June 2026 Labor Law Updates for Pittsburgh, Pennsylvania
June brought several significant Pennsylvania labor law developments involving wage-and-hour claims, workplace retaliation, unemployment compensation, and workers’ compensation. This June 2026 employment update from HKM Employment Attorneys explains the rulings that Pennsylvania employees, employers, HR professionals, and compliance leaders should understand.
These June 2026 Pennsylvania labor law decisions emphasize the importance of accurate payroll practices, careful handling of leave and accommodation requests, clear workplace communications, and well-supported employment decisions. Employees and employers with questions about Pennsylvania workplace rights or a possible labor or employment claim may contact HKM Employment Attorneys for legal guidance.
Secretary of Labor v. Comprehensive Healthcare Management Services LLC — Federal Wage-and-Hour Ruling
Date: June 3, 2026
Summary:
The U.S. Court of Appeals for the Third Circuit reviewed a Department of Labor enforcement action involving nearly 6,000 employees at 15 Pennsylvania nursing, rehabilitation, and assisted-living facilities. Following a bench trial, the district court found systemic Fair Labor Standards Act violations, including inaccurate time records, payment based on scheduled rather than actual hours, automatic deductions for meal periods during which employees worked, incorrect overtime rates, and the misclassification of employees as exempt. The district court awarded approximately $35.8 million in damages.
The Third Circuit upheld most of the district court’s factual findings but ruled that the FLSA does not provide a remedy for “overtime gap time.” That term refers to unpaid straight-time hours in a week when the employee also worked overtime, assuming the missing wages did not reduce the employee’s average pay below the minimum wage. The court also sent the employee-exemption issues back to the district court for reconsideration under the proper legal standard.
Implications:
This precedential ruling narrows the compensation employees may recover under the federal FLSA within Pennsylvania and the rest of the Third Circuit. Employees may still be able to pursue unpaid straight-time wages through the Pennsylvania Minimum Wage Act, the Pennsylvania Wage Payment and Collection Law, or a contract claim. Employers should not treat the decision as permission to withhold straight-time pay, and they should continue to maintain accurate records, review automatic meal deductions, and calculate overtime using all compensation that must be included in the regular rate.
Wouch Maloney & Co. LLP v. Unemployment Compensation Board of Review — Unemployment Compensation Ruling
Date: June 10, 2026
Summary:
A firm administrator resigned from an accounting firm after concluding that she was being ignored, spoken down to, and placed in what she described as a hostile work environment. The Unemployment Compensation Board of Review awarded benefits after finding that she had experienced an intolerable workplace atmosphere.
The Commonwealth Court reversed. It concluded that the incidents established by the record did not amount to an intolerable work environment and that the claimant had not made a reasonable effort to preserve her employment. In particular, she did not give the managing partner a full explanation of her concerns or a meaningful opportunity to address them before resigning.
Implications:
Pennsylvania employees who resign because of harassment, hostility, or abusive treatment generally must show both serious working conditions and reasonable efforts to correct the problem before leaving. Reporting concerns to management or human resources and documenting the employer’s response may therefore be important to a later unemployment claim. The decision is an unreported memorandum opinion, so it is not controlling precedent, but it illustrates how courts apply Pennsylvania’s “necessitous and compelling” standard.
Jim’s Commercial Service v. DiJoseph — Workers’ Compensation Ruling
Date: June 11, 2026
Summary:
An HVAC technician sought workers’ compensation disability benefits for Dupuytren’s contracture affecting his hands and plantar fibromatosis affecting his feet. He argued that the repetitive and physically demanding activities required by his work caused or aggravated the conditions. The employer challenged the causal findings and contended that the workers’ compensation judge had relied on equivocal medical evidence.
The Commonwealth Court affirmed the award. It determined that the workers’ compensation judge’s findings were supported by substantial evidence, including credited medical testimony connecting the claimant’s work activities to the aggravation of his preexisting conditions. The court declined to reweigh the testimony or replace the compensation judge’s credibility determinations with its own.
Implications:
A condition does not have to originate at work to qualify for Pennsylvania workers’ compensation. Benefits may be available when job duties materially aggravate a preexisting medical condition and competent medical evidence establishes the connection. The ruling also underscores the substantial deference appellate courts give to a workers’ compensation judge’s credibility findings. This was an unreported memorandum decision and is primarily instructive rather than precedential.
Steidle v. United States Liability Insurance Co. — ADA and FMLA Retaliation Ruling
Date: June 24, 2026
Summary:
An insurance employee diagnosed with depression, post-traumatic stress disorder, and anxiety took approved FMLA leave for mental-health treatment. While he was on leave, his supervisor approved a smaller bonus and salary increase than he had received in previous years. The employee later requested disability accommodations and eventually lost his job after additional leave and unsuccessful efforts to return with further restrictions.
The Third Circuit held that the relatively broad “materially adverse” standard used in Title VII retaliation cases also applies to retaliation claims under the Americans with Disabilities Act and the FMLA. Applying that standard, the court found that the timing between the employee’s 2020 FMLA leave and the reduction in his compensation was sufficiently suggestive to establish an initial retaliation case. It revived the claims involving the 2020 bonus and raise but upheld dismissal of the claims involving his 2021 compensation.
Implications:
This precedential ruling is important for Pennsylvania workplace rights because retaliation is not limited to termination, demotion, or another major change in employment status. A reduced bonus or salary increase may qualify when it could discourage a reasonable employee from requesting FMLA leave or an ADA accommodation. Employers should document legitimate compensation decisions carefully, particularly when they are made during or soon after protected leave.
RSR Electric LLC v. Unemployment Compensation Board of Review — Discharge and Willful Misconduct Ruling
Date: June 1, 2026
Summary:
An electrical apprentice told his supervisor that he did not intend to continue pursuing electrical work and asked whether he could transfer back to another division of the larger company. The employer terminated him after determining that no position was available in the other division. The employer argued that the employee had voluntarily quit or had engaged in willful misconduct that disqualified him from unemployment benefits.
The Commonwealth Court’s majority upheld the award of benefits. It accepted the Board’s determination that the claimant intended to continue working and had asked about a transfer rather than unequivocally resigning. The court also held that the employer had not carried its burden of proving that the discharge resulted from willful misconduct. One judge dissented, reasoning that the employee’s statements showed that he no longer intended to perform the electrical position for which he had been hired.
Implications:
Pennsylvania employers should obtain clear confirmation before treating an employee’s statements about changing positions, declining training, or exploring a transfer as a resignation. An employee’s expression of dissatisfaction or uncertainty may not establish a voluntary quit. Because this was an unreported memorandum opinion, it is not binding precedent, but the divided decision demonstrates how heavily unemployment cases may depend on precise communications and credibility findings.
Conclusion: Looking Back on Pennsylvania’s Labor Law Updates from June 2026
With recent Pennsylvania decisions expanding protections under Title VII and the PHRA—covering discrimination, hostile work environments, non-competes, and wrongful termination—having dedicated local counsel is critical. At HKM Employment Attorneys in Pittsburgh, our Pittsburgh office—featuring attorneys Brian P. Benestad, Amy Mathieu, and Stephanie Solomon—handles workplace discrimination, harassment, retaliation, and more. Known for aggressive advocacy in both federal and state arenas, as well as responsive client care, we support clients across Southwestern PA. If these legal developments reflect what you’re experiencing at work, contact our Pittsburgh office today to see how we can help enforce your rights.
