who had an arbitration agreement, by extending its coverage to any claim under Title VII it is much broader than cases involving sexual assault.

Here is the language of the Franken Amendment that survived conference :
SEC. 8116. (a) None of the funds appropriated or otherwise made available by this Act may be expended for any Federal contract for an amount in excess of $1,000,000 that is awarded more than 60 days after the effective date of this Act, unless the contractor agrees not to:

(1) enter into any agreement with any of its employees or independent contractors that requires, as a condition of employment, that the employee or independent contractor agree to resolve through arbitration any claim under title VII of the Civil Rights Act of 1964 or any tort related to or arising out of sexual assault or harassment, including assault and battery, intentional infliction of emotional distress, false imprisonment, or negligent hiring, supervision, or retention; or

(2) take any action to enforce any provision of an existing agreement with an employee or independent contractor that mandates that the employee or independent contractor resolve through arbitration any claim under title VII of the Civil Rights Act of 1964 or any tort related to or arising out of sexual assault or harassment, including assault and battery, intentional infliction of emotional distress,false imprisonment, or negligent hiring, supervision, or retention.

(b) None of the funds appropriated or otherwise made available by this Act may be expended or any Federal contract awarded more than 180 days after the effective date of this Act unless the contractor certifies that t requires each covered subcontractor to agree not to enter into, and not to take any action to enforce any provision of, any agreement as described in paragraphs (1) and (2) of subsection (a), with respect to any employee or independent contractor performing work related to such subcontract. For purposes of this subsection, a ‘‘covered subcontractor’’ is an entity that has a subcontract in excess of $1,000,000 on a contract subject to subsection (a).

(c) The prohibitions in this section do not apply with respect to a contractor’s or subcontractor’s agreements with employees or independent contractors that may not be enforced in a court of the United States.

(d) The Secretary of Defense may waive the application of subsection (a) or (b) to a particular contractor or subcontractor for the purposes of a particular contract or subcontract if the Secretary or the Deputy Secretary personally determines that the waiver is necessary to avoid harm to national security interests of the United States, and that the term of the contract or subcontract is not longer than necessary to avoid such harm. The determination shall set forth with specificity the grounds for the waiver and for the contract or subcontract term selected, and shall state any alternatives considered in lieu of a waiver and the reasons each such alternative would not avoid harm to national security interests of the United States. The Secretary of Defense shall transmit to Congress, and simultaneously make public, any determination under this subsection not less than 15 business days before the contract or subcontract addressed in the determination may be awarded.
The bill now goes back to the Senate where passage is expected before Christmas.

Hat tip to the Washington Labor & Employment Wire for their post on the appropriations bill.

Update (12/21/09): President Obama signed the law over the week end. Obama Signs Into Law Restriction on Arbitration Clauses.

Update (12/30/09):  If you check the comments below, a reader has pointed out that I may have read the Franken Amendment too broadly when I suggested it may cover any Title VII claim. I certainly can see the point, and actually think hope he or she is correct.

However, I am apparently not the only one to read it broadly (or at least write about it that way). The
Alaska Employment Law blog's post, The Breadth of the Franken Amendment, quotes from the Legislative & Public Policy Direct of NELA:
Importantly, it bars contractors and subcontractors that are funded by 2010 appropriations not only from entering into pre-dispute “agreements” with their employees that require arbitration of Title VII claims, but also from ENFORCING any such agreements that already exist. It also appears to apply to such “agreements” with ANY of the contractors’ employees, anywhere, not just those whose jobs are funded by defense appropriations.
My guess is that defense contractors will put the wording from the Franken amendment "as is" into their agreements, and then when someone seeks to enforce arbitration of a Title VII claim with no relationship to "sexual assault or harassment" and we will get our first determination that matters. Even if the commentator below is correct about Title VII being limited, it seems a little harder to apply that reasoning to "negligent hiring, supervision or retention."  ]

Legislative drafting is obviously not an easy task. Not that they need it, but it definitely provides job security to judges.

The trouble with cycle lanes

I am not a fan.  On my commute in this morning I was using a cycle lane to filter on the nearside past stationary traffic in Isleworth when a right turning car took me out.  I landed rather ungracefully on his bonnet.  Fortunately neither of us was going very fast (15mph my Garmin says) and I am essentially unhurt.  Looking at Google Maps (me left to right in that very narrow cycle lane) I see that the lane markings have changed since the satellite photograph as the cycle lane now extends past the driveway to the bus stop.   I would normally overtake on the offside but the cycle lane meant the stationary traffic was further out so, with a central traffic island, there was no room.  When passing a side road I am always in the primary position or to the offside of stationary traffic but I had not noticed this driveway nor had I seen the gap in traffic that enabled the oncoming car to turn right into my path.
I can now confirm that not all accidents are reported to the police.  I shall not bother [edit: actually I shall; I will try to report by email and see if the Metropolitan Police now make reporting easy]- the last time I was taken out on a roundabout and ended up in hospital the police agreed not to prosecute the motorist if she went on a course.  I will report it to CTC's SMIDSY campaign instead.

Joint Commission and Bullying

If you have ever worked in or around hospitals, you know that two words that get everyone's attention are, Joint Commission. That's a shorthand description of an accreditation review that is a top to bottom scrubbing of every facet of an institution, with serious consequences if you don't meet the standards.

So when Professor David Yamada, the leading proponent of anti-bullying legislation notes that the Joint Commission has enacted standards that can be read as requiring anti-bullying procedures and training, I take note. See Workplace bullying in healthcare I: The Joint Commission standards.

Labor and Employment Comes (Slowly?) Into the Electronic World

In looking at commentary on yesterday's granting of cert in City of Ontario v. Quon (more about that follows), I found a reference to an interesting law review article by William A. Herbert, Deputy Chair and Counsel for the New York State Public Employment Relations Board, provocatively titled, The Electronic Workplace: To Live Outside the Law You Must Be Honest.

While I haven't read the whole article, I was struck by one of his introductory comments:
In many ways, United States labor and employment law sleepwalked into cyberspace. Although there is wide societal recognition that new technologies are leading to the diminishment of personal privacy, there has not been an equal demand for changes in the legal paradigm.
There's probably a lot of truth to that, but I think that it is changing.

Besides not being able to open your email without the announcement of yet another seminar on social media, there's other evidence that we are actually moving beyond the platform to actual developments. One is a report from Richard Negri at today's workplace, Some Things I Took Away From The Organizing Conference Last Week. That's organizing as in bringing a union to your workplace, not as in straightening your closets. If you don't think it's a different world, just check out the power point presentation, Organizing & New Media in the Obama Era at the conference's web site.

And yesterday, the Supreme Court granted certiorari in the Quon case where the 9th Circuit held that notwithstanding the city's policy that it could review electronic messages on equipment furnished to its employees, the employee nevertheless had an expectation of privacy because of the way the policy was implemented. Although the case is likely to turn on 4th Amendment law that is not directly relevant to private sector employers, any action by the Court that seems to expand the privacy rights of employees is likely to have a ripple effect on related areas such as common law privacy claims.

It may be too early to say that labor and employment law is up to date on all forms of communication and interaction that we now live with on a daily basis, but there's no question that willingly or not, it is clear that we will soon be dealing with them.

The week that was


Law enforcement at the most basic level seems to me to leave something to be desired.  On my daily commutes last week I saw a woman cyclist pulled over by a 4x4 police vehicle who had stopped to hand out a fixed penalty for contravention of a traffic light.  Fair enough I suppose (always assuming she had not passed the line to be visible to an HGV) but I have never ever seen a motorist stopped for using a handheld mobile 'phone or for contravention of an advanced stop line or indeed for jumping a red light though I see scores of such offences every day.  The police are after all responding to the concerns of the popular press who almost daily call for a crack down on 'rogue cyclists'.

When Westminster councillor Angela Harvey spoke to The Times last week to support a proposal to allow traffic wardens power to fine errant cyclists she told them that:
“We’re always getting little old ladies who are knocked down and abused by a cyclist, who leaves them on the ground as they ride away.  The police are the only people who have the ability to enforce this issue, and they just aren’t taking this seriously enough. There are more of our officers on the street than there are police at any given time, so it is a sensible solution.”
Meanwhile BBC news reports a recent study which has confirmed what we all know, that mobile 'phone use amongst motorists is common-place.  Motorists now appreciate that the risks of a penalty are negligible and use hand held 'phones no less than they did before legislation banning their use.

Ms Harvey seems to me to be a bit like the sherriff in the lawless frontier town who does not dare to tackle the bandits with the shotguns, but instead urges her deputies to deal with the kids with the pea-shooters.  Let's exaggerate the harm done by the pea-shooters and turn a blind eye to the death and destruction threatened by the untouchables.

Imperial Winter Series Race 2

A fine day but with a stiff northerly wind for the second race of the Winter Series.  3 Thames Velo riders in the 4th cat event and 2 in the 3rds today - a record at least in recent years.  We were given advice on the start line as to how to avoid last week's difficulties with the coming together of the two races but in fact the problem solved itself this week.  Perhaps we 4th cats were marginally faster, or the 3rd cats marginally slower or both, but we were blissfully undisturbed by each other.  The field was not quite as crowded as last week's 70 riders but was still fairly full.  I aimed to keep near the front for at least the first 30 minutes.  For a short moment I thought I might have made it into a break of 5 but the pack has a capacity to put on an impressive burst of speed both to reel in any breaks and to leave me for standing in the final lap.  My teammate Andy fared better, in only his second race, he got towards the front and stayed there until the final sprint.
Average speed 24mph

MDV the Malicious Prosecution Way

There are a myriad of ways that employers end up in front of a jury. One of the less frequent, but as seen by the result, no less dangerous, is a case for malicious prosecution. They usually arise like the facts in a federal court in Virginia last week. Clyde Bennett, a night shift foreman was fired and charged with grand larceny in connection with the embezzlement of computer equipment.

When that charge was later dropped, he filed a lawsuit against his former employer for malicious prosecution. According to the report from the Richmond Times Dispatch, the jury took less than half an hour to deliver its message. Jury awards $3.2 million to local trucking company employee.

Because the legal standards are relatively high, this verdict is likely to have a long way to go before it becomes a judgment that has to be paid. But it is a good reminder that any time one of the actions that an employer is considering is filing a criminal charge against an employee, that there is at least the potential for what at the time would seem preposterous -- that it could be the employer that ends up the defendant.

Imperial Winter Series - Saturday 5th December

At last - racing again in the Imperial Winter series run by the terrific Doug and Lucy Collins.  Met up with my teammates Andy and Paul, the former a first time 4th cat and the latter a seasoned 3rd.  I got a puncture warming up which I noticed at the start line at 1pm (the start time).  I asked Doug for a spare wheel but he told me I had time to change my tube.  Well obviously he doesn't know just how slow I am.  By the time I got back to the car, fixed the punture and returned to the circuit they had all started.  The Commissaire kindly let me join a lap late; well that is one way of getting to the front early on.  As my club coach noted I can stay near the front for the first half of the race but seem to lose this ability later on.  For me it all fell apart a bit as the 3rd cats went by as it took for ever and for that period it was impossible to pull out and move back towards the front.  I came in at the back of the bunch as did Andy (brilliant, for my first few races I was lapped).  We hung around long enough to see Paul come in in the rear portion of his bunch.
For a full account of this (and many other) races see Lance Woodman's blog.
Average Speed 24 mph.

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