You don’t have to be an expert in employment law to realize social media issues are a growing presence in employment cases. In other words, “you don’t need a Weatherman to know which way the wind blows.” Whether social media use is a direct cause of lawsuit, or it raises an issue during litigation, the subject is almost unavoidable. The recent Fourth Circuit case, Bland v. Roberts, is instructive for two reasons: 1) clicking “Like” on a Facebook page constitutes speech, and 2) fully explaining the complexities of social media and its effect on the issues to the court can lead to a favorable result.
How it all began
One of the plaintiffs, Mr. Daniel Ray Carter, was a sworn, uniformed deputy sheriff who worked as a jailer in the Corrections Division. Mr. Carter’s extent of support was merely clicking “Like” on the opponent’s Facebook campaign page. Sheriff Roberts had made clear to the staff that those who publicly supported his opponent would not be re-appointed. Roberts won the campaign and, shockingly, did not reappoint Mr. Carter and a few others who had dared to support the “wrong” candidate.
District court ruling
Facebook Amicus Curie
Facebook’s brief reads like an instruction manual (in a good way). Facebook provides the court with a linear explanation of its service and how its members (called “users”) are able to publish and share their “opinions, ideas, photos, and activities” to Facebook’s 950 million users. Facebook patiently explains how a Facebook page works and carefully detailed how visible liking a page can be among the online community. Facebook noted that 500 million users are on the site daily and more than three billion (yes, billion) Likes are posted every day. It stated that liking a page is “the 21st-century equivalent of a front-yard campaign sign.”
Fourth circuit ruling
Why Bland is significant for all attorneys
“All speech, written or spoken, is a dead language, until it finds a willing and prepared hearer.” —Robert Louis Stevenson
On June 24, 2013, the U.S. Supreme Court handed down two critical decisions regarding Title VII of the Civil Rights Act, which improve an employer’s ability to defend against employee claims of harassment and retaliation.
Vance v. Ball State University: who’s the boss?
The EEOC and several federal courts—including the Fourth Circuit Court of Appeals, which covers North and South Carolina—have defined “supervisor” broadly to include anyone with the authority to direct the alleged victim’s work activities. This authority was not limited to hiring and firing, but included things such as scheduling shifts or assigning daily tasks. Other courts, however, applied a more restrictive definition, limiting “supervisor” to those individuals who had the ability to make a tangible employment decision; i.e., to hire, fire, promote or demote the alleged victim. As noted in the January 2013 update, the Supreme Court in Vance v. Ball State University was expected to resolve the dispute once and for all.
In that case, Maetta Vance, an African-American woman, sued her employer, Ball State University, under Title VII. Vance alleged that Ball State was liable because she was subjected to harassment by a white woman who had some authority to direct her daily activities, even though the woman did not have the authority to hire, fire, promote or demote her. The Supreme Court adopted the more restrictive—and employer friendly—definition of “supervisor” and held that only those who are “empowered by the employer to take tangible employment actions against the victim” are considered “supervisors” for the purposes of Title VII. Such tangible actions include “hiring, firing, failing to promote, reassignment with significantly different responsibilities, or a decision causing a significant change in benefits.” This framework, according to the Court, provides a bright-line rule for employers to determine which employees fall under “supervisory status,” enabling employers, employees and courts to more readily determine that status. Therefore, the broader interpretation espoused by the EEOC and courts in North and South Carolina was effectively overruled.
This decision weakens an employee’s ability to establish the necessary connection between an alleged harasser and employer. However, employers are cautioned that this case does not insulate them from liability if their employees—supervisors or otherwise—create a hostile work environment or subject other employees to harassment. To fully benefit from this decision, employers should clarify in writing the duties and authority of their various managers and team leaders, especially those in middle management and lower-level leadership positions. All employees should be aware of the authority of all managers and supervisors and, as always, employees must be informed that harassment will not be tolerated and should be reported immediately. Additionally, employers should also have a written policy that retaliation against employees making good faith complaints will not be tolerated, as explained further below.
University of Texas Southwestern Medical Center v. Nassar: retaliation revisited
The plaintiff in Nassar was a staff physician at a university hospital who claimed he was being harassed and discriminated against by a supervisor based on his national origin and religion. To address the complaints, his employer initially granted his request to act as a staff physician without acting as a member of the university faculty, taking him outside the supervision of the alleged harasser. However, the offer was rescinded based on a policy requiring staff physicians to be faculty members. The plaintiff resigned and ultimately filed a lawsuit alleging that he was constructively terminated as a result of unlawful harassment and in retaliation for complaining about that harassment.
The issue before the Supreme Court was the causation standard applicable to retaliation claims. Under Title VII, plaintiffs making status-based discrimination claims—such as those alleging discrimination based on race, sex or national origin—need only prove that discrimination was a “motivating factor” in the employer’s decision to take adverse action in order to establish the claim. Discrimination need not be the only reason for the adverse action in order for the employer to be liable.
The EEOC has traditionally taken the position that this same lesser proof standard applies to retaliation claims, making it easier for plaintiffs to survive summary judgment and potentially recover on those claims. However, the employer in Nassar argued that statutory differences require retaliation plaintiffs to prove that retaliation was the “but for” cause of the adverse action; in other words, that the plaintiff would not have been terminated or demoted absent having engaged in protected activity, such as having made a discrimination complaint.
In a victory for employers, the Supreme Court agreed with the hospital and held that Title VII requires retaliation plaintiffs to prove that adverse action would not have occurred “but for” the employer’s desire to retaliate against the employee for having engaged in protected activity. The Court reasoned that statutory and conceptual differences between the two types of claims—discrimination based on employee status versus retaliation based on voluntary employee conduct—dictated that retaliation claims be subject to stricter standards of causation that are traditionally required to succeed on legal claims. Moreover, the Court held that the increasing frequency of retaliation claims puts a strain on employer and administrative resources, which would only increase by reducing the proof required to establish a claim.
Although this case will likely enable more employers to succeed on summary judgment for retaliation claims, Nassar does not change the legal elements required to establish a retaliation claim. Nor does it have a significant effect on how employers should handle internal complaints of discrimination, harassment or retaliation. Instead, the Supreme Court’s rejection of a “mixed motive” retaliation claim reemphasizes the importance of clearly setting forth in writing all reasons for any adverse employment action taken against employees and ensuring that those reasons are legitimately related to the employee’s performance and business needs.
As of June 2013, Facebook, the reigning social media giant, had 1.15 billion monthly active users who spent an average of 8.3 hours a month on Facebook. During roughly the same period of time, Facebook users “liked” a Facebook posting 4.5 billion times a day and uploaded an average of 350 million pictures a day. These statistics demonstrate that Facebook and other social media platforms have become the new water cooler in the office. Employees debate season finales of television shows shows, opine about Miley Cyrus’ dancing, and announce changes in their relationship status at least as often on Facebook as they do around the lunch table in the breakroom.
Communication through social media sites such as Facebook is becoming an increasingly acceptable norm. More and more individuals regularly share details of their daily life and thoughts on Facebook. The consequence for employers, however, is that the same individual who post about being annoyed by the long wait at the doctor’s office is an employee who will post a complaint about a workplace rule she finds oppressive. Similarly, the same individual who gripes about the refereeing of his kid’s soccer game on Facebook is an employee who will vent about a new, stricter manager. However, unlike Vegas, what happens on Facebook does not stay on Facebook, and frequently content posted by employees online spills over into the workplace. As a result, companies and their attorneys are being increasingly challenged to find a balance between employee privacy rights and enforcing workplace standards. A recent case underscores the importance of understanding privacy laws before advising clients on adverse employment actions. Ehling v. Monmouth-Ocean Hosp. Serv. Corp., No. 2:11-cv-03305, 2013 U.S. Dist. LEXIS 117689 (D.N.J. Aug. 20, 2013).
Paramedic’s problematic post
On June 8, 2009, she posted a statement on her Facebook page about a shooting that had taken place at the D.C. Holocaust museum. Her status update noted that the shooter had been shot by other guards, but survived. The employee wrote: “I blame the DC paramedics. I want to say 2 things to the DC medics 1. WHAT WERE YOU THINKING? And 2. This was your opportunity to really make a difference!” The employee’s Facebook friend took a screen shot of her page showing her comments and provided it to a manager. The hospital suspended the employee based on concerns that her posts reflected a “deliberate disregard for patient safety.”
The employee sued alleging, among other things, that the hospital violated the federal Stored Communications Act by accessing her Facebook posts. The court ruled that while the federal law did apply to certain Facebook content, the hospital did not improperly access her post by viewing the screenshot taken by her co-worker.
Standards of the Stored Communications Act
The law’s primary premise is that it prohibits intentional access, without authorization, to non-public electronic communications. The court closely analyzed the law and concluded that Facebook posts are electronic communications within the meaning of the law. Additionally, the court concluded that because the employee had adjusted her privacy settings so that only friends could see her posts, her Facebook postings were non-public and therefore fell within the protections of the Stored Communications Act. Accordingly, her employer was prohibited from intentionally accessing her posts without authorization.
The court found that the authorized user exception applied to MONOC’s viewing of the paramedic’s postings, and its rationale provided a lot of insight for employers on how to handle reports of Facebook or online misconduct by employees. The basis for the court’s finding that the access to the paramedic’s page was authorized was two-fold. First, her posting was accessed by someone who was a Facebook friend of hers and, as a result, had rights to view her postings. Therefore, as her Facebook friend, her co-worker was an intended recipient of her postings.
Second, the co-worker was not coerced or pressured to turn over the postings. In particular, the court found that the access to her Facebook posting was done by an authorized user because her Facebook friend viewed and copied the postings voluntary and not based on any coercion or request by his employer. The court inferred that had the employer or one of its managers pressured the co-worker to provide copies of the paramedic’s Facebook posts, the access would have been unlawful.
The rationale behind the court’s finding was that if the access to the Facebook postings had been made because of pressure from the employer, the employer would be the real entity accessing the postings, and it was not an authorized recipient of the communication. When a Facebook friend voluntarily turns over the information, however, he or she is an authorized user and intended recipient of the communication and there are no restraints on his or her ability to share the communication with others. The law, according to the court, presumes that a Facebook user assumes the risk that what happens on Facebook, does not stay on Facebook, and that their Facebook friends can voluntarily share their postings with others.
In the case of MONOC’s paramedic, the court ruled that the employer’s actions were lawful because access was made by an authorized user, her Facebook friend, and turned over to the company voluntarily. Accordingly, it was lawful for the hospital to review the postings and take lawful disciplinary action against the paramedic.
Best practices for handling Facebook follies
If the posting is not generally accessible to the public, then the employer should investigate how it learned about the posting and whether any copies of the posting that were provided to the employer were voluntarily provided by someone who was authorized to see the posting. If access to the postings was made by someone who was not an authorized user, such as a Facebook friend, or a supervisor or manager pressured a co-worker to provide access to the posting, then the employer should not view the posting or take any action based on it.
Finally, before taking any disciplinary action, the employer should consider whether disciplinary action is consistent and lawful. The protections of Title VII and other anti-discrimination laws against discrimination and retaliation apply to disciplinary action taken based on online misconduct. Therefore, any disciplinary action taken should be consistent with employer’s policies and past practices. Additionally, the National Labor Relations Act protects non-supervisory employee rights to discuss the terms and conditions of their employment in a concerted manner. Accordingly, if an employee is posting comments or concerns about topics such as his or her wages, hours or treatment by a supervisor, those postings may be protected in some circumstances and disciplinary action would be unlawful.
The Equal Employment Opportunity Commission (EEOC or Commission) recently filed federal lawsuits against Dollar General Corporation and a BMW manufacturing plant in South Carolina, based upon the EEOC’s revised guidance concerning the use of criminal background checks. The commission’s new guidelines, revised last year, recommend that employers not ask applicants about past criminal convictions and encourage employers to give job applicants an opportunity to explain past criminal misconduct before they are rejected. The EEOC emphasizes that background checks have a discriminatory impact on minorities and can violate Title VII of the Civil Rights Act—even if the background check policy applies to all applicants regardless of race.
The EEOC contends that the use of criminal background checks by Dollar General and BMW has discriminated against African-Americans. According to the commission, Dollar General, the nation’s largest small-box discount retailer, has implemented and utilized a criminal background policy that resulted in employees being fired and job candidates being screened out for employment in a way that disproportionately affected minorities. The EEOC’s lawsuit alleges that Dollar General rejected two African-American applicants without regard to the specific circumstances of their criminal records. The first had previously worked for another discount retailer for four years without incident, but also had a six-year-old conviction for possession of a controlled substance. The second did not have a felony conviction at all—the records check was simply incorrect.
Closer to home, the EEOC alleges that BMW, with facilities in Spartanburg, S.C., disproportionately screened African-American applicants using a background check policy that was not job-related or consistent with a business necessity. In other words, the convictions that disqualified applicants were not closely related to his or her ability to perform that job. According to the commission, BMW’s “blanket” policy excluded all applicants, regardless of qualifications, based on several types of crimes, without taking into account the distinction between felonies and misdemeanors or the time elapsed since the conviction. For example, the EEOC alleges that one African-American applicant was denied employment based solely on a 1990 misdemeanor conviction that was punished by a $137 fine.
The two lawsuits are the first to be filed since the EEOC issued its revised guidance under Title VII. In a statement, the commission explained that “overcoming barriers to employment is one of our strategic enforcement priorities, (and) we hope that these lawsuits will further educate the public and the employer community on the appropriate use of conviction records.”
However, the Dollar General and BMW lawsuits are the not first time the EEOC has alleged discriminatory impact based on the use of background checks. Prior to the publication of the revised guidance, the EEOC brought a similar lawsuit in federal court against Freeman Companies, a Maryland-based integrated services provider. The court dismissed the lawsuit because the EEOC failed to present any identified, specific practice in Freeman’s background check policy that had a discriminatory impact.
The court was bothered by the EEOC’s tactic of bringing a lawsuit to validate its discriminatory impact theory without having any facts to support it. The court also noted the Dollar General and BMW cases and explained “any rational employer in the United States should pause to consider the implications of actions of this nature” because “the EEOC has placed many employers in the Hobson’s choice of ignoring criminal history … or incurring the wrath of the EEOC.”
These lawsuits are the latest examples of the EEOC’s aggressive pursuit of its strategic enforcement priorities and their resolution, which, coupled with the court’s decision in the Freeman case, will likely set the tone for future actions.
The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) Director Patricia Shiu proclaimed herself the “new sheriff in town” when she assumed her position during President Obama’s first term in office. Director Shiu has a background as a litigator, often representing plaintiffs in civil rights matters. In one of her earliest announcements as director and often in subsequent interviews, Director Shiu emphasized the OFCCP’s intent to engage in an aggressive enforcement of the affirmative action obligations required of federal contractors and subcontractors. Director Shiu has stood by her promise.
The OFCCP enforces Executive Order 11246, Section 503 of the Rehabilitation Act of 1973, as amended (Section 503), and the Vietnam Era Veterans Readjustment Assistance Act of 1974, as amended (VEVRAA). Employers who have 50 or more employees and a direct contract with the federal government, or a subcontract necessary for the performance of the federal contract or that assumes some of the obligations of the federal contract, or are a financial institution under some circumstances, are subject to the affirmative action requirements. Where the contract in issue is in the amount of $50,000 or more, the employer must meet the full affirmative action requirements imposed by Executive Order 11246 and its implementing regulations, most notably, conducting specific and mandatory statistical analyses of the gender and racial/ethnic demographics of its workforce. Where the contract at issue exceeds $100,000, the employer is also required to meet the requirements of VEVRAA, which will soon require comparing its veterans workforce representation with a national benchmark, currently eight percent.
Under President Obama’s administration, the OFCCP has more than doubled the number of its compliance officers, that is, those persons tasked with conducting OFCCP audits or compliance reviews. Therefore, more and more federal contractors have found themselves the subject of these government audits. Not only have the number and intensity of the audits increased during Director Shiu’s leadership, but also Director Shiu has dramatically expanded the scope of the OFCCP’s focus. So far, in 2013 alone, the OFCCP has made four significant changes—all of which result in potentially greater federal contractor liability: (1) new compensation analysis; (2) new Federal Contractor Compliance Manual; (3) new VEVRAA regulations; and (4) new Section 503 regulations.
OFCCP has expanded its definition of “compensation.” Compensation now includes overtime, premium pay, vacations, benefits and even territory assignments, as well as promotional opportunities. OFCCP has noted that it particularly intends to scrutinize potential “channeling,” that is, for example, an employer’s assigning female employees to lower-paid bakery jobs while assigning new male employees to the deli department where they receive a higher level of compensation.
Although this directive does not have the same force of law as federal regulations, federal contractors are aware, as is the agency most certainly, that internal agency guidance provides a roadmap for employers, and employers wishing to avoid compensation violations should comply with the directive to the extent possible.
Federal Contract Compliance Manual (FCCM)
New veterans regulations
These regulations significantly increase the data collection required by federal contractors. Federal contractors must collect data and compare it with an eight percent national benchmark, as currently established, or the employer may establish its own benchmark, using specific factors.
First, applicants must be asked to identify whether they want to be considered a “protected veteran.” Then, after the individual is hired, he or she is asked to voluntarily self-identify the specific applicable veterans categories. Although the OFCCP does not require the contractor to conduct adverse impact analyses, as it does with the gender and race/ethnic data it also collects, the contractor must, of course, compare its data with the benchmark. The OFCCP has stated that a contractor that fails to meet the benchmark will not be subject to a violation or any financial penalties on that basis alone.
Section 503 regulations
Federal contractor employers have a utilization goal of seven percent disabled employees in each job group. They must provide OFCCP’s required identification request form to pre-offer applicants, post-offer applicants and the workforce within one year of March 24, 2014, then every five years.
As with the veterans regulations, the employer has been told not to fear a violation or financial penalty as a result of a failure to meet the seven percent utilization goal. However, also as with the veterans regulations, the employer must collect and review the statistical data it receives as a result of its inquiries of applicants and employees.
Other OFCCP initiatives
A federal district court has recently rejected the EEOC’s enforcement efforts with respect to criminal background checks. In EEOC v. Freeman, No. RWT 09cv2573, 2013 U.S. Dist. LEXIS 112368 (D. Md. Aug. 9, 2013), the court roundly criticized the EEOC’s assertion that an employer’s simply conducting a criminal background check (or obtaining an employee’s or applicant’s credit history) could violate Title VII.
The EEOC published its Criminal History Enforcement Guidance (the Guidance) in 2012. See Consideration of Arrest and Conviction Records in Employment Decisions Under Title VII of the Civil Rights Act of 1964, EEOC Enforcement Guidance No. 915.002 (Apr. 25, 2012). Attorneys general from nine states (including South Carolina) wrote a letter to the EEOC urging it to reconsider its Guidance and enforcement position, calling the agency’s actions “a quintessential example of gross federal overreach” and accusing the EEOC of attempting to extend Title VII to protect former criminals.
On August 29, 2013, the EEOC replied to the attorneys general to inform them that it would not withdraw the lawsuits and to clarify its stance on employers’ use of background checks. Specifically, the EEOC explained that it expects employers to use a two-step process when considering applicants’ criminal histories: first, employers should use a “targeted” background check that considers “the nature of the crime, the time elapsed [since the crime was committed], and the nature of the job.” Then, employers should conduct an individualized assessment of applicants who were purged from the candidate pool as a result of the targeted background check. The EEOC characterizes the second step as “a safeguard that can help an employer to avoid liability when it cannot demonstrate that using only its targeted screen would always be job related and consistent with business necessity.”
Freeman and EEOC litigation of Guidance
As the court explained in detail, the data submitted by the EEOC’s experts was fraught with errors, and accordingly, the court ruled the experts’ reports inadmissible. Id. at *21-40. The court also rejected the EEOC’s argument that, even if its experts’ reports were inadmissible, the national statistics demonstrating that African-Americans, Hispanics and men are arrested and incarcerated at a higher rate than other groups supported the EEOC’s case. Id. at *39-42. The court remarked that the EEOC offered no evidence to demonstrate that the “general populace” reflected in the national statistics was similar to the pool of applicants who allegedly suffered a disparate impact as a result of Freeman’s use of background checks. Id. at *39-40. Further, Freeman considered an applicant’s conviction records, not the applicant’s arrest or incarceration records, in its employment decisions, and therefore, the national statistics proffered by the EEOC were largely inapplicable. Id. at *40. The court also noted that Freeman used a variety of background and credit checks in its employment decisions, and the kinds of background checks conducted on an applicant varied depending on the type of position Freeman sought to fill. Id. at *5-12. According to the court, Freeman’s system of background checks could be separated into multiple parts, and the EEOC had failed to meet its burden to identify a specific background or credit check (or series of checks) that caused the alleged disparate impact. Id. at *42-45. Finally, the court pointed out that the EEOC conducts criminal background checks on all job applicants and conducts credit checks for about 90 percent of its positions. Id. at *3. In sum, the EEOC’s case suffered from a variety of flaws, and as a result, it could not establish that Freeman’s use of criminal background checks had a disparate impact. Freeman, No. RWT 09cv2573, 2013 U.S. Dist. LEXIS 112368.
Importantly, the court’s remarks regarding employers’ use of background checks reached beyond the instant case and struck a blow against the crux of the EEOC’s enforcement position, set forth in the Guidance, that consideration of an applicant’s criminal history could by itself violate Title VII. The court characterized the lawsuit as “a theory in search of facts to support it,” then explained if the EEOC prevailed, employers would face a “Hobson’s choice” of either ignoring applicants’ criminal backgrounds and thereby exposing themselves to liability for criminal acts committed by employees or being sued by the EEOC for attempting to maintain an honest workforce by considering applicants’ criminal histories. Id. at *53-54. In closing, the court wrote, “Something more, far more, than what is relied upon by the EEOC in this case must be utilized to justify a disparate impact claim based upon criminal history and credit checks. To require less, would be to condemn the use of common sense, and this is simply not what the discrimination laws of this country require.” Id.
Beyond Freeman: Pending EEOC litigation
The EEOC’s case against Dollar General is based upon the company’s practice of sending the personal information of an applicant who has received a job offer to a vendor who conducts a background check on the applicant. The EEOC alleges that the vendor has developed a matrix to evaluate applicants’ criminal backgrounds, weighing the seriousness of the crime committed and the amount of time that has elapsed since the crime was committed, among other factors. The EEOC emphasizes that the background check leaves no room for an individualized assessment of an applicant; if the applicant fails the background check, his or her employment offer is automatically rescinded. Dollar General allegedly does not consider the age of the applicant when the crime was committed, the relationship between the crime committed and the position for which the applicant has applied, or any other potentially mitigating factors. According to the EEOC, this practice has resulted in Dollar General’s eliminating African-American applicants at a disproportionately high rate. Specifically, the EEOC claims that between January 2004 and April 2007, Dollar General’s background check eliminated 10 percent of African-American applicants while only seven percent of non-African-American applicants were eliminated. The EEOC seeks an injunction against BMW’s continued use of its background check policies and damages for the claimants.
The agency’s lawsuit against BMW alleges that BMW directed a vendor—allegedly the claimants’ joint employer—whose employees worked exclusively at BMW’s plant to apply BMW’s policy against hiring applicants who were convicted of violent crimes or crimes involving moral turpitude. The EEOC claims the vendor screened out 88 employees, 70 (80 percent) of whom were African-American. The EEOC faults BMW for, among other things, failing to distinguish between felony and misdemeanor convictions and not considering the applicant’s age at the time of the crime. As in the Dollar General case, the EEOC seeks an injunction against BMW’s continued use of its background check policies and damages for the claimants.
Recently, states have begun to take action to short-circuit the EEOC’s attempts to enforce its Guidance. On November 4, 2013, the State of Texas sued the EEOC in the Northern District of Texas, seeking declaratory and injunctive relief to prevent the EEOC from forcing the state to change the policies of state agencies that prohibit hiring applicants with certain criminal histories. This lawsuit was preceded by attorneys general from nine states sending a letter to the EEOC to protest its adoption and enforcement of the Guidance.
Employers across the country have come to realize that effective background check procedures can help produce more informed hiring decisions; protect employees, customers and company assets; and reduce liability for negligent hiring and other workplace claims. At the same time, these recent developments in the law have resulted in increased scrutiny of employers’ criminal and credit background check policies.
The Annual North Carolina/South Carolina Employment and Labor Law CLE in Charleston was a big success. Our program coordinator, Stephanie Lewis, did an outstanding job, but as usual, it was the invaluable work of Tara Caine and Marley Douglas who made the task of pulling it all together seamless and hassle free. The large attendance (more than 225) was a good sign of the strength of our section; however, if we want to attract more attendees without further compromising the available space we must look for possible alternative arrangements. We all know suitable facilities in Charleston are limited. We welcome ideas from the section members regarding options, keeping in mind that this is a joint endeavor and our North Carolina counterparts also get a say.
For those section members who agreed to speak this year—thank you and great job. We look forward to more volunteers for our future programs.
Section Midyear Meeting, Lunch & Award Presentation
The Employment & Labor Law Section will honor an individual nominated by his/her professional peers for meritorious service to employment and labor law practice in South Carolina. The honoree will be selected by the Section Selection Committee, which consists of the current Section chair, up to five past Section chairs and one former award recipient. The 2014 recipient will be recognized at the Section Midyear meeting, scheduled for May 16, 2014 in Columbia.
Click here for a nomination packet. The deadline to submit nominations and supporting documents is March 7, 2014.
Articles are needed for the next issue of the Employment & Labor Law Section newsletter. If you are interested in submitting an article, please forward your submission(s) to Karen L. Luchka at email@example.com.
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