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

George Rodrique, II, a photographer for WCVB-TV, sued his employer, Hearst Stations, Inc. ("Hearst"), after it denied his request for a religious exemption from the company's COVID-19 vaccination requirement and subsequently terminated him for refusing to receive the vaccine. Rodrique claimed that Hearst's actions violated Title VII of the Civil Rights Act of 1964, which prohibits religious discrimination in employment.The United States District Court for the District of Massachusetts granted Hearst's motion for summary judgment, concluding that Rodrique's objections to the vaccine were not religious in nature. The court did not address whether accommodating Rodrique's request would have imposed an undue hardship on Hearst.Rodrique appealed to the United States Court of Appeals for the First Circuit, arguing that his objections were indeed religious and that granting the exemption would not have caused undue hardship. He contended that Hearst provided insufficient evidence that the COVID-19 vaccine reduces virus transmission.The First Circuit assumed, without deciding, that Rodrique's objections were religious. However, it affirmed the district court's summary judgment on different grounds, holding that Hearst reasonably relied on objective medical evidence, including public health guidance, to conclude that the vaccine reduces the likelihood of transmitting COVID-19. The court found that Hearst's reliance on such evidence was reasonable and that accommodating Rodrique's request would have imposed an undue hardship on the company. Thus, the First Circuit affirmed the district court's order granting summary judgment to Hearst. View "Rodrique v. Hearst Communications, Inc." on Justia Law

Jesse Sutherland was employed as an oil service technician at Peterson's Oil Service, Inc. ("Peterson's"). Two months into his job, he injured his right knee, leading to a torn meniscus and damaged patella. Sutherland requested reduced work hours due to his injury and eventually took a 12-week leave for knee surgery. Upon attempting to return to work, he was informed of his termination, effective the date he was supposed to return, citing a lack of work during the COVID-19 pandemic. Sutherland sued Peterson's for disability discrimination and related claims.The United States District Court for the District of Massachusetts granted summary judgment in favor of Peterson's, leading Sutherland to appeal. The district court concluded that Sutherland did not provide sufficient evidence to establish a prima facie case of disability discrimination, particularly questioning whether his knee injury qualified as a disability under the ADA.The United States Court of Appeals for the First Circuit reviewed the case and found that the district court erred in its analysis. The appellate court concluded that Sutherland provided sufficient evidence to show that his knee injury was a disability under the ADA, as it substantially limited his major life activities. The court also found that Sutherland's requests for reduced work hours were reasonable and that Peterson's failed to engage in the interactive process required by law. The appellate court vacated the district court's summary judgment on Sutherland's disability-related claims and remanded the case for further proceedings. However, the court affirmed the district court's decision regarding Sutherland's wrongful termination claim based on alleged violation of Massachusetts public policy, as Sutherland did not provide sufficient evidence of a well-defined public policy supporting his views on biofuel. View "Sutherland v. Peterson's Oil Service, Inc." on Justia Law

Regina M. Thornton was employed by Ipsen Biopharmaceuticals, Inc. as Associate Director - Patient Safety. In September 2021, Ipsen required employees to receive COVID-19 vaccinations. Thornton requested a religious exemption, which Ipsen denied. After she did not comply with the vaccination requirement, Ipsen terminated her employment. Thornton sued Ipsen in the Superior Court of Massachusetts, alleging violations of Title VII, Massachusetts law (Chapter 151B), the Fourteenth Amendment, and the Massachusetts Declaration of Rights (MDR). Ipsen removed the case to the United States District Court for the District of Massachusetts and moved to dismiss all counts. The Magistrate Judge granted Ipsen's motion, dismissing Thornton's complaint. Thornton appealed.The United States District Court for the District of Massachusetts dismissed Thornton's complaint, finding that she failed to state a plausible claim of religious discrimination under Title VII or Chapter 151B. The court concluded that Thornton did not adequately state her religious beliefs or how they related to vaccines. The court also found that Thornton's federal constitutional claims failed because Ipsen was not a state actor, and her MDR claims failed because the MDR does not provide a private right of action.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the Magistrate Judge's dismissal of Thornton's religious discrimination claims under Title VII and Chapter 151B, finding that she had plausibly alleged that her religious beliefs conflicted with the vaccination requirement. However, the court affirmed the dismissal of her federal constitutional claims, as the Fourteenth Amendment does not apply to private actors like Ipsen. The court also affirmed the dismissal of her MDR claims, noting that Thornton had waived any argument that her claim should be reimagined under the Massachusetts Civil Rights Act. View "Thornton v. Ipsen Biopharmaceuticals, Inc." on Justia Law

Plaintiff-appellant Kimberly A. Ripoli, a decorated veteran, claimed she experienced gender-based discrimination when terminated from her role as Associate Director of the Rhode Island Office of Veterans Affairs (OVA). She sued the State of Rhode Island, Department of Human Services, Office of Veterans Affairs under Title VII of the Civil Rights Act of 1964 and various Rhode Island statutes. The district court granted summary judgment in favor of the State on all claims.The United States District Court for the District of Rhode Island granted summary judgment for the State, dismissing Ripoli's claims of gender-based discrimination, retaliation, and hostile work environment. Ripoli did not address the district court's adverse rulings on her retaliation or hostile work environment claims in her appeal, leaving those rulings intact.The United States Court of Appeals for the First Circuit reviewed the case. The court vacated the district court's order on Ripoli's disparate treatment claims, finding that she had established a prima facie case of discrimination and raised genuine issues of material fact regarding whether the State's reasons for her termination were pretextual. The court noted that Ripoli presented evidence suggesting her role was not redundant, that the reorganization was not driven by budgetary constraints, and that she was replaced by a less-qualified heterosexual male. The court affirmed the district court's summary judgment on Ripoli's retaliation and hostile work environment claims, as she did not pursue these on appeal. The case was remanded for further proceedings consistent with the appellate court's opinion. View "Ripoli v. Rhode Island Department of Human Services" on Justia Law

Jorge Baez sued BayMark Detoxification Services, Inc., alleging disability discrimination under Massachusetts law, claiming BayMark Detox was his former employer. Baez was repeatedly informed that he had sued the wrong party but did not amend his complaint in time. BayMark Detox moved for summary judgment, asserting it was never Baez's employer. Baez then requested to amend his complaint to name the correct employer, but the district court granted summary judgment to BayMark Detox, denied Baez's Rule 60(b) motion for relief, and ordered Baez to pay costs.Baez initially worked for Community Health Care, Inc. (CHC), which was acquired by BayMark Health Services, Inc. (BHS). During the COVID-19 pandemic, Baez worked from home but was later terminated after an audit revealed billing errors. Baez filed a discrimination complaint against BayMark Detox, which was removed to federal court. BayMark Detox, a separate entity from CHC, stated it never employed Baez. The district court set a deadline for amending pleadings, which Baez missed.The United States District Court for the District of Massachusetts granted summary judgment to BayMark Detox, finding no evidence that BayMark Detox was Baez's employer. The court denied Baez's request to amend his complaint, citing his failure to show good cause for the delay. The court also denied Baez's Rule 60(b) motion, rejecting the argument that Massachusetts procedural rules should apply. The court awarded costs to BayMark Detox.The United States Court of Appeals for the First Circuit affirmed the district court's rulings, agreeing that Baez failed to name the correct employer and did not demonstrate good cause for amending his complaint late. The court also upheld the award of costs to BayMark Detox. View "Baez v. BayMark Detoxification Services, Inc." on Justia Law

Gloria Cocuzzo, a long-term employee of Trader Joe's East Inc., claimed she was terminated due to age discrimination. Cocuzzo, who began working at Trader Joe's in 2003 and was promoted to Merchant in 2012, received positive performance reviews and regular pay increases. In February 2021, she purchased beer for her underage grandson, also an employee at the store. This incident was reported to her supervisor, Jennifer Gillum, who, after consulting with a regional vice president, decided to terminate Cocuzzo. Cocuzzo was given the option to retire but was ultimately terminated when she refused to sign a termination notice.The United States District Court for the District of Massachusetts granted summary judgment in favor of Trader Joe's and Gillum, finding no evidence of age discrimination. The court held that Trader Joe's had a legitimate, non-discriminatory reason for terminating Cocuzzo, namely her violation of the store's alcohol policy by purchasing alcohol for an underage individual. The court also found that Cocuzzo failed to provide sufficient evidence to show that this reason was a pretext for age discrimination.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The appellate court agreed that Trader Joe's had a legitimate reason for terminating Cocuzzo and that she did not provide adequate evidence to prove that this reason was a pretext for age discrimination. The court also found that the evidence presented by Cocuzzo, including her positive performance reviews and the treatment of other employees, did not support her claims of disparate treatment or discriminatory animus. Consequently, the court upheld the summary judgment in favor of Trader Joe's and Gillum. View "Cocuzzo v. Trader Joe's East Inc." on Justia Law

A Transportation Security Officer (TSO) claimed she was terminated due to her disability, gender, and parental status, and alleged retaliation for filing complaints with the Equal Employment Opportunity Commission (EEOC). Her employer, the Transportation Security Administration (TSA), attributed her termination to her erratic attendance, including numerous tardies and unscheduled absences, despite multiple warnings.The United States District Court for the District of Puerto Rico granted summary judgment in favor of TSA on all claims. The court found that the plaintiff failed to provide sufficient evidence to support her claims of discrimination and retaliation. Specifically, the court noted that the plaintiff's attendance issues persisted even when she was on a modified work schedule and that TSA had legitimate, nondiscriminatory reasons for its actions.On appeal, the United States Court of Appeals for the First Circuit reviewed the case de novo. The court assumed, without deciding, that the plaintiff could establish a prima facie case of discrimination and retaliation. However, it found that TSA had provided legitimate, nondiscriminatory reasons for its actions, including the plaintiff's chronic absenteeism and failure to follow leave procedures. The court concluded that the plaintiff failed to show that these reasons were pretextual or that TSA's actions were motivated by discriminatory or retaliatory animus.The First Circuit affirmed the district court's grant of summary judgment for TSA on all counts, holding that the plaintiff did not meet her burden to create a genuine issue of material fact regarding pretext and discriminatory or retaliatory intent. View "Serrano-Colon v. Dep't of Homeland Security" on Justia Law

Michael Hermalyn, a former employee of DraftKings, left his position to join a rival company, Fanatics, based in California. DraftKings, headquartered in Massachusetts, claimed that Hermalyn's new role violated a noncompete agreement he had signed, which included a Massachusetts choice-of-law provision and a one-year noncompete clause. DraftKings sued Hermalyn in the U.S. District Court for the District of Massachusetts for breach of the noncompete agreement.The district court sided with DraftKings, applying Massachusetts law to determine the enforceability of the noncompete agreement. The court found the noncompete enforceable and issued a preliminary injunction preventing Hermalyn from competing against DraftKings in the United States for one year. Hermalyn appealed, arguing that California law, which generally bans noncompetes, should apply instead of Massachusetts law. Alternatively, he argued that if Massachusetts law applied, the injunction should exclude California.The United States Court of Appeals for the First Circuit reviewed the case. The court examined whether the district judge abused her discretion in granting the preliminary injunction and whether she made any legal errors in applying Massachusetts law. The appellate court found that Massachusetts law was correctly applied, noting that Massachusetts generally respects choice-of-law provisions unless they violate a fundamental policy of another state with a materially greater interest. The court concluded that Hermalyn failed to demonstrate that California's interest in banning noncompetes was materially greater than Massachusetts's interest in enforcing them.The First Circuit also upheld the scope of the preliminary injunction, rejecting Hermalyn's argument to exclude California. The court reasoned that excluding California would undermine the effectiveness of the injunction, as Hermalyn's role involved interacting with clients in states where online sports betting is legal. Consequently, the appellate court affirmed the district court's decision and awarded costs to DraftKings. View "DraftKings Inc. v. Hermalyn" on Justia Law

Amy Rae, a school nurse employed by Woburn Public Schools (WPS), alleged that she faced retaliatory harassment due to her advocacy for students with disabilities and complaints about her own mistreatment. Rae claimed that the harassment, primarily by Kennedy Middle School Principal Carl Nelson, began in 2011 and continued for over a decade. She filed a lawsuit in November 2022, asserting claims under Section 504 of the Rehabilitation Act, Title II of the Americans with Disabilities Act (ADA), Massachusetts's antidiscrimination statute (Chapter 151B), and for intentional infliction of emotional distress.The United States District Court for the District of Massachusetts dismissed Rae's complaint on May 5, 2023, ruling that she failed to state any claims for which relief could be granted. The court found that Rae could not rely on the continuing violations doctrine to save her untimely discrimination claims and dismissed her timely state and federal discrimination claims on other grounds.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court's dismissal de novo. The appellate court agreed that Rae could not invoke the continuing violations doctrine to rescue her time-barred claims, as her allegations included discrete acts of retaliation that accrued separately. The court also affirmed the district court's dismissal of Rae's timely ADA, Section 504, and Chapter 151B claims, concluding that Rae did not plausibly allege severe or pervasive harassment necessary to sustain a retaliatory harassment claim. The court noted that Rae's allegations of two incidents within the actionable period were insufficient to meet the standard for severe or pervasive harassment. Thus, the appellate court affirmed the district court's decision to dismiss Rae's complaint. View "Rae v. Woburn Public Schools" on Justia Law

Sara Caruso, a flight attendant for Delta Air Lines, failed a breathalyzer test on August 4, 2018, after a layover in Dallas, Texas. Caruso claimed she was drugged and sexually assaulted by Delta First Officer James Lucas the night before. The Dallas Police Department found insufficient evidence to support her claim, and Delta also took no action against Lucas after its investigation. Caruso completed an alcohol rehabilitation program and sought accommodations from Delta for PTSD related to the alleged assault. Although Delta and Caruso initially agreed on accommodations, Caruso resigned after a month back at work.Caruso sued Delta in Massachusetts state court, alleging violations of Massachusetts General Laws chapter 151B, Title VII of the Civil Rights Act of 1964, and the Americans with Disabilities Act (ADA). The case was removed to the U.S. District Court for the District of Massachusetts, which granted summary judgment for Delta on all counts. The court found no causal connection between Delta's actions and the alleged harassment and determined that Delta responded reasonably to the allegations. Additionally, Caruso's disability discrimination claims failed because she did not engage in an interactive process in good faith with Delta to develop reasonable accommodations.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's decision. The court held that Caruso failed to show a causal connection between Delta's actions and the alleged harassment, and that Delta's investigation and response were reasonable. The court also found that Caruso did not cooperate in the interactive process for her disability accommodations, and her retaliation claims were either waived or undeveloped. Thus, the summary judgment for Delta was affirmed on all counts. View "Caruso v. Delta Air Lines, Inc." on Justia Law