Articles Posted in Labor & Employment Law

The First Circuit affirmed the entry of a jury verdict awarding over $1.3 in compensatory damages and $1.3 million in punitive damages to Plaintiff, a black female former employee of the Massachusetts Bay Transportation Authority (MBTA), who claimed that her supervisors at the MBTA conspired to terminate her employment because of her race. The Court held (1) the evidence was sufficient to support the compensatory damages award for wrongful termination and to justify the punitive damages amount; (2) the trial judge committed clear error in imposing a sanction for removing the entry of default, but the MBTA failed to show that it was prejudiced by the default sanction order; (3) MBTA failed to show that it was prejudiced when the trial judge allowed a hostile work environment theory not explicitly pled in the complaint to go to the jury; and (4) MBTA waived its claim that it should be able to take advantage of Buntin v. City of Boston, 857 F.3d 69 (1st Cir. 2017), decided while this case was on appeal. View "Dimanche v. Massachusetts Bay Transportation Authority" on Justia Law

The district court correctly granted summary judgment to the Defendant regarding Plaintiff’s hostile work environment and retaliation claims but erred in analyzing Plaintiff’s disparate treatment claim. After Plaintiff was transferred and replaced by one male employee and then by a second male employee, Plaintiff filed this Title VII gender discrimination action against her employer, the Corrections Department of the Commonwealth of Puerto Rico. The district court granted summary judgment to Defendant on all of Plaintiff’s claims. The First Circuit vacated in part the grant of summary judgment and remanded for further proceedings on Plaintiffs’ disparate treatment claim. The Court held (1) the district court erred in interpreting this Court’s decision in Johnson v. University of Puerto Rico, 714 F.3d 48 (1st Cir. 2013), to prohibit Plaintiff from relying on evidence highly relevant to the similar qualifications element of her prima facie case; and (2) Plaintiff established a prima facie case of gender discrimination that her employer failed to rebut, and therefore, summary judgment was incorrectly granted in the Department’s favor. View "Caraballo-Caraballo v. Correctional Administration" on Justia Law

In this complaint alleging violation of the Maine Whistleblower Protection Act (WPA), Me. Rev. Stat. Ann. tit. 26, 833, the district court faithfully followed the teachings of the Maine Supreme Judicial Court (the Law Court), correctly applied that court’s new, Maine-specific retaliation paradigm to Appellant’s WPA retaliation claim, and properly granted summary judgment in favor of Appellee. Invoking diversity jurisdiction, Appellant sued Appellee in Maine’s federal district court, alleging that Appellee violated the WPA. The district court granted summary judgment for Appellee. On appeal, Appellant argued that the district court ignored the prescriptions of the Law Court and improperly relied on the McDonnell Douglas framework, see McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973), in granting summary judgment for Appellee. The First Circuit affirmed, holding that the district court did not rely on the McDonnell Douglas framework but, rather, followed the teachings of the Law Court and properly determined that Appellant had not made out a cognizable claim for retaliation under state law. View "Theriault v. Genesis Healthcare LLC" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment to Defendants - the Town of Abington, Massachusetts and leaders of the Abington Police Department (Department) - on Plaintiff’s federal and state law claims in which he alleged that Defendants retaliated against him while he was an officer in the Department. The Court held that the district court did not err in granting summary judgment as to (1) Plaintiff’s claims that he brought under 42 U.S.C. 1983 for retaliation against him for exercising his First Amendment rights; (2) Plaintiff’s other section 1983 claim that Defendants impermissibly retaliated against him for his protected union activity; and (3) Plaintiff’s pendent Massachusetts law claims. Finally, the district court did not abuse its discretion in granting the Massachusetts Office of Attorney General’s motion to quash a deposition subpoena. View "Delaney v. Town of Abington" on Justia Law

Employee’s failure to accommodate claim and retaliation claim under the Americans with Disabilities Act (ADA) failed. Employee, who was previously employed by Employer as an assistant manager of a Burger King, was attacked during the course and scope of his employment. In response to his diagnoses of post-traumatic stress disorder and major depression disorder, Employee requested that Employer provide him with a fixed work schedule and move him to a Burger King location in an area not prone to crime. When Employer did not comply, Employee brought this action alleging failure to accommodate under the ADA and hostile work environment. The district court concluded that Employee was not a qualified individual under the ADA and that the acts comprising his hostile work environment claim were insufficient to support his claim. The First Circuit affirmed, holding (1) the district court properly concluded that being able to work rotating shifts was an essential function of the assistant manager job; and (2) Employee did not demonstrate from an objective standpoint that Employer’s actions were sufficiently severe or pervasive to sustain a retaliatory work environment claim. View "Sepulveda-Vargas v. Caribbean Restaurants, LLC" on Justia Law

On the merits of the remaining portion of this appeal not dismissed as moot, the First Circuit held that the district court properly struck a local union (“UDEM”) as a plaintiff and dismissed this case brought challenging the validity of an international union’s (“ILA”) decision to place UDEM, one of ILA’s affiliates, into a trusteeship after UDEM opposed ILA’s plan to merge it with other local unions. When UDEM filed suit against ILA, the district court ruled that the trusteeship was lawfully imposed, denied UDEM’s motion for a preliminary injunction against the trusteeship, and struck UDEM as a party on the grounds that it did not have authorization from the trustee to sue ILA. Because the sole plaintiff was stricken, the district court dismissed the complaint. The First Circuit affirmed, holding (1) UDEM’s appeal from the denial of its motion for a preliminary injunction was moot due to the termination of the trusteeship; and (2) on the merits of the remainder of the appeal, UDEM’s vote to disaffiliate before the ILA placed it in trusteeship was invalid under the ILA constitution, and the trusteeship was legally imposed under the Labor-Management Reporting and Disclosure Act, leaving UDEM without authority to bring this lawsuit absent permission from the trustee. View "Union de Empleados de Muelles de Puerto Rico, Inc. v. International Longshoremen's Ass’n, AFL-CIO" on Justia Law

A trial court that wishes to us the McDonnell Douglas framework, see McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-804 (1973), as part of its jury instructions should translate it into everyday parlance and fit it to the facts and circumstances of a particular case. In this case alleging violations of federal and state law, including the Family and Medical Leave Act and the Rhode Island Civil Rights Act, the First Circuit affirmed the judgment of the district court entering a take-nothing verdict in favor of Defendants. Plaintiff moved for a new trial, arguing, among other things, that the district court erred in employing the McDonnell Douglas framework in its jury instructions. The First Circuit affirmed, holding that the district court’s jury instructions as a whole were satisfactory. View "Teixeira v. Town of Coventry" on Justia Law

The First Circuit affirmed the judgment of the trial court, entered after a jury trial, ruling in favor of Plaintiff on both her gender-based hostile work environment discrimination and retaliation claims. The court awarded Plaintiff emotional and front pay damages. Defendant, the City of Providence, appealed from the denial of its motion for judgment as a matter of law, making numerous arguments as to why the jury verdict should be set aside or, in the alternative, why the judge’s front pay award should be stricken. The First Circuit affirmed, holding that Defendant’s arguments and assignments of error were unavailing. View "Franchina v. Providence Fire Department" on Justia Law

The First Circuit affirmed the district court's dismissal of a complaint filed by unions representing the firefighters and police officers employed by the City of Cranston. The Unions filed a complaint claiming that legislation modifying various state-run pension plans for government employees, including a plan that covered municipal firefighters and police officers, unconstitutionally repudiated contractual obligations owed to the City employees. The district court dismissed the complaint. The First Circuit affirmed, holding (1) the complaint failed to allege that the legislation at issue unconstitutionally impaired any contractual rights of the Unions' members; (2) federal court was not the proper forum to litigate the Unions' undeveloped claims that the City was failing to abide by the terms of its ordinances or collective bargaining agreements; and (3) this lawsuit provided no opportunity to challenge the terms of a settlement by other parties in another lawsuit. View "Cranston Firefighters, IAFF v. Raimondo" on Justia Law

The First Circuit affirmed the decision of the district court granting the Rhode Island State Board of Election's motion for judgment on the pleadings with respect to Plaintiff's claims that his constitutional rights were violated by the manner in which his employment was brought to an end. The district court concluded that Plaintiff, a quondam employee of the Board, had not shown a deprivation of any constitutionally protected interest. The First Circuit affirmed, holding (1) Plaintiff failed to allege facts sufficient to show a constitutionally protected property interest in his job, and therefore, Plaintiff's loss-of-employment claim failed; and (2) Plaintiff failed to allege sufficient facts to make his claim that the Board stigmatized him plausible. View "Kando v. Rhode Island Board of Elections" on Justia Law