Welcome to the Labor and Employment Fall Seminar 2015 ... and... · Labor and Employment Fall Seminar 2015 Update on Labor and Employment Law. 2

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HARTFORD | STAMFORD | GREENWICH | NEW HAVEN | WASHINGTON, DC

Welcome to the

Labor and Employment Fall Seminar

2015 Update on Labor and Employment Law

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Complicated Issues Under the FMLA: More Than Just the ABCs

Lisa Banatoski Mehta

Peter J. Murphy

www.shipmangoodwin.com© Shipman & Goodwin LLP 2015

Doctor, Doctor, Give Me The News…

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Complicating Factors• Family Medical Leave Act (Federal and/or State)

� Intermittent leave

• Paid Sick Leave

� The interaction between the FMLA and CT’s Paid Sick

Leave law

• Americans with Disabilities Act

� The interaction between the FMLA and the ADA

• Workers’ Compensation

� The interaction between the FMLA and Workers’

Compensation

HOW ABOUT ALL FOUR!


FMLA (Federal and State) Issues

�Covered Employer?

�Eligible Employee?

� If yes,

Confirm available amount of

FMLA time based on applicable law

and prior usage

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Paid Sick Leave

�Covered

Employer?

�Eligible

Employee?

�Existing Leave

Under Policy or

Labor Contract? “I have a headache, so I’m going home.

You HAVE to pay me.”


Americans with Disabilities Act

�Covered

Employer?

�Eligible

Employee?

� Interactive

Dialogue:

What’s Required?

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Workers’ Compensation

�Covered Injury?

� Supplemental

Benefits?

�Work Restrictions?

�Light Duty?


You Make The Call!

12


• Larry Litigious, a custodian, fell off a ladder while

replacing a light bulb. Larry said he felt fine so he

went home without incident

• The next day, the supervisor, Sal Slipup, got a fax

from Larry’s chiropractor saying he would have to

miss 4 weeks of work

• Sal begins charging this time against Larry’s paid sick

leave allocation

Let’s Shed Some “Light” On The Issue


May Larry use FMLA leave for this

absence?

1 2 3 4

0% 0%0%0%

1. No, because he was injured

at work and its covered by

“comp”

2. No, because he did not

specifically request it

3. Only if workers’ comp

denies his claim

4. Yes, assuming he is eligible

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Answer

• Yes, Larry can use FMLA leave for this 4

week absence provided it qualifies as a

serious health condition

• Did Sal Slipup make a mistake, though?


FMLA and Paid Leave

• FMLA is unpaid leave

• However, an employer can require

substitution of paid leave for unpaid

FMLA leave

• Query: Application of CT Paid Sick

Leave?

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Does the substitution rule apply to

Larry?

1 2 3 4

0% 0%0%0%

1. Yes, he can be required to use

paid leave in addition to workers’

compensation

2. Yes, he will use paid leave instead

of receiving workers’

compensation

3. No, he can only receive workers’

compensation during this FMLA

leave

4. No, he gets nothing; it was his

fault


Answer: It Depends.• Because the workers’ compensation absence is

not unpaid, the provision for substitution of the

employee's accrued paid leave is not applicable;

neither the employee nor the employer may

require the substitution of paid leave

• However, employers and employees may agree,

where state law permits, to have paid leave

supplement workers’ compensation benefits,

where workers’ compensation only provides

partial replacement income of an employee's

salary

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The Designation Letter AND

Certification Forms Are Important!

• Reason for Leave Information

• Timing Issues

• Address Any Paid Leave and Benefit

Payments

• Required Updates and Recertification

• Intermittent Leave Information

• Return to Work Requirements


After several weeks, Larry

tells Sal that he is ready

to return to work,

but needs Sal to create

a desk job for him.

Back to Work (Sort of)...

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Not So Fast…

A few years ago, Sal refused

to create a desk job for one

of Larry’s coworkers who

was pregnant because her

condition was (presumably)

not work-related.


Should Sal create a desk job for Larry?

1 2 3 4 5

0% 0% 0%0%0%

1. Yes, workers’ compensation

requires Sal to create the job

2. Yes, the ADA requires Sal to

create the job

3. No, because she did not do it for

the pregnant custodian

4. No, because it is not equivalent to

Larry’s custodial job

5. No, but if one already exists, Sal

may give it to Larry

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Answer: It Depends.

• Under the Workers’ Compensation Act,

the employer does not have to provide

light duty work if none is available

• However, if such work is available, and suitable to

Larry’s condition prior to his reaching “maximum

medical improvement,” the employer must provide

such work


Answer: Continued...

• Under FMLA, if the

health care provider

treating Larry’s workers'

compensation injury

certifies he is able to return to a “light duty job” but

that he is unable to return to the same or equivalent

job, Larry may decline the employer's offer of a

“light duty job”

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Can Sal pay Larry as a clerical worker

instead of his higher custodian wage?

1 2 3

0% 0%0%

1. Yes

2. Only if Larry stays in

the desk job after his

FMLA leave expires

3. No


Just One More Thing…

• After several weeks, Larry

tells Sal that he now needs

to leave at 1:00 p.m. twice

a week for chiropractor

appointments.

• Sal thinks this is excessive,

and wants to deny Larry’s

request.

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How should Sal respond to Larry’s

request?

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0% 0% 0%0%0%

1. Charge it against his vacation/

personal time

2. Count it as intermittent FMLA

3. Contact his chiropractor to

confirm that he really

has appointments

4. Refuse to pay him for it

5. In a few weeks, fire him for

absenteeism


Intermittent Leave under the FMLA

• Intermittent leave means leave taken in separate

periods of time rather than for one continuous period

of time

• An employee may take intermittent leave whenever it

is medically necessary for a serious health condition

of the eligible employee, his or her spouse, child or

parent

• Can be taken for portions of days, or full days on an

occasional/“as needed” basis for qualifying reasons

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Managing Intermittent Leave

• If there are scheduling issues, employers may

temporarily transfer employees taking intermittent

leave to another position of equal pay and benefits.

Equivalent duties are not necessary under FMLA,

however, consider bargaining issues

• Employers have the option of modifying the existing

position to accommodate the employee’s leave

schedule


More Leave, Please!Larry starts calling out sick on

some Fridays each month. Larry

requests intermittent leave for

these absences. He explains that

he needs this leave because by

the end of the week his back is in

pain. Sal is getting increasingly

frustrated.

Does Sal have any options?

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Can Sal Do Anything?

1 2 3

0% 0%0%

1. Nothing – intermittent

leave stinks!

2. Yes – Fire Larry

for abusing leave

3. Yes – Follow-up

with Larry’s doctor


Answer

• Yes, Sal may follow up with Larry’s doctor

• Under Federal FMLA, there is an option for

medical re-certification when “circumstances

described by the previous certification have

changed significantly (e.g., the duration or

frequency of the absence, the nature or severity

of the illness, complications)”

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Connecticut Law

• The CT FMLA statute specifically prohibits re-

certifications of less than 30 days, and does not

address changed circumstances at all

• Also, the CT FMLA regulations do not allow re-

certification every 30 days if the original certification

included a “minimum duration” for the underlying

serious health condition that is longer than 30 days

• You must confirm the facts carefully before

proceeding


Monday Morning Quarterbacking…

Larry loves to watch NFL football on the

weekends and gets a little too excited about the

games -- often leaping from the couch when

there’s a touchdown! He wrenches his back so

his doctor has prescribed him muscle relaxants to

take on Sunday nights to help with the pain. He

wakes up free of pain, but groggy and tells Sal

that he needs to come in late every Monday.

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Must Sal allow leave for this

purpose?

1 2 3

0% 0%0%

1. Yes

2. No

3. It depends,

because lawyers

always say that!


One Monday, Larry fails to return

and exhausts his FMLA. Larry’s

doctor says he needs another 3

weeks of leave. Larry is still

receiving workers’ compensation

benefits. Larry’s employer has a

“no fault” leave policy.

Point of No Return?

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Should Sal Terminate Larry?

1 2 3

0% 0%0%

1. Yes – It’s about time!

2. No – because of the

ADA

3. No – because Larry is

on Workers’

Compensation


Answer

Probably not, because of the ADA

and Workers’ Compensation Act

25


Application of the ADA

• Under the ADA, it is clear that far more health

conditions may be subject to “disability”

coverage, reasonable accommodations, and

protection, even some short term conditions

• In Larry’s situation, his unpaid leave likely

qualifies as a reasonable accommodation

invoking the protection of the ADA


Impact of Workers’ Compensation

• Workers’ Compensation claims of retaliation/

discriminatory discharge under CGS § 31-290a are

common when an employer terminates an injured

employee, no matter how much time has passed

without him/her returning to work

• Even though Larry has exhausted all of his available

FMLA time, terminating him may give the

appearance of retaliation because of the “confluence

in time” to the date of his injury

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HR recommends that Sal not

terminate Larry. Sal writes a

letter to Larry granting him

the requested 3 weeks of

additional leave. Of course,

3 weeks later, Larry requests

another 4 weeks off.

Will It Ever End?


Should Sal give Larry more time?

1 2 3

0% 0%0%

1. Yes

2. No

3. Maybe, because

lawyer’s always

say that

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Larry returns to the “light duty” position and

after 6 months, Sal decides that she can’t justify

paying a custodian to sit at a desk. Sal decides to

eliminate the “light duty” position. Sal plans to

use the savings to hire Ronald Replacement as a

custodian to fill Larry’s old role.

Back on the (Desk) Job!


Can Sal eliminate Larry’s position?

1 2 3 4

0% 0%0%0%

1. No, because Larry was

injured on the job

2. No, not if Larry is

disabled

3. Yes, if there is a

legitimate business reason

4. Yes, because his FMLA

leave has been exhausted

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Overview of the ADA

• Federal law that prohibits discrimination against

individuals on the basis of disability. It applies to all

state and local entities

• May not discriminate against an otherwise qualified

individual (i.e., participant must meet all essential

qualifications with or without reasonable

accommodations)

• Requires “reasonable accommodations”


If, after learning of Sal’s plans,

Larry demands a reasonable

accommodation, can Sal still fire him?

1 2 3 4

0% 0%0%0%

1. No, it would be disability

discrimination

2. No, if the desk job is a

reasonable accommodation

3. Yes, Larry waited too long to

make the demand

4. Yes, Larry is not disabled if he

can work any job

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Questions



Coffee Break

Please return by 10:30 a.m.

Agenda:

10:30 – 11:15 – The NLRB vs.

Your Employee Handbook

11:15 – 12:00 – Medical

Marijuana in the Workplace

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The NLRB vs.

Your Employee HandbookDaniel A. Schwartz

Christopher E. Engler


What is your favorite thing about the

Halloween season?

1 2 3 4

0% 0%0%0%

1. The candy

2. The costumes

3. The movies

4. Pumpkin spice lattes

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What is your favorite Halloween

movie?

1 2 3 4

0% 0%0%0%

1. Halloween

2. Hocus Pocus

3. Casper the Friendly

Ghost

4. Scream


The Law: The National Labor

Relations Act

• The law has not changed and has been in

existence for decades

• But, the interpretation has evolved to “fit”

modern times

• And, to make the National Labor Relations

Board more relevant

32


Does the NLRA apply to your

workplace?

1 2 3 4

0% 0%0%0%

1. Yes

2. No

3. Yes, but only to our

employees who are

union members

4. Maybe


The Law: The National Labor

Relations Act

• “Section 7” rights

� Apply to all employees

� Right to self-organization, to join labor

organizations, to bargain collectively

� To engage in “other concerted activities” for the

purpose of collective bargaining or other “mutual

aid and protection”

33


Public Sector Laws

• State law provides identical rights to state and

municipal employees:

� Section 7-468 of Municipal Employee Relations

Act (“MERA”)

� Section 5-271 of State Employee Relations Act

(“SERA”)

• Connecticut State Board of Labor Relations (“SBLR”)

often follows NLRB precedent and guidance


What is Protected Concerted

Activity?

• Is employee acting on behalf of other employees?

• Is employee initiating group action?

• What is the subject of the employee’s conduct?

• Who heard or saw the conduct?

• How did employee communicate the conduct?

• Was employee disparaging or disloyal?

34



Activity?


• Speaking to co-workers about preferential

treatment and favoritism of other employees

• Public statements about patient care issues

• Employee complained about fuel surcharge

that decreased employees’ net pay


Activity?

35


• “Supervisor insults are protected activity”

What is Protected Concerted Activity?


“Inherent” Protected Concerted

Activity

• Discussions about wages, work schedules and

job security are likely to spawn collective

action

36


“Inherent” Protected Concerted

Activity

• Employee asks

co-worker about

help-wanted

advertisement to

see who would be

terminated


What is Not Protected?

• Posting unprofessional

“tweets” where employee

had not discussed

concerns with co-workers

37


What is Not Protected?

• Complaints about tip sharing

policy

• Criticizing employer on page

of U.S. Senator

• Comment made on way to

pick up patient making fun

of co-worker


You Be the NLRB!

Do these employees’ actions constitute protected

concerted activity?

38


“Bob is such a NASTY MOTHER

F*@KER don’t know how to talk to

people!!!!! F*@k his mother and his entire

f*@king family!!! What a loser!!!! Vote

YES for the UNION!!!!!!

An Employee Posts This on

Facebook:


Do the employee’s actions constitute

protected concerted activity?

a b c d

0% 0%0%0%

a. No, because profanity

isn’t protected

b. No, because it involves

Bob’s family

c. Yes, but only if Bob

never saw the post

d. Yes, because it shows

support for the Union

39


An employee seeks her coworker’s

assistance in pursing a sexual

harassment complaint. The

employee was the only victim of the

harassment.


Do the employee’s actions constitute

protected concerted activity?

a b c

0% 0%0%

a. No, because the employee

should report the harassment

to HR immediately

b. No, because the complaint

would only “benefit” the

individual employee

c. Yes, because the harasser

might harass other employees

40


Protect Yourself With A Policy

• Be careful not to be too broad

� Will employees (or the NLRB) construe the

policy to prohibit protected concerted

activity?

� Is policy being used as such?

• Was policy drafted in response to protected

activity?


How to Draft a Compliant Policy

• The NLRB likes limiting language – a

“savings clause”

� “This policy is not designed to prohibit or

preclude employees’ exercise of their rights

under Section 7 of the NLRA”

� “Please go form a union”

41


Confidentiality Policies• Do:

� Draft policies carefully

� Provide examples and context

� Use limiting language

• Don’t:

� Use provisions relating to employment terms and

conditions

� Overreach


Unlawful Provisions

• Do not discuss customer or employee information

outside of work, including phone numbers and

addresses

• If something is not public information, you must not

share it

• You must not disclose proprietary or confidential

information about the company or other associates if

the information was obtained in violation of the law

or lawful company policy

42


Lawful Provisions

• No authorized disclosure of business secrets or

other confidential information

• Misuse or unauthorized disclosure of

confidential information not otherwise

available to persons outside of company is

cause for disciplinary action, including

termination


You Decide: Which of these policies is

most likely to be lawful?

a b c

0% 0%0%

a. Never publish or report on

conversations that are meant to

be private or internal to the

company

b. Do not disclose details about the

company

c. Do not disclose confidential

financial data or other non-public

proprietary company information

43


Confidentiality of Human Resource

Investigations

• No automatic confidentiality

• Factors:

� Protect witnesses

� Prevent destruction of evidence

� Ensure that testimony is not fabricated

� Prevent a cover-up


Regulating Employee

Conduct Toward Employer

• Proceed with caution!

• The NLRA has been

interpreted to provide very

broad rights to employees

• Few permissible restrictions

remain

44


Unlawful Policies

• Do not make fun of, denigrate, or defame your

co-workers, customers, suppliers, or

competition

• Be respectful of others and the company

• No defamatory or discriminatory comments

about the company, its customers, its

competitors, employees, or management


Lawful Policies

• No rudeness or unprofessional behavior

toward a customer

• Employees are expected to work in a

cooperative manner with management, co-

workers, customers, and vendors

45


You Decide: Which of these policies

is most likely to be lawful?

a b c

0% 0%0%

a. Being insubordinate, threatening,

intimidating, disrespectful, or

assaulting a manager, co-worker,

or customer will result in

discipline

b. No disrespectful conduct or

insubordination, including refusing

to follow supervisors’ orders

c. Maintain a respectful atmosphere

at all times


Employee Conduct Toward Other

Employees

• Perhaps a little more

discretion for employers

here

• But, the rules are still

slanted toward employees

being able to do and say

more than you might want

46


Unlawful Policies

• Do not pick fights online

• Do not make insulting, embarrassing,

hurtful, or abusive comments about other

employees online

• Show proper consideration for others’

privacy and avoid topics that may be

considered objectionable or inflammatory


Lawful Policies

• Do not make inappropriate gestures, including visual

staring

• Any graphic work by employees must not reflect

violent, discriminatory, abusive, offensive,

demeaning, or unprofessional messages

• No harassment of employees, patients, or facility

visitors

• No use of racial slurs or derogatory comments

47


You Decide: Inquiries from outside the

company

a b c

0% 0%0%

a. All inquiries from the media

must be referred to the Director

of Operations

b. If you are contacted by any

governmental agency, you must

contact the Law Department

immediately

c. The company will respond to the

news media only through the

designated spokesperson


Photography And Recordings

• Basically, the more

detail you can

provide as to the

reason and scope of

the rule, the better

the chance it will

work

48


Other Considerations

• Restrictions on leaving work should be

specific

• At will employment statements

• Use of logos and trademarks

• Conflict of interest rules


Questions?

49



Medical Marijuana in the Workplace:A Trip Down the Rabbit Hole

Kevin M. Roy

Keegan A. Drenosky


Marijuana Legislation in the U.S.

• Currently, 23 states and the District of Columbia have

legalized some type of marijuana usage

• Some of these states, like Connecticut, only allow the

use of medical marijuana, while others also permit

recreational use

• There are ballot initiatives in many other states

regarding similar proposed legislation

50


Potential Medical Marijuana Ballot Initiatives:

Florida, Pennsylvania, Ohio, NebraskaSee “Marijuana on the Ballot,” BALLOTPEDIA,

available at http://ballotpedia.org/Marijuana_on_the_ballot#tab=By_year

See Kathleen McLaughlin, “Medical Marijuana Bill Won’t

Fly This Session, But Attitudes Shift,” INDIANAPOLIS BUS. J.

(Jan. 31, 2015)


What % of Americans support

the use of medical marijuana?

34%

53%

67%86%

0% 0%0%0%

1. 34%

2. 53%

3. 67%

4. 86%

51


Connecticut Legislation

• May 31, 2012 passage of “An Act Concerning the

Palliative Use of Marijuana”

• Conn. Gen. Stat. § 21a-408 et seq.

� Legal for “qualifying patients” and “primary caregivers” to

possess limited amounts of marijuana for “palliative use”

� In order to be a “qualifying patient,” a person must have a

physician written prescription, a valid registration from the

Department of Consumer Protection, and a diagnosis of a

“debilitative medical condition”


Which of the following illnesses is a

“Debilitative Medical Condition”?

1 2 3 4 5 6

0% 0% 0%0%0%0%

1. Attention Deficit Disorder

2. Influenza

3. Post Traumatic Stress

Disorder

4. Psoriasis

5. All of the above

6. None of the above

52


(A) cancer, glaucoma, positive status for human

immunodeficiency virus or acquired immune deficiency

syndrome, Parkinson's disease, multiple sclerosis, damage to

the nervous tissue of the spinal cord with objective

neurological indication of intractable spasticity, epilepsy,

cachexia, wasting syndrome, Crohn's disease, posttraumatic

stress disorder, or

(B) any medical condition, medical treatment or disease

approved by the Department of Consumer Protection

pursuant to regulations adopted under section 14 of this act

“Debilitating Medical Condition”


Where does the CT Palliative Use

Act permit medical marijuana use?

1 2 3 4

0% 0%0%0%

1. Moving vehicles

2. Schools

3. The workplace

4. At home

53


“No employer may refuse to hire a person or may

discharge, penalize or threaten an employee solely on

the basis of such . . . employee’s status as a qualifying

patient or primary caregiver. . . . Nothing in this

subdivision shall restrict an employer's ability to

prohibit the use of intoxicating substances during

work hours or restrict an employer's ability to

discipline an employee for being under the influence

of intoxicating substances during work hours.”

Conn. Gen. Stat. § 21a-408p(b)(3)


Potential Problem Areas

Hypothetical #1:

Your employee, Bob Jones, appears under the influence

of marijuana at work, where he is responsible for

computer data input. When questioned, he tells you he

is getting treated for cancer and going through

chemotherapy, and the only thing that helps is medical

marijuana, so he smoked a bowl at lunch to keep from

throwing up. He apologizes and says he will do

something light until the effect wears off.

54


How do you respond to Bob Jones?

1 2 3

0% 0%0%

1. Fire him

2. Determine whether he has a

written certification from a

physician and is a

“qualifying patient,” and

then fire him

3. Accommodate Bob’s

request by allowing him to

go home and smoke at

lunch


Employers May:

• Continue to prohibit the use of intoxicating

substances, including marijuana, in the

workplace

• Employers may continue to discipline

employees for being under the influence of

intoxicating substances at work

55


Hypothetical #2:

Your employee, Jen Smith, asks her

direct manager if he would

accommodate her use of medical

marijuana.

The manager responds: “Hell no!

You can’t be stoned at work!”

Jen says, “Gee, I have glaucoma and

I was hoping you’d accommodate

my condition.”


Was the manager’s response

appropriate?

No

Yes

Mayb

e

0% 0%0%

1. No

2. Yes

3. Maybe

56


Conflict Between State and Federal Law

• Marijuana, even for medical use, is still illegal under

federal law

� Attorney General – Possessing marijuana in any

capacity, other than a federally authorized research

program, is a violation of federal law regardless of

state laws permitting such activities

• Employers may discriminate if required by federal

funding or contracting provisions


High Risk and Safety Sensitive Jobs

• Federal DOT Regulations: Unacceptable for any

safety-sensitive employee subject to drug testing

under DOT regulations to use marijuana, regardless

of state legislation

• What jobs are “safety-sensitive”?

� Conductors, school bus drivers, pilots, etc.; jobs

regulated by federal law

• Federal OSHA: Employers have a general duty to

provide safe work environment

57


American With Disabilities Act 42

U.S.C. § 1201 et seq., “ADA”• Employers must provide a reasonable

accommodation to qualified individuals with

disabilities unless to do so would cause an undue

hardship

• The ADA excludes persons currently engaged in the

“illegal use of drugs” from the definition of an

“individual with a disability”


Must Employers Accommodate

Medical Marijuana Use?

• NOT under the ADA

• “We recognize that the plaintiffs are gravely ill, and that their

request for ADA relief implicates not only their right to live

comfortably, but also their basic human dignity. . . . Congress

has made clear, however, that the ADA defines ‘illegal drug

use’ by reference to federal, rather than state law, and federal

law does not authorize the plaintiffs’ medical marijuana use.”

James v. Costa Mesa

58


• No protected class based on use of medical marijuana

� BUT an employee may argue that he was discriminated

against based on his underlying disability

• Anti-discrimination provision of the Palliative Use Act =

employers are prohibited from discriminating against a

“qualifying patient”

� We are likely to see additional discrimination cases in CT

on these grounds

Connecticut Fair Employment Practices Act, § 46a-60, et seq.,“CFEPA”


Hypothetical #3: You are considering John Henry

for a position with your company. You search for

him on the internet and find his public Facebook

page, where he has posted pictures of himself

smoking a joint. On this basis, you decide not to hire

John. John later finds out the reason he wasn’t

chosen for the position and sues your company,

claiming that he wasn’t hired because of a perceived

disability and/or because you don’t want to

accommodate his use of medical marijuana.

59


Does John Henry have a valid

claim?

1 2 3

0% 0%0%

1. No

2. Yes

3. Maybe


Drug Testing

• Conn. Gen. Stat. § 31-51t, et seq.

� Requires that an employer have “reasonable

suspicion” that an employee is under the influence

� Generally may not require random drug testing

• Testing positive for marijuana may not necessarily

mean an employee is “under the influence”

� Blood tests vs. urine tests

60


How Can Employers Avoid These

Issues?

• Train managers to document verifiable observations

in order to prove an employee was under the

influence at work

• Determine whether the employee is a “qualifying

patient” and/or has requested an accommodation for a

disability

• Determine whether additional lab testing can be done

to determine when the drug was used


Lessons from Other States

• Majority of courts across the country considering

these issues have concluded that employers may

discipline employees that use marijuana in the

workplace, are under the influence, or fail drug tests

• Courts have concluded that because medical

marijuana is illegal under federal law, the activity

cannot be “lawful” for purposes of the state law

61


Employer Policies

• Revise policies to reflect the 2012 CT legislation

• Adopt straightforward, zero tolerance policies for

employees that use drugs at work or that are under the

influence at work

• Educate staff on these policies and procedures

• Comply with required federal laws

• Review these policies and legal updates frequently, as

the law is evolving


Questions?

Documents

Welcome to the Labor and Employment Fall Seminar 2015 ... and... · Labor and Employment Fall Seminar 2015 Update on Labor and Employment Law. 2