United Steel Workers of Am. v. U.S. Steel Corp., No. 11-3002 (8th Cir. 2012)
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United States Steel Corporation (U.S. Steel) operated an iron ore plant in Minnesota. After the economic downturn, U.S. Steel idled operations at the plant and laid off 313 workers represented by the United Workers of America Local 2660 (the Union). The Union filed a complaint for damages, alleging that U.S. Steel had violated the Worker Adjustment and Retraining Notification Act (the WARN Act) by failing to provide the required notice under the Act prior to the layoff. The district court granted summary judgment to U.S. Steel. The Eighth District Court of Appeals affirmed, holding (1) in light of the circumstances, U.S. Steel satisfied its burden of proving that the conditions giving rise to the WARN Act's unforeseeable business circumstances exception had been met; and (2) the notice given to the Union was sufficient under the WARN Act and was given as soon as practicable in this case.
Court Description: Civil case - Worker Adjustment and Retraining Notification Act. District court did not err in finding the "unforeseeable business circumstances" exception applied as the undisputed evidence demonstrated that the company's abbreviated WARN Act notice was caused by an unanticipated and dramatic major economic downturn, the impact of which was not apparent until just before the notice was given; employer gave as much notice as was practicable and the content of the notice was sufficient.
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