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

The First Circuit affirmed in part and reversed in part in this case brought against three Maine government officials in their official capacities (collectively, the State) and several healthcare providers (the Providers) by Plaintiffs, seven healthcare workers whose employment was vaccinated after they refused to accept COVID-19 vaccination (collectively, the Providers), holding that the court erred in dismissing certain claims.In 2021, under the "Mandate," Maine required certain healthcare facilities to ensure that their non-remote workers were vaccinated against COVID-19. Plaintiffs alleged that their sincerely-held religious beliefs prevented them from receiving any of the available COVID-19 vaccines and requested that their employers, the Providers, exempt them from the vaccination requirement. The Providers refused and terminated Plaintiffs' employment. Plaintiffs brought this suit alleging several claims. The district court dismissed the complaint in its entirety. The First Circuit reversed in part, holding that the district court (1) did not err in dismissing Plaintiffs' claims brought under Title VII of the Civil Rights Act of 1964; but (2) erred in dismissing Plaintiffs' claims for relief under the Free Exercise and Equal Protection Clauses. View "Lowe v. Mills" on Justia Law

The First Circuit reversed the judgment of the district court dismissing Plaintiff's breach of contract claim against Defendant, a digital health company, and affirmed the district court's dismissal of all other claims against Defendant and three of its board members, holding that Plaintiff plausibly stated a claim for entitlement to severance benefits.Plaintiff worked for Defendant as its CEO for one year. Thereafter, Defendant decided that it no longer wished to continue its relationship with Plaintiff, as defined in her one-year, automatically renewable employment agreement, and, after she left, refused to pay severance benefits under the agreement. In response to Plaintiff's ensuing lawsuit, Defendant argued that it did not terminate Plaintiff's employment because it merely exercised its right not to renew the agreement. The district court agreed and granted Defendant's motion to dismiss for failure to state a claim. The First Circuit (1) reversed the dismissal of Plaintiff's breach of contract claim, holding that the complaint adequately alleged that Defendant obligated itself to pay severance benefits by ending her employment under the agreement without cause before the end of the one-year term; and (2) affirmed the dismissal of all other claims against Defendant and its three board members, holding that the district court did not otherwise err. View "Sullivan v. etectRx, Inc." on Justia Law

The First Circuit affirmed the decision of the district court denying Defendants' motion to dismiss the underlying case or, in the alternative, to compel arbitration under section 1 of the Federal Arbitration Act (FAA), holding that Defendants were not entitled to reversal.Plaintiffs, who distributed Defendants' baked goods along routes in Massachusetts, brought this action alleging that Defendants misclassified them as independent contractors and seeking unpaid wages, overtime compensation, and other damages. Defendants filed a motion to dismiss or, in the alternative, to compel arbitration under the FAA. The district court denied the motion, concluding that Plaintiffs fell within the FAA's section 1 exemption from the FAA's purview "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce." The First Circuit affirmed, holding (1) two of Defendants' arguments were waived; and (2) Defendants were not entitled to relief on the merits of their remaining arguments. View "Canales v. CK Sales Co., LLC" on Justia Law

The First Circuit affirmed the district court's default judgment in a tort action brought against the owner of a boat that Plaintiff was working on at the time of his injury, holding that the district court did not err in granting default judgment and denying Appellant's request for leave to file a late claim under Supplemental Rule F of the Federal Rules of Civil Procedure.Appellant, a commercial fisherman, filed a complaint in a Massachusetts state court alleging that he was injured while working on a vessel owned by G&J Fisheries, Inc. and that G&J was liable for unseaworthiness and negligence under the Jones Act, 46 U.S.C. 30104. G&J filed a complaint in the federal district court seeking exoneration from liability under 46 U.S.C. 30501-12 and Supplemental Rule F. The district court enjoined all other lawsuits against G&J pursuant to Supplemental Rule F(3) and then granted default judgment for G&J on the grounds that Appellant failed to file a claim as required under the rule. The First Circuit affirmed, holding that the district court did not err in granting default judgment and in denying Appellant's request to file a late claim under Supplemental Rule F(4). View "G&J Fisheries, Inc. v. Costa" on Justia Law

The First Circuit affirmed the judgment of the district court granting in part and denying in part Cultural Care, Inc.'s motion to dismiss this putative class action alleging violations of Plaintiffs' rights under various state and federal wage and hour laws, holding that the district court did not err.Plaintiffs sued Cultural Care, a private company that places au pairs with host families in various states, alleging that the company qualified as an "employer" under the respective states' wage and hour laws and not only failed to pay Plaintiffs what they were owed but that Cultural Care violated the Family Leave Act and other laws. Cultural Care filed a motion to dismiss, arguing, inter alia, that it was shielded from immunity under the doctrine of derivative sovereign immunity as set forth in Yearsley v. W.A. Ross Construction Co., 309 U.S. 18, 20-22 (1940). The district court dismissed the state law deceptive trade practices claims under Connecticut and Washington law for lack of standing but otherwise denied the motion. The First Circuit affirmed, holding that Cultural Care was not entitled to protection under Yearsley at this stage of the litigation. View "Posada v. Cultural Care, Inc." on Justia Law

The First Circuit affirmed the decision of the district court entering summary judgment for Defendants on all of Plaintiff's claims in this wrongful termination case, holding that there was no error in the trial court proceedings.Plaintiff, a former police officer, filed a complaint against the town of Lexington, Massachusetts and its retired chief of police, arguing that Defendants denied him due process during the proceedings that led to the termination of his employment and that Defendants intentionally interfered with his efforts to gain employment elsewhere. The district court entered summary judgment for Defendants on all claims. The First Circuit affirmed, holding that there was no material fact in dispute as to whether the reason stated for refusing to hire Plaintiff was pretextual and that there was sufficient evidence from which a reasonable jury could find that Defendants' stated reason for denying him employment was pretextual. View "Mirabella v. Town of Lexington, Mass." on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Kent County Memorial Hospital and Michael Dacey, M.D., in his individual capacity and as President of Kent Hospital, and dismissing Richard Gilbert, M.D.'s suit challenging the Hospital Board of Trustees' revocation of Dr. Gilbert's privileges at Kent Hospital, holding that dismissal was proper.In granting summary judgment for Defendants, the district court concluded that Dr. Gilbert had not rebutted the presumption that Defendants were immune from liability in damages under the Health Care Quality Improvement Act (HCQIA), 42 U.S.C. 11101-11152, and immune from suit under Rhode Island state law. The First Circuit affirmed, holding (1) the Board was entitled to HCQIA immunity; and (2) the Board was entitled to immunity under R.I. Gen. Laws 23-17-23(b). View "Gilbert v. Kent County Memorial Hospital" on Justia Law

The First Circuit affirmed the order of the district court granting Defendant's motion for summary judgment and dismissing Plaintiff's action alleging gender discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq. and other claims under Puerto Rico law, holding that Defendant was not entitled to relief on her assignments of error.Plaintiff sued Defendant after she was not selected for promotion and her employment was terminated. The district court dismissed Plaintiff's claims on summary judgment, finding that Plaintiff failed to show that Defendant's decisions relating to Plaintiff's employment were motivated by discriminatory animus. The First Circuit affirmed, holding that summary judgment was proper as to all of Plaintiff's claims. View "Lopez-Hernandez v. Terumo Puerto Rico LLC" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendants' motion to dismiss this case arising from a labor dispute under Fed. R. Civ. P. 12(b)(6), holding that Plaintiff's constitutional rights were not violated by the designation of his union as the exclusive bargaining representative for all employees within Plaintiff's bargaining unit.At issue was whether a public employee's First Amendment rights to freedom of speech and association are infringed when a public employer authorizes a union to serve as the exclusive representative in collective bargaining for employees within that employee's designated bargaining unit. Plaintiff, a law professor, brought this lawsuit against, inter alia, the union that represented his bargaining unit, arguing that Defendants infringed his First Amendment rights by making the union his exclusive representative in negations regarding certain pay cuts. The district court granted Defendants' motions to dismiss. The First Circuit affirmed, holding that there was no merit to Plaintiff's contention that his constitutional rights were infringed by the designation of the union as the exclusive bargaining representative for all employees within Plaintiff's bargaining unit. View "Peltz-Steele v. Umass Faculty Federation" on Justia Law

The First Circuit affirmed the judgment of the district court entering summary judgment against Plaintiff, a police officer with the City of Somerville, and dismissing his wrongful discharge claim, holding that there was no error in the grant of summary judgment.Plaintiff was involved in an off-duty altercation with a civilian, who reported the matter. The Somerville police department conducted an internal investigation, during which Plaintiff lied about his conduct. After a hearing, the City determined that justice cause existed to terminate Plaintiff's employment. Plaintiff brought this lawsuit, alleging that his discharge was based on his race in violation of Title VII and Mass. Gen. Laws ch. 151B. The district court entered summary judgment for the City. The First Circuit affirmed, holding that the district court correctly dismissed both claims on summary judgment. View "Diaz v. City of Somerville" on Justia Law