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

The First Circuit affirmed the district court's entry of a preliminary injunction against Skinner Services, Inc., and four individuals (collectively, Skinner) to prevent Skinner's acceleration of efforts to insulate their individual and corporate assets to avoid a meaningful recovery for Plaintiffs in the underlying action, holding that the district court did not abuse its discretion.Plaintiffs, former low-wage employees of Skinner Demolition, sued Skinner on behalf of themselves and other similarly situated workers for unpaid wages. The court entered a protective order to prohibit Skinner from retaliating against any workers who participated in or assisted in the litigation. Skinner was subsequently held in contempt for violating the protective order. In the meantime, Skinner created four separate entities, which Plaintiffs alleged were used to dissipate or hide assets. The district court granted Plaintiffs' ensuing motion for injunctive relief, finding that Skinner likely had violated state and federal wage laws and was trying to transfer assets from its laborers' reach. The First Circuit affirmed, holding that the district court (1) had the authority to enter the preliminary injunction; and (2) did not abuse its discretion. View "Pineda v. Skinner Services, Inc." on Justia Law

The First Circuit affirmed the district court's entry of summary judgment in favor of BB&S Acquisition Corp. in this case brought by the personal representative of the estate of George Forbes, who was killed in an accident allegedly caused by Wiley Hooks, holding that the district court did not err.Before the accident, Hooks, the employee of Gregory Trucking, had delivered lumber to BB&S, which contracted with Gregory Trucking to transport a separate load of its treated lumber. After Hooks completed Gregory Trucking's contractual obligation to BB&S, Gregory Trucking hit a pick-up truck driven by George Forbes. Plaintiff brought this suit alleging that BB&S had negligently selected Gregory Trucking as an independent contractor to transport its lumber and that BB&S was the "statutory employer" of Hooks under 49 C.F.R. 390.5. The district court granted summary judgment for BB&S. The First Circuit affirmed, holding that the district court did not err in (1) concluding that BB&S could not be liable under Massachusetts common law for the actions of an independent contractor that occurred after the completion of the job; and (2) concluding that BB&S was not the "statutory employer" of Hooks. View "Forbes v. BB&S Acquisition Corp." on Justia Law

The First Circuit affirmed the decision of the district court entering summary judgment against the political discrimination claims brought by Plaintiffs, former Automobile Accident Compensation Administration (AACA) employees, against Defendants, the AACA and its former executive director, holding that the district court did not err.Plaintiffs were laid off pursuant to an agency-wide, facially-neutral layoff plan based on seniority. Plaintiffs brought this action under 42 U.S.C. 1983 alleging violations of their rights under the First, Fifth, and Fourteenth Amendments, along with violations of Puerto Rico law. The district court adopted Puerto Rico court decisions concluding that it was the Board of Directors, and not the Executive Director, that was responsible for the layoff plan, and then granted summary judgment for Defendants. The First Circuit affirmed, holding that the district court correctly concluded that Plaintiffs were barred from arguing in this litigation that the executive director was responsible for the layoff plan. View "Diaz-Baez v. Alicea-Vasallo" on Justia Law

In this vaccination dispute, the First Circuit denied the motion brought by Appellants seeking an injunction pending appeal, holding that Appellants were not entitled to the injunction.Appellants, eight employees of Mass General Brigham, Inc. (MGB), challenged MGB's application of its mandatory vaccination policy to them individually. The policy was issued in June 2021 requiring all MGB employees to be vaccinated against COVID-19 unless they qualified for a medical or religious exemption. After Appellants' requests for exemptions were denied and they still refused to get vaccinated, MGB placed them on unpaid leave. Appellants sued under Title VII of the Civil Rights Act and the Americans with Disabilities Act, arguing that MGB unlawfully denied their individual exemption requests. The district court denied Appellants' motion for a preliminary injunction, which would have required Appellants' reinstatement from unpaid leave status. The First Circuit denied Appellants' motion for injunction pending appeal, holding that adequate legal remedies foreclosed injunctive relief. View "Together Employees v. Mass General Brigham Inc." on Justia Law

The First Circuit reversed the order of the district court denying Lyft Inc.'s request to compel arbitration in this purported class action but affirmed the denials of preliminary injunctive relief, holding that the Federal Arbitration Act (FAA) applied.Plaintiffs were Massachusetts-based rideshare drivers who used the Lyft application and platform to find passengers. In their complaint, Plaintiffs claimed that Lyft misclassified them as independent contractors rather than employees. At issue on this appeal were rulings concerning Plaintiffs' requests for preliminary injunctive relief and the denial of Lyft's request to compel arbitration. The First Circuit reversed in part, holding (1) the FAA applies in this case; and (2) the district court did not err in denying Plaintiffs' requested injunction. View "Cunningham v. Lyft, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court ordering that Plaintiff's breach of contract claim be dismissed for failure to state a plausible claim and granting summary judgment for Defendants on all remaining counts, holding that there was no error.Plaintiff sued the City of East Providence, Rhode Island, its School Department, and the School Superintendent, asserting claims arising from what she alleged were unlawful discriminatory employment actions taken against her. The First Circuit resolved all claims in favor of Defendants. The First Circuit affirmed, holding (1) Plaintiff failed to plead even a prima facie case of discrimination; and (2) Plaintiff's claim of retaliatory employment discrimination was not supported by admissible evidence that would warrant putting the case to a jury. View "Lima v. City of East Providence" on Justia Law

The First Circuit affirmed the rulings of the district court dismissing Plaintiff's claims alleging that his termination violated 42 U.S.C. 1983 and Titles VI and VII of the Civil Rights Act of 1964, holding that there was no merit to Plaintiff's challenges on appeal.On appeal, Plaintiff challenged the district court's grant of summary judgment to Defendant on his Title VII retaliation claim, its dismissal of Plaintiff's Title VII hostile work environment claims for his failure to exhaust administrative remedies, and its denial of Plaintiff's motion for leave to amend his complaint to add a claim of disability discrimination. The First Circuit affirmed, holding that the district court did not err in granting summary judgment on the retaliation claim, its dismissal of the hostile work environment claim, and its denial of Plaintiff's motion to amend his complaint. View "Jenkins v. Housing Court Department" on Justia Law

The First Circuit reversed the district court's grant of summary judgment in this action alleging disability discrimination under the Maine Human Rights Act and retaliation under the Maine Whistleblower Protection Act and the Maine Human Rights Act, holding that summary judgment was improper.Plaintiff, a former Wal-Mart employee, brought this action against Wal-Mart Stores East, L.P., alleging disability discrimination and retaliation under Maine state law. After the case was removed to federal district court the district court issued an order granting summary judgment in favor of Wal-Mart. The First Circuit reversed, holding (1) there were genuine issues of material facts preventing summary judgment on Plaintiff's disability discrimination claim; and (2) the district court erred in concluding that none of the actions Plaintiff raised, if considered as protective activity, were causally connected to her termination. View "Benson v. Wal-Mart Stores East L.P." on Justia Law

The First Circuit affirmed the judgment of the district court summarily affirming an arbitration award dismissing Union Interacional UAW, Local 2415's wage grievance claim against Bacardi Corporation, holding that the Union did not identify an error in the arbitration award so egregious as to permit this Court to vacate it.The arbitrator found that the Union's claim was not procedurally arbitrable because the Union failed to comply with the contractual wage grievance procedure. On appeal, the Union argued that either the arbitrator should have deemed the procedural arbitrability defect waived or that the procedural defect did not justify dismissing the entire claim. The First Circuit affirmed, holding that, while the Union's waiver arguments had merit, the arbitrator acted within the scope of his authority in dismissing the entire claim for lack of procedural arbitrability. View "Union Internacional, UAW Local 2415 v. Bacardi Corp." on Justia Law

The First Circuit certified a question to the Massachusetts Supreme Judicial Court pursuant to Massachusetts Supreme Judicial Court Rule 1:03, holding that the outcome of this appeal depended upon a question of Massachusetts law, upon which the Massachusetts courts have not spoken.Plaintiffs, owners of 7-Eleven franchise operated in Massachusetts, alleged that 7-Eleven misclassified them was independent contractors rather than employees, in violation of Massachusetts law. At issue was a conflict between the Massachusetts Independent Contractor Law (ICL), Mass. Gen. Laws ch. 149, 148B, and the Federal Trade Commission's Franchise Rule making it allegedly impossible for 7-Eleven to satisfy federal law. The district court held that, due to this conflict, the ICL did not apply and therefore, its franchisees were properly classified as independent contractors. The First Circuit certified a question to the Massachusetts Supreme Judicial Court regarding the issue and retained jurisdiction pending resolution of the certified question. View "Patel v. 7-Eleven, Inc." on Justia Law