Justia U.S. 1st Circuit Court of Appeals Opinion Summaries

Plaintiff brought suit against his employers in the District of Puerto Rico, alleging, inter alia, violations of the Age Discrimination in Employment Act. The employers moved to dismiss the complaint, asserting that a forum selection clause in Plaintiff’s separation agreement provided exclusive jurisdiction in the Court of First Instance, San Juan Division. Plaintiff argued that the forum selection clause was invalid because he did not affirmatively waive his Seventh Amendment Right to a jury trial. The district court concluded that the forum selection clause was valid but entered a declaratory judgment stating that the Commonwealth of Puerto Rico must afford civil litigants the Seventh Amendment right to a jury trial. The First Circuit vacated the portion of the district court’s judgment declaring that the Commonwealth must afford civil litigants a jury trial, holding that this action was in contravention of binding Supreme Court precedent. Remanded. View "Gonzalez-Oyarzun v. Commonwealth of P.R." on Justia Law

Plaintiff worked for the Town of Camden for thirty-one years prior to being laid off. The collective bargaining agreement (CBA) between the police union and the Town provided for recall of qualified employees based on seniority. During the twelve-month period after Plaintiff was laid off, vacancies opened in the Camden Police Department, but the Town did not recall Plaintiff. Plaintiff and his wife brought this action under 42 U.S.C. 1983 alleging that the Town had deprived Plaintiff, without due process of law, of his property interest in his right to be recalled. The district court dismissed Plaintiff’s complaint for failure to state a claim. The First Circuit vacated the dismissal and remanded. On remand, the district court entered judgment for the Town, concluding that the CBA contained a condition precedent requiring Plaintiff to submit his address and phone number to the Town after his layoff in order to assert his recall rights and that Plaintiff did not submit such information post-layoff. The First Circuit vacated the judgment and remanded, holding that the CBA recall provision did not unambiguously create a condition precedent, and therefore, further fact-finding was necessary. View "Clukey v. Town of Camden, Maine" on Justia Law

Hector Luis Roman-Oliveras (Roman) was dismissed from his job after working for the Puerto Rico Electric Power Authority (PREPA) for over twenty years. Roman, along with his wife and mother, brought suit against PREPA and two individual supervisors, alleging that Defendants unlawfully targeted Roman due to his medical disability and his union activities. In 2012, the parties held settlement negotiations, which took place in the district judge’s chambers. The judge memorialized an account of the discussions in a minute entry recounting that the parties had reached a binding oral settlement agreement. The parties, however, did not submit a final written agreement. Another district judge later dismissed the case with prejudice on the basis of the settlement agreement. Plaintiffs appealed, arguing that “an agreement had never been reached,” and, assuming such a settlement had been reached, the district court lacked subject matter jurisdiction to enforce it. The First Circuit affirmed, holding that the district court did not err in finding that the talks conducted in 2012 produced a binding oral settlement agreement that the district court had jurisdiction to enforce. View "Roman-Oliveras v. P.R. Elec. Power Auth." on Justia Law

Plaintiffs were employees of Puerto Rico National Processing Service Center (PR-NPSC), which is now closed, run by the Federal Emergency Management Agency (FEMA). Plaintiffs filed this lawsuit alleging that FEMA’s actions in implementing a rotational staffing plan at the PR-NPSC, which reduced the number of work days for each employee, and in eventually closing the facility discriminated against them on the basis of national origin and retaliation in violation of Title VII. The district court granted summary judgment to Defendants. The First Circuit affirmed, holding (1) Plaintiffs’ disparate impact claims failed because (i) Plaintiffs expressly disavowed any claim of intentional discrimination, and under relevant caselaw, claims of different treatment based on location absent a claim of intentional discrimination do not establish liability under 42 U.S.C. 2000e-2(h), and (ii) the challenged actions were job-related and consistent with business necessity, and Plaintiffs failed to show that there were alternatives available to FEMA that would have had less disparate impact and served FEMA’s legitimate needs; and (2) both retaliation claims failed because Plaintiffs did not show that the allegedly adverse employment actions were causally related to any protected conduct. View "Abril-Rivera v. Johnson" on Justia Law

Plaintiff Sonia Velez-Velez, a Popular Democratic Party (PDP) member, lost her job with the Puerto Rico Highway and Transportation Authority after an election returned the opposing political party, the New Progressive Party (NPP), to office. Plaintiff was informed on February 11, 2010 that she would be terminated under the new NPP administration’s ruling that one set of hiring policies under which Plaintiff was hired was unlawful and therefore, those employees hired under the erroneous determinations must be terminated. Plaintiff requested a hearing, and on November 8, 2010 the Examining Officer recommended affirming the decision to terminate Plaintiff’s employment. On December 20, 2011, Plaintiff and her husband filed this complaint, alleging claims for political discrimination, among other claims. The district court granted summary judgment for Defendants, concluding that the discrimination claim was time-barred. Plaintiff appealed, claiming that the clock did not begin to run until she was formally terminated after the hearing. The First Circuit affirmed, holding that the statute of limitations began to run when Plaintiff was informed on February 11, 2010 of the re-interpretation of policy. View "Velez-Velez v. P.R. Highway & Transp. Auth." on Justia Law

Plaintiffs held licenses from the Puerto Rico Treasury Department (Treasury) authorizing them to own and operate “adult entertainment machines” (AEMs). Special Treasury task-force agents later seized AEMs belonging to Plaintiffs. Plaintiffs sued Defendants, the parties supposedly responsible for damages, in a federal district court under 42 U.S.C. 1983, alleging that the inspections and confiscations of the AEMs violated their constitutional rights. Plaintiffs also asserted supplemental local-law claims mirroring their federal-law claims. The court granted Defendants summary judgment on the federal law claims and relinquished jurisdiction over the local-law claims. The First Circuit (1) vacated the summary judgment on the search-and-seizure and local-law claims, holding that the case must be remanded so the district court can address timing and scope matters in the qualified-immunity context; and (2) affirmed in all other respects. View "Rivera-Corraliza v. Puig-Morales" on Justia Law

In Sprint Commc’ns, Inc. v. Jacobs, the Supreme Court revisited the doctrine of abstention enunciated in Younger v. Harris. That doctrine requires federal courts, in the absence of extraordinary circumstances, to refrain from interfering with certain state proceedings. In this case, David Knight, an employee of Sirva Relocation, LLC, filed a charge of discrimination with the Massachusetts Commission Against Discrimination (MCAD) alleging that Sirva and Aetna Life Insurance Company (together, Appellants) had discriminated against him on the basis of disability in violation of Mass. Gen. Laws ch. 151B and the Americans with Disabilities Act (ADA). Appellants filed a federal complaint against the Commonwealth of Massachusetts, the MCAD, its commissioners, and Knight, asking the court to enjoin the MCAD proceeding on the basis that ERISA preempted the chapter 151B claim. The MCAD and Knight moved to dismiss the complaint, entreating the district court to abstain. While the case was pending, the Supreme Court decided Sprint. The district court dismissed the federal court action, concluding that Younger abstention was appropriate in this case. The First Circuit affirmed the district court’s decision to abstain and further clarified its own case law concerning the exception to the Younger doctrine for facially conclusive claims of preemption. View "Sirva Relocation, LLC v. Golar Richie" on Justia Law

Plaintiff, a naturalized United States citizen, alleged that, in 2009, she was unlawfully detained in violation of her Fourth And Fifth Amendment rights when she was imprisoned for 24 hours pursuant to an immigration detainer so that U.S. Immigration and Customs Enforcement (ICE) agents could investigate her immigration status. Plaintiff named as defendants three ICE agents - defendants Edward Donaghy, Bruce Chadbourne, and David Riccio. Defendants filed motions for summary judgment and to dismiss, all on the basis of qualified immunity. The district court denied Defendants’ motions. The First Circuit (1) affirmed the district court’s denial of qualified immunity on Plaintiff’s Fourth Amendment claim against Donaghy on the ground that the law was clearly established in 2009 that an ICE agent was required to have probable cause before issuing a detainer; (2) dismissed Donaghy’s appeal on his Fourth Amendment argument regarding the circumstances surrounding the issuance of the detainer and his Fifth Amendment equal protection argument for want of jurisdiction because these arguments did not present pure issues of law; and (3) affirmed the district court’s denial of qualified immunity on Morales’s Fourth Amendment supervisory liability claim against Chadbourne and Riccio, as Plaintiff had sufficiently alleged that Chadbourne and Riccio violated a clearly established Fourth Amendment right. View "Morales v. Chadbourne" on Justia Law

Plaintiff, a sales representative for Wyndham Vacation Resorts, Inc., brought this claim of retaliation under Title VII of the Civil Rights Act of 1964 alleging that her supervisor subjected her to a hostile work environment on the basis of race and national origin and that Wyndham retaliated against her for complaining about the supervisor’s conduct. The magistrate judge recommended that the district court grant summary judgment for Wyndham. The district court summarily affirmed the recommendation. The First Circuit affirmed, holding that Plaintiff did not present sufficient evidence to establish a retaliation claim under Title VII. View "Planadeball v. Wyndham Vacation Resorts, Inc." on Justia Law

Plaintiff was a supervisor at the Programmatic Area of the Department of Education’s Special Education Center in Bayamon when the New Progressive Party came to power in Puerto Rico. Plaintiff claimed that, as a result of his membership in the Popular Democratic Party, he was subject to impermissible political discrimination when he was reassigned to a new position, a diminution of his supervisory responsibilities, and other adverse employment actions. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding (1) Plaintiff failed to generate facts that would allow a rational jury to conclude that Plaintiff’s reassignment was an act of political discrimination or that his job responsibilities were diminished in his new position; and (2) Plaintiff’s remaining allegations of workplace discrimination were insufficient to constitute adverse employment actions. View "Santiago-Diaz v. Rivera-Rivera" on Justia Law