Case Comparison
Case 1
Case Name
James Pittman V. Cook Paper Recycling Corp
The name of the court deciding the case
Missouri Court of Appeals, Western District
Case Citation
478 S.W.3d 479 (2015)
Key Facts
James Pittman made a petition against his employer Cook Paper Recycling Corporation with the allegations of hostility and abuse in the work place based on his sexual orientation. However, Pittman failed to state a claim leading to a dismissal of the case by the court. Pittman further contended that the dismissal was unwarranted since he had made a claim for sexual discrimination at his place of work that eventually led to the termination of his employment. According to the Missouri Human Rights Act, discrimination on the basis of an individual’s sexuality is not prohibited hence, the decision to dismiss the petition made by Pittman was affirmed for failure to allege state required course of action.
Pittman who is a male homosexual worked at Cook Paper as a controller from 2004. However, he was dismissed in December 2011. Pittman also claimed that in the period he worked in the company, the president of Cook Paper; Joe T. Jurden made discriminatory comments against him and even asked him whether he had AIDS. Pittman also added that the company discriminated against him because they were against his relationship. When Pittman and his partner terminated the relationship, the workplace became more hostile and he was constantly abused based on his sexual orientation. Cook Paper eventually terminated Pittman’s employment on 7th December 2011.
Issue
Following Pittman’s petition, Cook Paper submitted an appeal to dismiss the petition on the grounds that no claim was stated by Pittman. Using the Missouri Human Rights Act as a basis for the argument, Cook Paper stated that the Law of Missouri does not prohibit employment discrimination on the basis of sexual preference. The court dismissed the claim made citing that the Missouri Human Rights Act as does not list mistreatment as a result of one’s sexuality as a form of discrimination. Pittman made an appeal asserting that he made a claim for sexual bias in his petition. He further contended that his sexual orientation led to his dismissal and harassment at the work place.
Rule
The court noted that the petition does not make an allegation of discrimination on the basis of “sex” and that Pittman only made an allegation of hostility and abuse in the work place due to his sexual orientation. The court further acknowledged the categories considered as discrimination by the Missouri Human Rights Act noting that sexual bias is not among the categories. The courts further argued that unless the statute is amended, sexual discrimination cannot be considered due to the provisions of the act.
Decision
The court’s decision to dismiss Pittman’s claim was affirmed for failure to state a claim.
Reasoning
The court dismissed the petition made because of Pittman’s failing to state a claim based on the provisions of the Missouri Human Rights Act does not outline discrimination based on an individual’s sexuality.
Case 2
Case Name
King Et al. V. Burwell, Secretary Of Health And Human Services, Et al
The name of the court deciding the case
Supreme Court of the United States
Case Citation
576 U.S. 988 (2015)
Key Facts
One of the reforms implemented by the Affordable Care Act (ACA) provides Exchanges which allow people to compare and make purchases that suit their insurance needs. The reforms in the act also gives authority to both the rich and the poor to make purchases of insurances through the Exchanges. The regulations provided by the Internal Revenue Service (IRS) also grants access to all Americans regardless of whether they purchase insurance on state or federal Exchange.
Four individuals living in Virginia filed a lawsuit arguing that the ACA only gives tax credits to people who purchase insurance on the standard Exchanges. Virginia has Federal Exchange which, according to the petitioners, does not meet the requirements of a state established Exchange, hence they should not receive tax credits. In so doing, the cost of insurance will be a higher percentage of their income which would limit them from the requirements for coverage established by the Act. The IRS however, made a ruling in which the individuals would receive tax credits. The petitioners opposed the ruling in Federal District Court. The petition was rejected by the court arguing that the Act unambiguously issued tax credits to individuals enrolled by Federal Exchange. The plaintiffs in King appealed the decision for the Fourth Circuit which agreed that the Act was equivocal.
Issue
The suit was dismissed based on the unambiguous tax credits made available to people who were enrolled through the Federal Exchange program. Given the ambiguity of the text, the court must further analyze the Act to find the correct interpretation of Section 36B.
Rule
The court held that section 36b’s tax credits are accessible to individuals who reside in states that have Federal Exchange programs.
Decision
The court affirmed the decision.
Reasoning
Despite the ambiguity of the phrase “an Exchange established by the State under [42 U. S. C. §18031]” it might be limited to the Exchanges of the State. On the other hand, it can be used to refer to both the Exchanges of State and those of the Federal.
Case 1 and 2
James Pittman V. Cook Paper Recycling Corp is relevant to the business environment as it provides a guideline of the issues surrounding the rights of the employees in regards to the existing acts. In the case of Pittman, the Missouri Human Rights Act does not provide specifications based on discrimination on the basis of sexual orientation. Therefore, the analysis of this case creates an understanding of the employee treatment at the workplace. The absence of specific guidelines on the issues presented by Pittman limited his rights as an employee and affected the access to human rights.
King Et al. V. Burwell, Secretary Of Health And Human Services, Et al is relevant to the business environment as it provides an overview of the provisions of the state and the federal governments whose provisions may differ hence affecting the application of the law. The violation of language used in the Affordable Care Act by the IRS points the discrepancies in the provisions of the law which may affect how business entities operate.
Business Law students should read the cases to understand the applications of the law in the issues faced by business entities. The cases create a reality of the employee issues, they shape the public debate and they set out the expectations outlined by the state. Therefore, they enlighten the students on the approaches taken through law.
Finally, both cases are important for students of business law as they present varied perspectives on the application of the rule of the law in certain situations. In the case of Pittman, the law provides a standard approach to the issue based on the provisions of the Missouri Human Rights Act. On the other hand, King v Burwell establishes the relationship between the Federal government and the central government in regards to the laws passed.
