Protecting Employers Since 1985

DOL Issues Six New Opinion Letters

By Alan E. Seneczko / August 30, 2018

On August 28, 2018, the Department of Labor, Wage and Hour Division, issued six new opinion letters on issues under the Fair Labor Standards Act and Family Medical Leave Act. They are summarized below: “No-fault” attendance policies and roll-off of attendance points under the FMLA – attendance policy that “freezes” attendance points accrued prior to…

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Absenteeism And Proof Of “Misconduct”

By Alan E. Seneczko / August 2, 2018

The Wisconsin Unemployment Compensation Act defines “misconduct” to include “absenteeism on more than 2 occasions within the 120-day period before the date of the employee’s termination, unless otherwise specified by [the] employer in an employment manual [which the employee has acknowledged receiving].” Wis. Stat. § 108.04(5)(e). What if the employer’s attendance policy defines excessive absenteeism,…

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Intent To Discriminate No Longer Inferred From Conduct Caused By Disability

By Alan E. Seneczko / August 1, 2018

Over the last several years, the Wisconsin Labor and Industry Review Commission (“LIRC”) has developed a maddening interpretation of the Wisconsin Fair Employment Act as it relates to disability discrimination; that is, if the conduct that prompted an employee’s discipline was caused by a disability, then taking action based on that conduct is an act…

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DOL Rolls Out Voluntary Self-Audit Program (PAID)

By Alan E. Seneczko / April 9, 2018

On April 3, 2018 the Department of Labor implemented a new pilot program, in effect for the next six months, under which employers may correct inadvertent minimum wage and overtime violations without the imposition of penalties or liquidated damages (employers must still pay 100% of any back wages owed). Under the new program – Payroll…

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Expunged Conviction Not A “Conviction” Under WFEA

By Alan E. Seneczko / March 20, 2018

HR professionals that conduct criminal background checks on prospective employees are well aware of (or should be) the Wisconsin Fair Employment Act’s prohibition against discrimination on the basis of an individual’s arrest or conviction record. Under the WFEA, an employer may not discriminate against an employee or prospective employee on the basis of a pending…

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Temporary Employees May Sue Host Employers for Injuries

By Alan E. Seneczko / March 19, 2018

In a stunning recent decision, the Wisconsin Court of Appeals held that temporary employees who are injured/killed while performing services for their host employer have the right to choose between the receipt of workers’ compensation benefits under the Wisconsin Worker’s Compensation Act or the pursuit of a personal injury claim against the host employer. Under…

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Non-Compete Statute Applies To No-Raiding Provisions

By Alan E. Seneczko / March 15, 2018

The enforcement of non-compete agreements in Wisconsin is governed by the provisions of Wis. Stat. § 103.466, which sets forth five requirements that must be met in order for the restriction to be enforceable. Over the years, the courts have found that these restrictions applied not just to traditional non-compete agreements, but also to agreements…

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Lessons Learned: Effective Documentation

By Alan E. Seneczko / January 15, 2018

“The importance of documentation” is an axiomatic, and almost trite, battle cry that human resource professionals constantly beat into the psyches of their supervisors – quite often to no avail. But what, really, is “documentation?” When do you do it? How do you do it? And, what, exactly, are you supposed to document? More importantly,…

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Electronic Timekeeping – A Hidden Source of Liability

By Alan E. Seneczko / November 9, 2017

Your company utilizes electronic timekeeping software, whether purchased for internal use or provided by a third party payroll service. The system is operating, so it must be doing so legally, right? Not necessarily. On several recent occasions I discovered, much to the dismay of my clients, that the timekeeping system they have been utilizing for…

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Extended Medical Leaves and the ADA: Court Provides Much-Needed, Long-Awaited Clarity

By Alan E. Seneczko / October 12, 2017

“The ADA is an antidiscrimination statute, not a medical-leave entitlement.” These are the words employers have been waiting more than 25 years to hear, since the date the ADA first became effective, and even more so after the passage of the Family Medical Leave Act in 1993. They address an issue that has vexed employers…

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