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

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

The plaintiff, Lupe Stratton, worked at Bentley University from August 2016 to July 2018. She alleged that her supervisors discriminated against her based on her gender, race, disability, and Guatemalan origin. After she complained to Bentley's human resources department, she was placed on a performance improvement plan, which she claimed was retaliatory. Stratton also contended that Bentley interfered with her right to medical leave and failed to provide reasonable accommodations for her disability. She resigned, claiming her workplace had become intolerable.The United States District Court for the District of Massachusetts granted summary judgment in favor of Bentley University on all of Stratton's claims. The court found that Stratton did not suffer an adverse employment action that could support her discrimination claims and that her retaliation claims failed because she could not establish a causal connection between her complaints and the adverse actions. The court also held that Bentley had provided reasonable accommodations for Stratton's disability and had not interfered with her FMLA rights.The United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court agreed that Stratton did not experience an adverse employment action that could support her discrimination claims, as her working conditions were not so intolerable as to constitute a constructive discharge. The court also found that Stratton's retaliation claims failed because she could not show that her complaints were the but-for cause of the adverse actions. Additionally, the court held that Bentley had provided reasonable accommodations for Stratton's disability and had not interfered with her FMLA rights. The court clarified the relevant law governing Title VII retaliation claims in the circuit. View "Stratton v. Bentley University" on Justia Law

Amanda J. Bazinet, an executive office manager at Beth Israel Deaconess Hospital in Milton, Massachusetts, was terminated after the Hospital implemented a mandatory COVID-19 vaccine policy. Bazinet sought a religious exemption, citing her Christian beliefs and opposition to vaccines developed using fetal cell lines from aborted fetuses. The Hospital denied her request without engaging in an interactive process and subsequently terminated her employment.Bazinet filed a civil action alleging religious discrimination under Title VII of the 1964 Civil Rights Act and Massachusetts anti-discrimination law. The U.S. District Court for the District of Massachusetts dismissed her religious discrimination claims sua sponte, ruling that Bazinet failed to allege a sincerely held religious belief and that accommodating her would cause the Hospital undue hardship.The United States Court of Appeals for the First Circuit reviewed the case. The court found that Bazinet had sufficiently alleged a religious belief conflicting with the vaccine requirement, as her accommodation request and supporting letter detailed her religious objections. The court also determined that the sincerity of Bazinet's beliefs and the undue hardship defense required further factual development and could not be resolved at the motion to dismiss stage.The First Circuit vacated the district court's dismissal of Bazinet's religious discrimination claims and remanded the case for further proceedings, allowing the claims to proceed past the Rule 12(b)(6) stage. View "Bazinet v. Beth Israel Lahey Health, Inc." on Justia Law

The Acting Secretary of Labor filed a lawsuit against F.W. Webb Company, alleging that the company misclassified its Inside Sales Representatives (ISRs) as exempt administrative employees, thereby violating the Fair Labor Standards Act (FLSA) overtime and recordkeeping requirements. Webb, a wholesale distributor of engineering and construction products, employed over 600 ISRs who were responsible for selling products to various customers. The ISRs were classified as exempt from FLSA overtime requirements, despite some working over forty hours a week without receiving overtime pay. The ISRs' duties included interacting with customers, providing quotes, and managing orders, but they did not have managerial responsibilities over other employees.The United States District Court for the District of Massachusetts granted summary judgment in favor of the Secretary, finding that the ISRs' primary duty was to make sales, which is directly related to Webb's core business purpose of selling products. The court concluded that the ISRs did not qualify for the administrative exemption under the FLSA because their primary duty was not related to the management or general business operations of Webb. Consequently, the court found that Webb violated the FLSA by failing to pay overtime and maintain proper records for the ISRs.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's judgment. The appellate court agreed that the ISRs' primary duty was to sell Webb's products, which is directly related to the company's business purpose. The court held that the ISRs did not perform work directly related to the management or general business operations of Webb, and thus, did not qualify for the administrative exemption under the FLSA. The court emphasized that the ISRs' customer service and advisory roles were part of their sales duties and not separate administrative functions. View "Su v. F.W. Webb Company" on Justia Law

Michele Tourangeau filed a complaint against her former employer, Nappi Distributors, alleging nine employment-related claims. Nappi moved for summary judgment on all claims, but the District Court denied the motion for all but one claim, leading to a jury trial. The jury found in favor of Nappi on all claims. Tourangeau then filed a motion for a new trial, citing juror bias and errors in jury instructions, which the District Court denied.Tourangeau appealed the District Court's decision to the United States Court of Appeals for the First Circuit. She argued that the District Court erred in not disqualifying a juror who allegedly displayed bias and failed to answer voir dire questions truthfully. The District Court had previously determined that the juror's conduct and Facebook activity did not demonstrate bias sufficient to warrant disqualification. The appellate court found no abuse of discretion in the District Court's handling of the juror bias allegations, noting that the District Court had appropriately assessed the juror's behavior and responses.Tourangeau also challenged the jury's verdict on one of her Equal Pay Act (EPA) claims, arguing that the verdict was against the great weight of the evidence and that the District Court erred in not giving a specific jury instruction. The appellate court upheld the District Court's decision, finding that Nappi had provided sufficient evidence that the pay differential was based on a business decision unrelated to sex. The court also agreed with the District Court's refusal to give the requested jury instruction, as there was no evidence of a prior illegal practice of gender discrimination in hiring.The United States Court of Appeals for the First Circuit affirmed the District Court's judgment, concluding that there was no reversible error in the handling of the juror bias allegations or the EPA claim. View "Tourangeau v. Nappi Distributors" on Justia Law

The case involves William Rios, a part-time security guard for Centerra Group LLC, who was fired after being found asleep at his post. Rios, who has diabetes, sued Centerra alleging violations of the Americans with Disabilities Act (ADA). He claimed that he had an episode of hypoglycemic shock which caused him to fall asleep on the job, and thus, Centerra should have accommodated his disability. However, Rios did not present any evidence that Centerra knew about his hypoglycemic episode when it fired him.The district court granted summary judgment to Centerra on all claims. Rios appealed, challenging the district court's decisions on his ADA discrimination claim, ADA claim for failure to provide a reasonable accommodation, ADA claim for hostile work environment, ADA claim for retaliation, and the denial of his Federal Rule of Civil Procedure 56(d) motion seeking additional discovery to respond to the motion for summary judgment.The United States Court of Appeals for the First Circuit affirmed the district court's decisions. The court found that Rios failed to present evidence from which a reasonable jury could find that Centerra held a discriminatory animus toward him based on his disability. The court also found that Rios failed to provide any evidence of discriminatory animus that would allow a reasonable jury to infer that Centerra's reasons for firing Rios were pretextual. The court further held that the district court did not abuse its discretion in denying Rios's Rule 56(d) motion given his failure to show good cause or due diligence in pursuing discovery for information regarding similarly situated employees. View "Sheridan v. Centerra Group, LLC" on Justia Law

A former teacher at Hanover High School in Massachusetts, Kari MacRae, was terminated from her position due to controversial memes she posted on her personal TikTok account. The memes, which were posted before she was hired, touched on sensitive topics such as gender identity, racism, and immigration. After her posts became public knowledge, the school district decided to terminate her employment, citing concerns about potential disruption to the learning environment.In the lower courts, MacRae filed a lawsuit against the school district, the school's principal, and the superintendent, alleging that they had unconstitutionally retaliated against her for exercising her First Amendment rights. The district court granted the defendants' motion for summary judgment, concluding that the school district's interest in preventing disruption outweighed MacRae's First Amendment rights.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court's decision. The appellate court applied the Garcetti framework, which balances the interests of a public employee in commenting on matters of public concern against the interest of the state in promoting the efficiency of public services. The court found that while MacRae's posts did touch on matters of public concern, the school district's interest in preventing disruption to the learning environment was reasonable and outweighed MacRae's First Amendment interest. The court also noted that the timing of the posts, the media attention they received, and the controversy they stirred in the community all supported the school district's prediction of disruption. View "MacRae v. Mattos" on Justia Law

Jeffrey Neece sued the City of Chicopee, alleging that the mayor's decision not to renew his employment contract was retaliation for his testimony in a gender-discrimination case against the city. Neece claimed that his testimony undermined the city's defense, while the mayor argued that Neece was unproductive and unresponsive to his colleagues. The jury rejected Neece's retaliation claims. Neece appealed, arguing that he was entitled to a new trial because the district court limited the evidence he could present about a key event: a closed-door meeting between the city's attorneys and the city council about the merits of the gender-discrimination case and the impact of Neece's testimony.The United States Court of Appeals for the First Circuit upheld the district court's decision, concluding that the district court did not abuse its discretion in limiting evidence about the meeting. The court found that the mayor, who did not attend the meeting, was the decision-maker in not renewing Neece's contract. Neece was unable to show that the mayor ever learned about the details of the meeting, making the meeting irrelevant to the mayor's state of mind or alleged retaliatory motive. The court also found that the city did not waive its attorney-client privilege regarding the mayor's private conversations with the city attorney about the settlement of the gender-discrimination case. Therefore, the court affirmed the jury's verdict in favor of the city. View "Neece v. City of Chicopee" on Justia Law