Rod Satterwhite and David Greenspan are members of the Labor & Employment group at McGuireWoods LLP. Both handle employment litigation on behalf of employers, and advise companies on employment issues regularly.

Saturday, April 05, 2008 - Posts

USERRA conundrums

A new USERRA case gives a useful review of the limits of claims against employers when veterans return from military service.

In Woodard v. New York Health and Hospital Corp., No.1:04cv05297 (E.D.N.Y., March 17, 2008), the employee worked in a management position overseeing surveys of healthcare centers to evaluate their accreditation and regulatory practices. She also served in the Army Reserve as a major, taking three weeks of military leave when she was hired in 1995, and completing her annual Reserve requirements thereafter.

Woodard took an extended military leave from October 2001 until March 29, 2004. On her return, she was not returned to her former job (which was still vacant) but instead assigned to a quality assurance area that was understaffed. Nevertheless she retained her management title and the same salary grade.

Woodard sued claiming that she was discriminated against because her pay increase was reduced following an evaluation in 2001 and because her new position upon return in 2004 did not involve managerial duties, but instead required a number of   “secretarial” functions.

Initially the court ruled that Woodard made a prima facie case of USERRA discrimination because her pay raise, which was only half of what it should have been, occurred in close proximity to her return from military leave and because her supervisor referred to her military leave of absence in a memo justifying the reduced pay raise.

Important safety tip here: in memos, employee evaluations, emails, or polite conversation, do not refer to protected factors in the same sentence as adverse employment actions.

But the court then noted that merely making a prima facie case, and perhaps even showing pretext, is not enough if you don’t have damages. In this case, the employer retroactively credited Woodard with a pay increase equivalent to what she would have received if she had been working full time, without the leaves of absence. This effectively mooted her USERRA discrimination claim.

Woodard’s re‑employment claim is subject to a somewhat more confusing analysis. In fact, you might be able to make a case that the court got this one wrong. It is undisputed that Woodard was not put back in her old job, but was moved laterally to an understaffed position that had slightly different duties, although she retained her title and salary. The employer justified not putting her back in the same position by noting that the company was operating on a very tight budget that precluded new hiring and employees were being moved around throughout the hospital to ensure critical positions were filled. Other employees were assigned to perform the essential elements of Woodard’s old job, which the court said essentially caused “her old job to disappear”.

Given that the requirements for the job were still there, I’m pretty sure that an employer does not get the flexibility under USERRA to simply shift somebody out of their old job and into a new one because it was able to manage staffing the old position with the remaining employees. The language of the statute is clear—it requires a return to work in the position the employee would have had if she had not left. The court’s opinion is not clear on how the employer demonstrated that it could not have reassigned the duties of the new position to remaining employees when Woodard returned and simply put Woodard back into her old job. I think this may be an issue revisited on appeal because it seems inconsistent with the plain language of the statute.

In other words, you don’t get to reassign an employee simply because other people have proved capable of doing her job while she’s gone. If the obligations to perform those tasks remain, and the company has not reorganized that position out of existence, I think a good case could be made that the requirement to put the employee back in that position remains and the employer’s obligation is to shuffle staffing to make up for any other shortfalls rather than having the burden fall on the returning service member.

The EEOC and “No Re‑employment” Clauses

On April 3, at an ABA Labor and Employment Law Section meeting in California, an EEOC attorney stated that the Commission will oppose so-called “no rehire” or “re‑application” clauses in settlement agreements, or any other type of employment agreements. A no rehire clause is typically used to preclude an employee, who has left the company and filed an EEOC charge or a lawsuit, from setting up a retaliation claim by re-applying for work at the same company. As the EEOC surely knows, a former employee applying under these circumstances confronts the employer with a choice: either rehire the employee (who was frequently a problem employee in the first place) or deny the application and set‑up an endless loop of retaliation claims when the employee files a charge saying that the reason she wasn’t hired is because of the previous protected conduct of filing a charge of discrimination.

This is the kind of shortsighted viewpoint that makes the EEOC actually work against its statutory role as a conciliator. In fact, the Commission’s opposition to these clauses reduces the likelihood of settlement or conciliation.  Without a “no rehire” provision, an employer really can’t rid itself of claims from the aggrieved employee. It’s not uncommon to see ex-employees try to get a job with a former employer (in a career and location where they feel comfortable, know the job, and may know the personnel) after filing an EEO charge.   

The fact that the employee is willing to return to the workforce notwithstanding her earlier claim that it was a hostile environment, managed by racists, sexists, or discriminates against the elderly, casts more than a little doubt on the veracity of the original charge, but the Commission seems to ignore this.

The speaker at the ABA conference stated that the reason the Commission opposes these clauses is that frequently the employee does not realize how broad in scope the no rehire clause actually is. In other words, the Commission wants to save the employee from her own bad judgment. Saving people from themselves has never been a particularly successful philosophy for a government program and it doesn’t work well here either. Employers should know that if they are involved with the Commission, a no rehire clause may be a showstopper as far as settling the charge or case is concerned.