United Steel, Paper and Forestry, Rubber, Manufacturing, Allied Industrial and Service Workers International Union v. Magnitude 7 Metals, LLC., 1:24-cv-00089

The United Steelworkers Union sued Magnitude 7 Metals under the Worker Adjustment and Retraining Notification ("WARN") Act after over 400 employees were laid off at Magnitude 7's Missouri aluminum smelter with less than the 60-day WARN notice.
Magnitude 7’s operations relied on raw materials shipped exclusively by barge on the Mississippi River; an unprecedented freeze in January 2024 delayed critical shipments, disrupting operations.
On January 24, 2024, Magnitude 7 gave notice to employees that operations would be curbed in 3-5 days due to “abnormally cold weather” but did not specify whether the shutdown was permanent or temporary.
Both parties moved for summary judgment: the Union argued no exceptions applied and notice was inadequate; Magnitude 7 asserted that the natural disaster and unforeseeable business circumstances exceptions excused it from the 60-day notice requirement.
The court analyzed whether the natural disaster or unforeseeable business circumstances exceptions to the WARN Act applied and whether the notice met statutory and regulatory requirements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the natural disaster exception apply?	Cold weather and river freeze are not “natural disasters” under WARN and did not directly cause closure; other business reasons existed.	The Mississippi River ice event was a hydrological natural disaster, directly causing curtailed operations.	Exception does not apply; river freezing was at best an indirect cause.
Does the unforeseeable business circumstances exception apply?	Not communicated in the notice; closure decision inconsistent with timing and the plant had adequate supplies; financial issues were primary cause.	Freezing and shipping delays were unforeseeable; operational risks and barge delays required the curtailment.	Factual question remains; not resolved on summary judgment.
Was adequate notice provided under WARN?	Notice failed to specify permanent/temporary shutdown, schedule, and affected jobs; lacked necessary detail about the cause.	Substantially complied based on best info available; technical defects caused no prejudice.	Factual issue; notice may not have met statutory/regulatory detail.
Was the company’s business judgment commercially reasonable?	Magnitude 7 should have planned better for winter conditions and supplies.	Freezing and barge delays were beyond reasonable foresight or control.	Factual dispute; not resolved on summary judgment.

Pearson v. Component Tech. Corp., 247 F.3d 471 (3d Cir. 2001) (summarizes WARN Act’s purpose and scope)
Easom v. US Well Servs., Inc., 37 F.4th 238 (5th Cir. 2022) (interprets "natural disaster" scope under WARN; proximate/direct causation required)
Loehrer v. McDonnell Douglas Corp., 98 F.3d 1056 (8th Cir. 1996) (WARN statutory exceptions to advance notice)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (summary judgment standard)
Torgerson v. City of Rochester, 643 F.3d 1031 (8th Cir. 2011) (summary judgment burden)
Kalwaytis v. Preferred Meal Systems, Inc., 78 F.3d 117 (3d Cir. 1996) (substantial compliance with WARN notice requirements)
Schmelzer v. Office of Compliance, 155 F.3d 1364 (Fed. Cir. 1998) (employee’s actual knowledge relevant to WARN notice)