Bank of Amicus Briefs and Legal Documents
This page houses amicus briefs and is meant to be used as a guide for insight into state preemption topics. View all briefs.
Zdanko v. American Airlines: Amicus Brief by A Better Balance in Support of Zdanko
This amicus brief was submitted by A Better Balance in support of an American Airlines employee who was denied paid sick leave, arguing that Arizona’s Earned Paid Sick Time Act covered the employee even though he was also covered by a Collective Bargaining Agreement.
San Antonio v. Assoc. Builders and Contractors: Amicus Brief by A Better Balance
Amicus brief submitted by A Better Balance in support of San Antonio’s paid sick leave law, arguing that the ordinance should not be preliminarily enjoined.
San Antonio v. Assoc. Builders and Contractors: Amicus Brief by Local Government Law Professors
Amicus brief submitted by state and national local government law professors in support of San Antonio’s paid sick leave law, arguing that the city has authority to enact the law and that such authority has not been preempted.
Texas Ass’n of Business v. City of Austin: Amicus Brief by A Better Balance
Amicus brief by A Better Balance before the Texas 3rd Court of Appeals in support of Austin’s Earned Sick Time Ordinance, arguing that, because paid sick leave laws like Austin’s do not harm businesses and provide significant benefits to workers, the court should not temporarily enjoin the ordinance while it is being challenged.
Texas Ass’n of Business v. City of Austin: Amicus Brief by Workers Defense Project et al.
Amicus brief by the Workers Defense Project, Austin workers, businesses, and advocacy organizations arguing that Austin’s Earned Sick Time Ordinance should not be temporarily enjoined because the plaintiffs challenging the ordinance have failed to demonstrate (1) that the ordinance is unduly burdensome to businesses in relation to the underlying government interest of protecting the health and safety of Austin residents, (2) that there was no rational reason to allow employers operating under a collective bargaining agreement to modify the cap of required paid sick leave, and (3) that the records-keeping requirement under the ordinance would subject businesses to unreasonable searches and seizures.
Pa. Rest. and Lodging Ass’n v. Pittsburgh: Amicus Brief by Women’s Health and Safety Organizations
Amicus brief submitted to the Pennsylvania Supreme Court by fifty-one organizations committed to women’s health and safety in support of Pittsburgh. The brief explains the importance of paid sick leave to protect public health, notes that a lack of paid sick leave disproportionately harms women and people of color, and argues that Pittsburgh has the authority to enact the Paid Sick Days Act.
Pa. Rest. and Lodging Ass’n v. Pittsburgh: Amicus Brief by A Better Balance et al.
Amicus brief submitted to the Pennsylvania Supreme Court by A Better Balance and leading law school professor experts in local government law and/or labor law in support of Pittsburgh. The brief outlines the history and importance of home rule in Pennsylvania, argues that Pittsburgh has the authority to pass the Paid Sick Days Act, and notes that striking down the ordinance would undermine home rule in Pennsylvania, severely limiting the ability of municipalities to protect public health and safety.