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Labor and Employment Insights
Spring/Summer 2001
Articles:
Are You Vulnerable To A Wage-Hour Class Action?
James M. Coleman, Arlington Office
The plaintiffs’ bar has discovered a new gold mine: class actions under the Fair Labor Standards Act ("FLSA"). The allegations are usually that the employer failed to compensate employees for time worked, or that the employer erroneously classified non-exempt employees as exempt.
The plaintiff’s bar knows that a class action—the mere threat of it—can often result in big, extortionate settlements. Most companies (as well as their shareholders) would rather give in than face years of time-consuming, costly litigation.
Why are wage-hour lawsuits so attractive to our worthy adversaries in the plaintiffs’ bar? Two words: Easy, and Money.
It’s EASY to create the "class." Wage-hour violations generally affect a broad class of employees rather than a single individual. If an employer has misinterpreted the overtime laws for one non-exempt employee, it’s a pretty good bet that the employer is misinterpreting the overtime laws with respect to all of its non-exempts in the same or similar job classifications. All it takes is one aggrieved plaintiff to become the representative for an entire class of employees and ex-employees. What’s more, the courts have said that the plaintiff’s burden in proving that a class of employees is "similarly situated" to the individual plaintiff (a requirement in class actions) is light in wage-hour cases—lighter than the burden faced by plaintiffs in other types of class actions.
And the MONEY in wage-hour cases is substantial. The FLSA allows for double damages on awards for minimum wage or overtime compensation (in other words, unpaid wages times two). At first glance, that doesn’t seem too bad compared with a big racial harassment suit, but the FLSA class action gets you on volume: a wage-hour suit is likely to involve hundreds or even thousands of employees and former employees who were underpaid. And, as with most federal causes of action, the FLSA allows the court to award costs and attorney’s fees on top of any recovery awarded to the plaintiffs.
So, how do you know whether your company will be a victim?
Normally, it will start innocuously enough, with a small-dollar lawsuit filed on behalf of an individual employee or a handful of employees alleging, for example, that they were not paid overtime because the employer improperly classified their jobs as being "exempt." The clue that the lawsuit may be much worse than meets the eye will be some language, probably buried in the complaint, saying that the suit is being filed on behalf of "all those ‘similarly situated’" to the named plaintiffs.
Although the "similarly situated" language is an alarming clue, many unskilled plaintiffs’ lawyers routinely throw this language into every employment complaint they file, so the language itself does not necessarily mean you are in for a class action. The real sign comes during discovery, which can be served simultaneously with the complaint: if the plaintiff’s attorney really has "class action" on his or her mind, the requests will ask for the names and last known addresses for everyone employed during the past three years in the position at issue.
Employers who are accustomed to garden-variety disparate treatment discrimination lawsuits will think they can refuse to provide this information. But, in a wage-hour case, the courts usually require the employer to provide it.
Alternatively, the plaintiffs’ attorney may ask the court to supervise or facilitate the notification process. With this strategy, the court actually sends a notice to all potential members of the class (i.e., everybody who has worked in the job at issue for the past three years), explaining the nature of the pending lawsuit and advising the members of their right to "opt-in" as plaintiffs if they wish to have their rights determined by the court. Unfortunately, courts are increasingly inclined to order such notices based on a cursory review of a limited factual record.
Whether through discovery or through a court-issued notice, the plaintiff’s lawyer has you. In the case of disclosure through discovery, the lawyer can contact the "witnesses" to "pursue factual information," but don’t be fooled: the pursuit of "information" is usually nothing more than a thinly disguised invitation to join the lawsuit. In the case of a court-issued notice, the court itself invites your employees and ex-employees to join the party.
As stated above, the big-money FLSA cases usually involve allegations that employees were not paid for all hours worked, or that an employer incorrectly treated a group of employees as exempt from the overtime laws. Either way, back wages are determined by calculating the number of hours that went uncompensated. This can be particularly problematic in the case of an employer who incorrectly classified its non-exempt employees as "exempt," because in such situations there will normally be no records of any hours worked, much less of overtime hours worked. It will be the employer’s memory against the employee’s.
(Thus resulting in the phenomenon of the employee who couldn’t even remember to show up for work on time suddenly developing perfect recall of the many, many undocumented overtime hours "worked," undoubtedly because of selfless devotion to the company.)
So, how do you keep this fate from befalling your company? First, make sure your employees are accurately recording all time worked, and scrupulously maintain those records. Second, make sure the people you think are "exempt," really are. An employee is not eligible for the "professional" exemption simply because she conducts herself at work in a "professional" manner. An "executive secretary" is not eligible for the "executive" exemption simply by virtue of his job title. Apart from these obvious examples, be particularly careful about your treatment of employees on the borderline between exempt and non-exempt, such as low-level supervisors and high-level clericals. Keep informed about the jobs that have resulted in litigation during the past few years: claims adjuster, computer programmer, and news reporter and editor.
Even with the employees you know are non-exempt, be careful about things like working during lunch hours, or before or after normal working hours; business conducted via mobile phone during commutes; and work performed while at home. Remind such employees that they need to include all of these "little extras" in their time records. Better yet, remind them in writing so you have proof that you did so. Check behind them to make sure they are doing it. Discipline them if they aren’t (you can’t refuse to pay them if you know they worked, but you can progressively discipline them for failing to follow your instructions regarding documentation or for working without your authorization).
Finally, when in doubt about any wage-hour issue, consult with counsel. The wage and hour laws are highly technical, and many employers, despite the best of intentions, make mistakes. It is advisable to have an audit of your wage and hour practices every two to three years to ensure that you are in compliance with applicable laws and can defend yourself in the event that employees claim you owe them unpaid wages. A few hours of prevention could keep a plaintiff’s lawyer from "striking gold" in your company.
Jim Coleman practices in the areas of wage-hour, and employment litigation prevention and defense.
EEOC Rule On Age Waivers: An Analysis
Robin E. Shea, Winston-Salem Office
During my 40-plus years I have graduated from college and law school, held several jobs, reared two sons and managed to get one off to college, bought two houses and several cars, and voted in seven presidential elections.
I have signed permission slips, wills, checks, promissory notes, credit agreements, tax returns, mortgages, marriage licenses, and divorce decrees. My status as a lawyer makes me an "officer of the court." I am a Notary Public. I can drink alcoholic beverages and smoke cigarettes, if I want to. If I commit a crime, I will be tried as an adult.
Yet the EEOC says that, because I am over 40, I am not competent to waive my rights through the type of agreement that I draft for my clients every day.
The EEOC has issued regulations on waivers of rights under the Age Discrimination in Employment Act ("ADEA") that implicitly presume that people age 40 and over are not competent to enter contracts or handle their own affairs.
The key points are these: (1) any ADEA waiver that requires the employee to "tender back" the amounts paid (in other words, give the settlement money back to the employer) as a precondition to suing is void; (2) an employer who loses in a suit alleging an invalid ADEA waiver and is found liable for discrimination can recover no more than the amount, if any, recovered by the employee in the lawsuit; and (3) any ADEA waiver that says otherwise is void.
Point 1 is unremarkable, given the decision of the U.S. Supreme Court in Oubre v. Entergy Operations, Inc., saying the same thing. One can disagree with it, but at least this has already been determined to be the law of the land.
Points 2 and 3 are far more troubling. Unlike the "tender back" provision, or, for that matter the Older Workers Benefit Protection Act, there is no court or congressional authority for the EEOC’s position on these points. Thus, there’s an argument that the EEOC has exceeded its authority in issuing these regulations at all.
And the regulations are substantively bad. Imagine an employer who conducts a reduction in force and offers severance packages to the affected employees in exchange for getting releases. The young ones, who arguably need the most protection (being relatively inexperienced and all), get none. If they take the deal, they’re stuck with it. But we "helpless" 40-and-overs have it made: 45 days to consider the agreement, disclosures, seven days to change our minds and revoke our signatures. And now, thanks to the EEOC, we can still sue for age discrimination, even though we got all those special allowances before the agreement became enforceable.
The regulations give a 40-and-over no reason not to sue in breach of the ADEA waiver. Arguably, the regs say that we can never lose more than our actual recovery. Let’s say you pay me $30,000 in severance, after which I sue you in breach of my agreement and win $1 million. You can offset my $1 million judgment with the $30,000 you paid me under the Agreement. That seems reasonable. But let’s say I win only $15,000 because the jury decides I’m greedy. You can get back $15,000, reducing my recovery to zero, but that’s all you get. It doesn’t matter that you paid me $30,000 not to sue you or that you may have paid your attorneys substantially more than that to defend you in my lawsuit.
This "offset" provision of the regulations ostensibly applies only where the plaintiff proves that (1) there is an "invalid" waiver, and (2) there was age discrimination. The regs don’t address what happens when the plaintiff’s lawsuit gets tossed out of court for being in breach of the agreement. One would like to think the employer-defendant would then be able to get full recovery, including costs and attorneys’ fees as well as all amounts paid under the agreement, in this circumstance.
But don’t bet the rent that this is the EEOC’s position. In the commentary to the regulations, the EEOC says that anybody ought to be able to test the validity of an ADEA waiver in the courts without penalty. "Anybody" would presumably include the thousands of people who, with their eyes wide open and knowing the full implications of their decisions, signed agreements with ADEA waivers.
So, do we remove the teeth from all our releases? That is certainly one option. It is possible to draft your agreements so that a suit filed in breach of any other portion of your release—but not ADEA—still subjects the employee to damages and attorneys’ fees.
The problem with this option is that, if you remove your penalties for lawsuits filed in breach of ADEA waivers, and then a court later invalidates the waiver regulations, then you have no protection from ADEA suits as a matter of simple contract law.
Another option, at least until some courts have had a chance to rule on the regs, would be to handle ADEA waivers on a case-by-case basis. Does the employee have an attorney, thus making it more likely that a court would find the waiver to be knowing and voluntary? How realistic is the possibility that the employee would assert an ADEA claim? How likely is such a claim to be viable?
An idea that falls into the "so crazy it just might work" category would be to take advantage of the recent Supreme Court decision in Circuit City v. Adams. In that decision, the Court held that unilateral arbitration agreements are enforceable in the employment context. Could we soften the impact of the EEOC’s waiver regulations by providing for mandatory arbitration of disputes relating to the validity of the age waiver or any age discrimination claims? Hmmm...
There are no easy decisions, and the call has to be yours. Here’s hoping that somebody—either the courts, or maybe even Congress—will take issue with the EEOC’s unreasonable position.
Robin Shea (DOB 8/12/55) practices in the areas of employment litigation prevention and defense, training, affirmative action and OFCCP.
From the Editor’s Desk: Is Genetic Testing Really So Bad?
The EEOC, Senator Tom Daschle (D-S.D.), and their anti-scientific brethren and sistren are in a tizzy over the use of DNA testing by Burlington Northern Santa Fe Railroad. The railroad was testing employees with workers’ compensation claims of carpal tunnel syndrome to determine whether the carpal tunnel was a result of a chromosomal abnormality.
"[A] person who been has forced to give blood can never be made whole, and genetic information that is revealed can never be concealed," the EEOC argued. Daschle, for his part, has introduced the Protecting Civil Rights for All Americans Act (with a title like that, how can he lose?), which would prohibit discrimination based on predictive genetic information.
Apparently intimidated by the outcry, the railroad has backed down and discontinued the tests.
But was the railroad really so naughty?
Had it chosen to fight, the railroad probably would have had a strong argument that the testing did not violate the ADA, as the EEOC alleged. The testing was for an illness that is reputed to be occupational in nature. The testees had already made workers’ compensation claims for carpal tunnel.
The testing would have been much more troubling had it been for propensity to develop certain medical conditions that are not clearly job-related, such as cancer, heart disease, or Alzheimer’s.
But what is so wrong with testing people for their genetic potential to suffer from certain occupational diseases or injuries, and guiding them to jobs that are less hazardous to their biological makeup? Even further, what’s wrong with an employer’s defending itself in a workers’ compensation case by proving that the alleged "workplace injury" was actually inherent in the employee’s biology?
Certainly, genetic testing has the potential for abuse, as do physical and psychological examinations, drug tests, and every other point at which the worlds of medicine and the workplace intersect. But an automatic reaction against all genetic testing is unrealistic, and counterproductive to the development of the intelligent, humane guidelines that we really need.
Robin E. Shea, Editor
"Spring Clean" Your HR Department With An Audit
Arlene Acord, Tampa Office
Every year, the more-organized among us participate in the ritual of spring cleaning. Spring cleaning rids our homes of dirt, dinginess, and cobwebs, as well as useless junk, that accumulate throughout the year. Just like a home, HR departments can also grow dingy and junky if they’re not "cleaned out" regularly. Spring cleaning, in the form of an employment practices audit, can rid you of out-of-date policies and practices that no longer support current business needs, or are not in compliance with the new laws or the latest interpretations thereof. It can also inspire you to update existing policies, or begin developing new initiatives. Any way you look at it, it’s a great idea.
As with a big housekeeping project, the prospect of reviewing employment policies, procedures, and forms with painstaking care can be overwhelming for HR professionals. The following is a small agenda that is designed to help you get moving in the right direction.
Recruiting. Watch the language of your advertisements. An age discrimination claim can zap the energy right out of a "young and energetic" office. Do you identify yourself as an equal opportunity employer? Are you enforcing your reference checking policy? Are your employee testing programs lawful? Do you have a transfer and promotion policy? Consider using structured interviews (standardized interview questions developed for each job) to help avoid allegations of discrimination in hiring and promotions. Are your I-9s complete, accurate, and legal? Do you have valid work authorizations for your employees who are minors?
Job Descriptions. Jobs change: a job may evolve as an employee grows with the company; maybe what once was one job has turned into two, or vice versa; or perhaps your organization went through a merger, acquisition, or restructuring. Whatever the reason, be sure your job descriptions are accurate. If they’re not, and you don’t have the resources to update them, then you are better off without them.
Office Postings. Do all of your locations comply with federal and state posting requirements? Checking for compliance at least once a year is always a good idea. Consider investing in a locked glass case for your postings if you haven't done so already. There is always an employee looking for something of yours to draw a mustache on.
Records Retention. Do your branch office locations keep personnel-related records? Do you have a policy regarding what records cannot be retained at branch office locations? Conduct periodic audits of branch office files if you don't already. Do you separate personnel records from medical records? Retention requirements vary by record, but consider disposing of records that you are no longer required to keep.
Safety compliance. Do you have a policy regarding violence in the workplace? Verify that you are in compliance with specific OSHA programs: hazard communication, hearing conservation, lockout/tagout, confined space, respiratory protection, emergency evacuation and fire protection plans, bloodborne pathogens, ergonomics, forklifts, contractor procedures, personal protective equipment, and safety and health record-keeping requirements.
Employee Manual & Unlawful Harassment Policies. You’ve heard it before, you’ll hear it again: an employee manual is a valuable organizational resource—if it accurately describes employment with your organization, and if it fully complies with current employment laws. Do you train your managers and supervisors regarding the administration of your policies? Do you have a harassment policy? Have you established internal grievance procedures? Do you investigate all complaints of harassment? Do you have an anti-retaliation policy?
Benefits and Benefit Eligibility. Do your programs comply with ERISA? Do you employ long-term "temporary" employees who are "ineligible" for benefits?
Affirmative Action. If your company is a federal contractor (do you know whether your company is a federal contractor?), do you have a current and at least one prior year affirmative action plan? Do you carefully track job applicants on a log that is maintained in Excel format? Do you keep accurate records of hires, terminations, promotions, and transfers, also in Excel?
Compensation Policy. Do you audit for pay disparities among employees with similar jobs and length of service, and similar education, experience, knowledge, skills and abilities? Do you regularly audit to make sure your "exempts" really are exempt and that your non-exempts are properly recording all hours worked?
Attendance Policy. Are your leave policies in compliance with federal and state laws? Do you have a policy regarding job abandonment? Do you have a Family and Medical Leave Act policy that complies with the regulations?
Performance and Discipline. Do you have a progressive discipline program? Does it give you sufficient flexibility in making termination decisions? Are supervisors trained on conducting performance evaluations? Does more than one member of management review performance evaluations before they are presented to employees?
Voluntary and Involuntary Terminations. Do you carefully assess the risks before firing an employee? Are supervisors and managers required to get HR approval before terminating employees? Do you conduct exit interviews with employees who voluntarily resign? (Consider mailing follow-up exit interview questionnaires shortly after employees resign. If an employee had problems with the supervisor who is conducting the exit interview, this might be the way to find out what those problems were and whether they are a cause for concern.) What criteria are used to determine layoffs and recalls? Do you provide timely notification of COBRA rights?
Constangy attorneys are available if you need help in determining whether your policies or procedures comply with applicable law, or if you need help resolving any problems you find.
Arlene Acord practices in the areas of litigation prevention and defense.
Getting To Know Us
LEE BOEKE (Atlanta Office, employment liability prevention and union-related matters) is Chairman of Constangy, Brooks & Smith, and has been practicing law since 1974. He received both his bachelor’s and law degrees from the University of Iowa. Before entering the private practice of law, Lee was a special agent with the Federal Bureau of Investigation, where he spent some time working with J. Edgar Hoover. He also worked on special matters with the U.S. Department of Justice and served as a staff attorney for the National Labor Relations Board. When he is not practicing law, Lee enjoys reading history and novels, and playing golf. Lee and his wife, Phyllis, have two daughters, Mary and Anne.
WILLIAM "ZAN" BLUE (Nashville Office, employment litigation prevention and defense, compliance audits, traditional labor) is head of Constangy’s Nashville Office. He received his undergraduate degree in philosophy from Bradley University and his law degree from Vanderbilt University, where he was a Founders’ Medallist and a member of the Order of the Coif. Zan has humble origins, having worked as a housepainter before beginning his legal career. Presently he is the chair of the CLE Committee of the Nashville Bar Association; co-chair of the Ethics and Professionalism CLE Committee; Barrister of the Henry B. Phillips Inn of Court; and on the Board of Directors of the Nashville Bar Association Member Services. Zan’s articles have appeared in several legal publications. His hobbies include cooking, winemaking, deer hunting, tree farming, and reading. Zan has two teenagers, and he and his wife, Francie, divide their time between Nashville and their farm.
DAVID WARE (Atlanta Office, employment litigation prevention and defense) received his undergraduate degree from West Georgia College and his law degree from the University of Georgia. David also represents professional athletes, including Heisman Trophy winner Barry Sanders. He has been President of the Gate City Bar Association and has been featured in Jet, Ebony, Black Enterprise, Sports Illustrated, USA Today, and The Wall Street Journal, and also on ESPN, HBO-Real Sports and Prime-Time Live. David is also an ordained minister. He and his wife, Sharon, also an attorney, have three children.
KIM SETEN (Kansas City Office, traditional labor) has a bachelor’s degree in psychology from the University of Illinois and a law degree cum laude from the University of Miami. Kim is the author of the three-part series on health care organizing that appeared in prior editions of this newsletter. Kim is an expert farm tractor driver, having learned at the tender age of five. She also enjoys wine tasting, reading, and traveling with her husband, Matt.
ANGELIQUE GROZA LYONS (Tampa Office, employment litigation prevention and defense, and OFCCP) has both her undergraduate and law degrees (with high honors) from the University of Florida. Angelique majored in Exercise and Sports Sciences and used to teach physical education to students with emotional and behavioral problems. Angelique’s hobbies include running, kickboxing, reading, and golf. She also manages to find a little time to spend with her husband, Jeff.
"E-sign" Is Deliberately Vague
Some were breathless with excitement when the Electronic Signatures in Global and National Commerce Act (also known as the "E-Sign Act") became law last June. The Act gives electronic contracts, signatures and records the same legal status as their pen-and-paper ancestors. Many hoped that the law would give some definitive guidance in enforcing electronic contracts.
However, the Act is a conserva-tively drafted statute that leaves most of the important decisions regarding e-signatures in the hands of the "market," not Congress.
Not that there’s anything wrong with that, given the constantly changing nature of the technology. A more specific statute would probably become obsolete before you could say "mag-card typewriter."
The Act ambiguously defines an electronic signature as an "electronic sound, symbol, or process, attached to or logically associated with a contract or other record and executed or adopted by a person with the intent to sign the record." The technology- neutral definition illustrates Congress’s intent to let the market shape the future of the Act.
Although the Act’s vagueness makes a lot of sense, it leaves many questions unanswered. How do you authenticate e-signatures? How do you ensure the integrity of an e-contract? Who is liable in the event of an e-contract dispute?
The market and the courts will no doubt resolve these and many more questions in the years to come.
A. Robert Bell, Winston-Salem Office
Reason Prevails... And Reason Flails...
Sweeney says it’s bad; ergo, it’s good. In a huge victory for truth, justice, and the American way, Congress and Dubya undo the vile OSHA ergonomics rule promulgated in Clinton’s eleventh hour. Among other things, the rule would have required companies to redesign workplaces and give employees 90 days’ paid leave (notwithstanding the FMLA and workers’ compensation laws) whenever an injury was deemed to be caused by the workplace. The AFL-CIO’s John Sweeney said that "‘dishonest’ and ‘disgraceful’" weren’t strong enough words to describe the congressional action.
You’d be crabby, too, if you were him. The Seventh Circuit held that decreased sexual performance secondary to a bad back is not a "substantial limitation of a major life activity" within the meaning of the ADA. The plaintiff was terminated after he allegedly called his supervisor a "motherf---er" in Spanish.
Ninth Circuit gets one right. (The decision to insert the word "finally" is completely up to you, Dear Reader.) The Ninth Circuit (California, Nevada, Idaho, Montana, Arizona, Alaska, Hawaii, Oregon, Washington, Guam) is not normally one of our favorites because of its employer-unfriendly stances. However, a panel of the court recently held that an employer acted appropriately by counseling an employee about alleged sexual harassment, instructing him to stay away from the alleged victim, and transferring him to another shift, even though no formal discipline was administered.
Give her some exposure to the court system, and she’ll think a one-hour delay sounds pretty darned quick. A federal district court found that a clothing store did not violate the ADA or California law by taking one hour to consider the accommodation request of a blind woman who wanted her husband to assist her in the women’s dressing room. (The woman was granted the requested accommodation after the understandably confused store employees consulted with their Human Resources representative.)
Plaintiffs from Mars . . . and Venus. Ford Motor Company instituted a program of grading employees "on a curve" as part of their performance evaluations. Nine employees have sued, contending that the evaluation system discriminates on the basis of age. "This is a whole new system," the plaintiffs’ lawyer sputtered. The nerve!
Love the cheesesteak and mummers, but, oh, those Keystone Kourts! The federal court for the the Eastern District of Pennsylvania refused to dismiss an ADA suit on summary judgment, even though there was evidence showing that the plaintiff was belligerent, unprofessional, and sensitive to criticism. In fact, the court cited the plaintiff’s bad personality in finding that she may have been "substantially limited in the major life activity of interacting with others." The same district also refused to throw out a retaliatory discharge lawsuit filed by a plaintiff who had allegedly threatened to shoot a co-worker and her plant manager.
California opens floodgates . . . even more. California amends its Fair Employment and Housing Act to make up for the Supreme Court’s having put some limits on who is entitled to ADA protection. Under the new law, employers will have to accommodate employees who do not have "substantial limitations" and without regard to mitigating measures. Employment attorneys predict that employers will lose 80 to 90 percent of their disability discrimination cases because of the change in the law.
Stress’t practices. Guess the ending to this story: An employer in New Jersey allegedly bet an obese employee $250 a pound if he could lose 100 pounds in 14 months, and then the employee failed to lose the weight. Then the employer needed to fire the obese employee... (See answer below.)
ANSWER: Court finds that obese employee’s discrimination suit can go to trial, citing bet as evidence of anti-fat animus.
Quarterly Quiz
XYZ Corporation has a job opening, and two women apply: Sicklea, who has numerous chronic and substantially limiting medical conditions, and Robusta, who is healthy as the proverbial ox. On the application form, which is filled out before a conditional offer of employment is made, XYZ asks both women whether they have ever had any absences from their previous jobs due to illness.
XYZ hires Robusta and rejects Sicklea (on the ground that she is too sickly).
Who has a viable ADA claim against XYZ? Sicklea, Robusta, both, or neither?
Quarterly Quiz Answer:
Both. Sicklea is much more likely to file a charge since she did not get the job, and for an obviously discriminatory reason, but both women have valid ADA claims. The EEOC takes the position that any medical inquiry during the pre-employment stage (before a conditional offer of employment is made) is a per se violation of the ADA. Therefore, the fact that Robusta got the job would have an impact on her damages, but not on XYZ’s liability.
(The EEOC says that the question on the application form would have been legal if it had merely asked for the number of days missed from their previous jobs – without the "due to illness" part.)
Kudos
John Dickinson (Jacksonville) was named "One of Jacksonville’s Best Lawyers" by Jacksonville Magazine...
Dana Thrasher (Birmingham) has been elected to serve as the Alabama representative on the Gulf Coast Employee Plans/Exempt Organizations Council. The Council works with IRS representatives to facilitate the exchange of information between the public and the IRS regarding benefit plan issues...
Mel Haas (Macon) has been appointed chairperson of the Employment Law Committee of the Georgia Defense Lawyers Association ...
Congratulations to John, Dana, and Mel!
And a very special congratulations to Constangy’s newest members: Tom Davis (Birmingham), Tammy Dobbs (Birmingham), Craig Moore (Nashville), Tim Newton (Atlanta), Charles Powell (Birmingham), Chuck Roberts (Winston-Salem), David Smith (Atlanta), and Tim Williams (Atlanta).
Check Us Out
Constangy attorneys have recently been published in the following "out-of-house" publications:
Pat Tyson (Atlanta), "Early Returns Will Tell Much About OSHA Under President Bush," Safety and Health Magazine (February 2001).
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