Judge Refuses to Upend Verdict Finding Company Violated OSHA
U.S. District Judge Mitchell S. Goldberg of the Eastern District of Pennsylvania denied defendant Lloyd Industries Inc.'s motion for judgment as a matter of law or, in the alternative, a new trial.
August 02, 2019 at 04:25 PM
3 minute read
A federal judge has upheld a jury verdict finding a manufacturing company violated the Occupation Health and Safety Act by firing employees who assisted the Occupation Health and Safety Administration in identifying workplace hazards at the company.
U.S. District Judge Mitchell S. Goldberg of the Eastern District of Pennsylvania denied defendant Lloyd Industries Inc.’s motion for judgment as a matter of law or, in the alternative, a new trial.
The defendants argued that the jury instructions were faulty because of the court’s inclusion of the “perception theory” of liability, the “third party theory” of liability, and the “substantial reason” causation standard, according to Goldberg’s opinion. The defendants also argued that the verdict was not supported by sufficient evidence.
Former Labor Secretary Thomas F. Perez filed the lawsuit on behalf of plaintiffs Matthew Spillane and Santos Sanna, who claimed they were fired for their involvement with an OSHA inspection of Lloyd Industries.
Spillane testified that he took pictures of a machine that previously injured a co-worker, Joshua Elbode’s hand. He also testified that the company’s owner, William P. Lloyd, “spied” on Sanna, the plant manager, who had provided information to OSHA.
Goldberg said that the defendants motion failed with regard to the perception theory because Spillane was engaged in a protected activity regarding taking pictures of the machine in question. Additionally, the jury was properly instructed on the third-party theory of liability, Goldberg said.
“It was sufficient for Mr. Lloyd to have believed that Mr. Elbode engaged in a protected activity while he was an employee and that Mr. Spillane and Mr. Sanna were terminated as a result of their relationships with Mr. Elbode,” Goldberg said. Goldberg also upheld his reading of the causation standard to the jury.
The defendants also argued that Perez presented insufficient evidence to the jury to support its verdict.
“Mr. Spillane testified that, in July and August of 2014, he had taken pictures of the machine involved in Mr. Elbode’s injury. Rene Santos, another Lloyd Industries’ employee, testified that he saw Mr. Spillane taking pictures of this machine,” Goldberg said. “Mr. Santos also testified that he told Mr. Lloyd about seeing Mr. Spillane taking the pictures one day later. Mr. Lloyd acknowledged that he knew that Mr. Spillane was taking pictures of this particular machine. He also testified that ‘the first thing [OSHA] wanted to look at was that machine’ when they arrived for the inspection in November of 2014.”
He added, “Mr. Lloyd also testified that he told another Lloyd Industries’ employee, Mr. Richard Smith, that he believed that ‘there was a rat in the plant and [he] was going to find out who it was,’” and concluded that the evidence was sufficient.
Judson Dean of the Department of Labor represented Perez and did not respond to a request for comment. Brandon Brigham of Morgan, Lewis & Bockius represents Lloyd and did not respond to a request for comment.
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