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

Jorge L. Vaello-Carmona worked for Siemens Medical Solutions USA, Inc. from 1991 until his dismissal in 2009. In 2011, Vaello-Carmona filed a complaint against Siemens alleging disability discrimination and unlawful termination in violation of Title I of the Americans with Disabilities Act (ADA) and Puerto Rico’s general employment discrimination and employment disability discrimination statutes. Vaello-Carmona died one month after filing his complaint. Appellants subsequently moved to substitute themselves as plaintiffs in this case. The district court denied the motion and dismissed Vaello-Carmona’s complaint, concluding that Vaello-Carmona’s employment discrimination claims were not inheritable. The First Circuit vacated the judgment of the district court, holding that Vaello-Carmona’s claims were inheritable under Puerto Rico law. View "Vaello-Carmona v. Siemens Med. Solutions USA, Inc." on Justia Law

Plaintiff, a former pretrial detainee at the Somerset County Jail (SCJ), filed this action under 42 U.S.C. 1983 alleging that various correctional and administrative officers at SCJ violated his rights under the First, Fourth, Sixth, Eighth, and Fourteenth Amendments by inflicting punishment on him without due process of law and by retaliating against him for filing grievances against members of SCJ’s staff. The district (1) granted summary judgment to several defendants who did not personally support or direct the alleged violations; and (2) with respect to the remaining defendants, there were genuine issues of material fact concerning the defendants’ motives and actions precluding summary judgment. Those remaining defendants appealed. The First Circuit dismissed the appeal for lack of appellate jurisdiction, as the defendants did not take issue with the district court’s factual assessments or come forward with any purely legal issues for the Court’s consideration. View "Goguen v. Allen" on Justia Law

Appellant was associated with Appellee, Raymond James Financial Services, as a securities broker. After Appellee decided to terminate Appellant’s contract, Appellant brought an arbitration proceeding before the Financial Industry Regulatory Authority, alleging that he had been fired because of his sexual orientation and his status as a recovering alcoholic, in violation of Vermont law. After granting the parties’ request that Florida law be applied to the proceedings, an arbitration panel awarded Appellant $600,000 in back pay on his claim of discrimination based on disability. The district court vacated the award, concluding that the arbitrators lacked authority to grant the remedy because Appellant brought no claims under Florida law. The First Circuit reversed, holding that although the arbitration decision may have been incorrect as a matter of law, the arbitrators’ decision to impose liability on Appellee under Florida law did not willfully flout the governing law or otherwise exceed the bounds of the arbitrators’ authority to resolve the parties’ dispute. Remanded for entry of an order confirming the arbitration award. View "Raymond James Fin. Servs., Inc. v. Fenyk" on Justia Law

Plaintiff, a retired employee of the Department of Veterans Affairs (VA), filed a civil action in the district court pursuant to Title VII’s anti-retaliation provision, alleging several claims. The district court granted partial summary judgment in favor of the VA dismissing all but one of Plaintiff’s retaliation claims, concluding that the majority of Plaintiff’s claims were untimely and, in regards to another, Plaintiff failed to show a prima facie case of retaliation. Plaintiff then requested voluntary dismissal with prejudice of her remaining claim. The district court granted the request and dismissed the entire complaint with prejudice. The First Circuit affirmed, holding that the continuing violation doctrine did not apply to Plaintiff’s claims and, thus, her claims were time-barred. View "Ayala v. Shinseki" on Justia Law

Plaintiff was a customer service employee at a Bank. When Plaintiff could no longer endure disparate treatment due to her bisexuality she received at the Bank, she stopped reporting to work. The Bank then terminated her for job abandonment. Thereafter, Plaintiff sued the Bank for employment discrimination under the Maine Human Rights Act (MHRA) and for defamation under Maine common law. The case was removed to federal court on the basis of diversity jurisdiction. The district court granted summary judgment to the Bank. The First Circuit (1) vacated summary judgment as to the wrongful termination and hostile work environment portions of Plaintiff’s discrimination claim, holding holding that a reasonable fact-finder could conclude that (i) the Bank’s explanation for firing Plaintiff was pretextual and that she was actually fired because of her sexual orientation, and (ii) Plaintiff had endured sufficiently pervasive harassment to alter the conditions of her employment; and (2) affirmed as to the balance of Plaintiff’s discrimination claim as well as on her defamation claims, holding that, in regards to these claims, the district court did not err in its judgment. View "Flood v. Bank of Am. Corp." on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to conspiracy to distribute controlled substances, possession of controlled substances with intent to distribute, and three specific offense counts reflecting particular crack sales. The district court sentenced Defendant to a bottom-of-the-range incarcerative term of 135 months. The First Circuit affirmed the convictions and sentence, holding (1) Defendant was adequately apprised of the nature of the charges, and his guilty plea was knowing and voluntary; (2) the district court did not err in enhancing Defendant’s offense level on the ground that he maintained an apartment as a stash house; (3) the district court did not err in selecting Defendant’s criminal history category; (4) Defendant’s ineffective assistance of counsel claim was not properly before the Court; and (5) Defendant’s additional assignments of error were without merit. View "United States v. Jones" on Justia Law

Plaintiff, the former head chef at the Villa Cofresi Hotel, was at least forty years old at the time he was suspended and then fired. Plaintiff filed suit in federal court against the Hotel and its general manager under the Age Discrimination in Employment Act and Puerto Rico employment law, alleging that he was fired because of his age and in retaliation for his efforts to assert his rights against this discrimination. The district court granted summary judgment for the defendants on both the federal age discrimination and retaliation claims. The First Circuit vacated the judgment of the district court, holding (1) Plaintiff put forth a sufficient prima facie case of age discrimination to survive summary judgment; (2) there is a triable issue of fact as to whether the defendants’ stated grounds for firing Plaintiff were in fact a pretext for age discrimination; (3) in regard to Plaintiff’s retaliation claim, the record gives rise to competing plausible inferences from which a rational jury could find for Plaintiff; and (4) the dismissal of Plaintiff’s pendent state law claims must also be vacated. Remanded. View "Soto-Feliciano v. Villa Cofresi Hotels, Inc." on Justia Law

Three criminal defendants (“Defendants”) were indicted and convicted for conspiracy to import cocaine. Defendants appealed their convictions and sentences. The First Circuit affirmed the judgment of the district court, holding that the district court (1) did not err in denying Defendants’ motions for judgment of acquittal; (2) did not err in determining cocaine quantity at sentencing; (3) did not abuse its discretion in fashioning Defendants’ sentences; (4) did not violate Defendants’ right to a public trial; and (5) did not err in applying a two-level sentencing enhancement for the foreseeable presence of a firearm. The Court nevertheless remanded to the district court so that it may consider a sentencing reduction in accordance with the newly-promulgated Amendment 782 to the United States Sentencing Guidelines. View "United States v. Alejandro-Montanez" on Justia Law

Sterling Suffolk Racecourse, LLC (SSR) applied for a license to place a casino in certain areas of Massachusetts. Caesars Entertainment Corporation and three Massachusetts affiliates (collectively, Caesars) were the proposed operators of the casino. The Massachusetts Gaming Commission issued an investigatory report concluding that Caesars was unsuitable as an operator, which caused Caesars to accede to SSR’s request that it withdraw from their contractual relationship. Caesars brought this action under 28 U.S.C. 1983 against certain Commission officials in their individual and official capacities and also brought a state law claim subject to supplemental jurisdiction. The district court dismissed the federal claims under Fed. R. Civ. P. 12(b)(6) as beyond the scope of federal affordable relief and dismissed the state law claim as standing alone. The First Circuit affirmed, holding (1) because Caesars alleged no cognizable protected property interest, its Fifth and Fourteenth Amendment due process claims were correctly dismissed for failure to state a claim; and (2) Caesars’ class-of-one Fourteenth Amendment equal protection claim could not be recognized against a state actor given the breadth of discretion provided by the Massachusetts casino licensing statute. View "Caesars Mass. Dev. Co., LLC v. Crosby" on Justia Law

After a jury trial, Petitioner was found guilty of armed robbery and armed burglary. The state trial judge found Petitioner to be a habitual offender and sentenced him to life in prison. On appeal, the state appellate court determined (1) the victim’s pretrial identification of Petitioner’s voice on a recorded telephone call was not tainted by an improperly suggestive police procedure; and (2) Petitioner’s post-Miranda statements to the police were made voluntarily. Petitioner later sought federal habeas relief, alleging that his due process rights under the Fifth and Fourteenth Amendments were violated. The district court denied the petition. The First Circuit affirmed, holding (1) the state court’s decision that the pretrial identification of Petitioner’s voice was sufficiently reliable for the jury’s consideration was not the result of “extreme malfunction” sufficient to warrant relief under 28 U.S.C. 2254; and (2) the state court’s decision on voluntariness was objectively reasonable.. View "Cooper v. Bergeron" on Justia Law