Worker Adjustment and Retraining Act (WARN Act)

"[T]he Worker Adjustment and Retraining Notification Act of 1988, 29 U.S.C. § 2101, et seq. (1988) ('WARN'), requires employers either to give sixty days notice of site closings or to compensate laid-off employees for sixty days salary and benefits."

"Although we conclude that [the defendant] was a WARN employer, [the workers' union] is not entitled to the relief it seeks.  As noted, WARN § 2104(a) provides a damages action for back pay and for 'the cost of medical expenses incurred during the employment loss.'  Section 2104(b) states, however, that 'the remedies provided for in this section shall be the exclusive remedies for any violation of this chapter.'  The relief appellants seek, a preliminary injunction compelling [the defendant] to provide fifty-seven days of insurance coverage under WARN, is, therefore, not one of the remedies specified in WARN and was properly denied."

"[Former employees] are not, therefore, entitled to injunctive relief.  At best, they showed that, under WARN, medical coverage should have been provided for the sixty days after the closing of the hotel.  WARN provides only a damages remedy for a breach of that obligation."