At a Glance
This Littler Lightbulb highlights some of the more significant employment and labor law developments in the federal courts of appeal in the last month.
Fourth Circuit Affirms Dismissal of Plaintiffs Claims Based on Joint Employer Doctrine
The plaintiffs in Hoffman v. Inova Health Care Services, 169 F.4th 207 (4th Cir., Mar. 3, 2026)1 were nurse anesthetists employed by a medical group that provided anesthesia services to facilities operated by the defendant health care services provider. After the plaintiffs refused to be vaccinated against COVID-19, the hospitals where they worked suspended their clinical privileges, and two months later the medical group that employed them terminated their employment. The plaintiffs sued the defendant health care services provider alleging violation of Title VII, the ADA, and the Virginia Human Rights Act (VHRA). The district court dismissed their claims on the grounds that defendant health care services provider was not the plaintiffs’ employer.
The plaintiffs appealed to the U.S. Court of Appeals for the Fourth Circuit, which considered whether in this case “multiple entities [could] simultaneously be considered” the plaintiffs’ employer under the “joint employment doctrine.” The court applied the nine-factor test from Butler v. Drive Automotive Industries of America, Inc., 793 F.3d 404 (4th Cir. 2015) used to determine “which entities actually exercise control over an employee…: (1) authority to hire and fire the...
Schubert Jonckheer & Kolbe LLP advises e.l.f. Beauty, Inc. (NYSE: ELF) investors that the firm is investigating potential legal claims arising from alleged false statements about the strength ...