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

The First Circuit affirmed the order of the district court granting summary judgment to Defendant on Plaintiff's claims of disability discrimination and retaliation, in violation of the Americans with Disabilities Act, 42 U.S.C. 12101-12213 (ADA), and Mass. Gen. Laws ch. 151B, 4, holding that the material facts did not raise a reasonable inference of employment discrimination under state or federal law.After Defendant was terminated from his employment he filed an employment and retaliation complaint under the ADA and Chapter 151B. The district court determined that the undisputed material facts did not raise a reasonable inference that Defendant discriminated or retaliated against Plaintiff because of his disability. The First Circuit affirmed, holding that Plaintiff did not produce sufficient evidence to survive summary judgment on his claims. View "Brader v. Biogen Inc." on Justia Law

In this case brought under the anti-retaliation provision of the False Claims Act, the First Circuit affirmed the judgment of the district court awarding Plaintiff $762,525 in compensatory damages, holding that the causation standard for retaliation claims under the Act is a "but-for" standard.Plaintiff filed suit against Defendant, her employer, alleging that Defendant had retaliated against her in violation of the Act after it learned that she had filed a qui tam action against it and one of its largest customers. The jury awarded Plaintiff compensatory damages, and the district court denied Plaintiff's subsequent motions for judgment as a matter of law and a new trial. The First Circuit affirmed, holding (1) retaliation claims under the Act must be evaluated under the "but-for" causation standard; (2) the "substantial motivating factor" instruction given to the jury was erroneous, but the instruction was not plain error; (3) the jury supportably found sufficient evidence against Defendant on the retaliation claim; and (4) the district court properly denied Defendant's motion for a new trial. View "Lestage v. Coloplast Corp." on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendant's motion for judgment as a matter of law and dismissing Plaintiff's claim that she was fired from her position because of her age, holding that Plaintiff's claims were without merit.After she was discharged, Plaintiff brought suit in the federal district court pursuant to the Age Discrimination in Employment Act, 29 U.S.C. 623(a)(1). Plaintiff also asserted a number of supplemental claims under Puerto Rico law. At trial, once Plaintiff rested, Defendant moved for judgment as a matter of law. The district court granted the motion. The First Circuit affirmed, holding that the district court (1) did not contradict the law of the case doctrine when it excluded certain evidence at trial; (2) did not abuse its discretion in refusing to admit the evidence at trial; and (3) did not err in entering judgment as a matter of law. View "Daumont-Colon v. Coop de Ahorro y Cred Caguas" on Justia Law

The First Circuit vacated the October 30, 2019 order of the National Labor Relations Board reinstating its November 10, 2016 order finding that Wang Theatre, Inc. (WTI) committed labor violations by failing to bargain with the Boston Musicians' Association, holding that the Board made errors of law and fact in certifying a bargaining unit that had no employees.BMA petitioned the Board to become the union representative for musicians employed by WTI. WTI argued that the petition should be dismissed because WTI had not employed any musicians since 2014. On November 10, 2016, the Board certified the bargaining unit. BMA then filed a charge with the Board alleging that WTI committed an unfair labor practice by refusing to bargain. The Board granted summary judgment for BMA. On October 30, 2019, the Board reinstated its original November 10, 2016 order. The First Circuit vacated both orders, holding that the Board misapplied the law and its own case law in certifying a no-employee bargaining unit. View "National Labor Relations Board v. Wang Theatre, Inc." on Justia Law

The First Circuit affirmed the district court's dismissal of this complaint alleging that Puerto Rico's series of laws that affect the relationship between public employees in the Commonwealth and their employers impermissibly interfere with their collective bargaining rights, holding that the complaint failed to state a claim upon which relief may be granted.To address Puerto Rico's fiscal criss, the Puerto Rico Legislative Assembly passed the four laws challenged in this case affecting the rights and benefits of public sector workers. Two Puerto Rico unions brought this action alleging that these measures violated the Contract Clause of the United States Constitution and the Collective Bargaining Clause of the Puerto Rico Constitution. The district court dismissed the complaint. The First Circuit affirmed, holding that the district court properly dismissed the complaint for failure to state a claim. View "Hermandad de Empleados v. Financial Oversight & Management Board" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment on Plaintiff's racial discrimination and retaliation claims against the Massachusetts Bay Transportation Authority (MBTA), holding that both challenges were meritless.Plaintiff brought claims of racial discrimination, unlawful retaliation, and negligent infliction of emotional distress against the MBTA. The district court granted summary judgment to the MBTA on all claims. The First Circuit affirmed, holding (1) Plaintiff did not produce sufficient evidence to get to a jury on his claim that he was denied a promotion based on his race; and (2) Plaintiff did not establish a prima facie case of retaliation. View "Henderson v. Massachusetts Bay Transportation Authority" on Justia Law

The First Circuit denied the petition filed by United Nurses and Allied Professionals (the Union) for review of the decision of the National Labor Relations Board (the Board) ruling that lobbying expenses are categorically not chargeable to objecting employees, holding that unions cannot require objectors to contribute toward lobbying costs.Jeanette Geary worked as a nurse at a Rhode Island hospital where the Union was the exclusive bargaining representative. Geary challenged the Union's decision to charge her for some of its 2009 lobbying expenses and to refuse her a letter verifying that its expenses were examined by an independent auditor. The Board ruled in favor of Geary. The First Circuit upheld the decision, holding (1) the Board's decision on the Union's lobbying expenses comported with Supreme Court decisions addressing the changeability of lobbying expenses by public-sector unions; and (2) the Board's determination requiring the Union to provide Geary a letter signed by an auditor verifying that the financial information disclosed to the objectors had been independently audited was reasonable. View "United Nurses & Allied Professional v. National Labor Relations Board" on Justia Law

The First Circuit reversed the district court's judgment ordering Council 93, a regional division of the American Federation of State, County and Municipal Employees (AFSCME), to reconstitute its executive board "within one year so that there may be proper proportional representation for its constituent locals and members," holding that the district court erred.This case arose out of a dispute between Council 93 and one of its local divisions, Local 402, over the allocation of seats on Council 93's governing executive board. Plaintiffs, members of Local 402, brought this action alleging that the allocation of seats on the executive board violated their right to an equal vote under Title I of the Labor-Management Reporting and Disclosure act of 1959 (LMRDA) and the AFSCME constitution. The district court agreed and ordered Council 93 to reconstitute its executive board. The First Circuit reversed, holding (1) any remedy for a violation of the equal rights provision of Title I must be implemented by the Secretary of Labor under the remedial provisions of Title IV of the LMRDA; and (2) Plaintiffs failed to show that the union constitution supported their claims. View "Conille v. Council 93" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Walden Security and dismissing the suit brought by Plaintiffs for statutory separation pay pursuant to Puerto Rico Law 80, holding that Plaintiffs had no remedy pursuant to Law 80.Plaintiffs had served as court security officers for the District of Puerto Rico for thirty-two years when Walden Security assumed the federal contract to provide courthouse security services. Walden refused to hire Plaintiffs because they lacked certification from a law enforcement training academy. Plaintiffs subsequently filed the instant lawsuit for statutory separation pay. The district court granted summary judgment for Walden, reasoning that Law 80 did not apply to Plaintiffs' claims. On appeal, Plaintiffs argued that the district erred in ignoring the theory of liability that Plaintiff's advanced: Puerto Rico's common law successor employer doctrine. The First Circuit affirmed, holding (1) the district court misconstrued Plaintiffs' theory of liability; but (2) the successor employer doctrine was clearly inapplicable to Plaintiffs' case. View "Lopez-Santos v. Metropolitan Security Services" on Justia Law

The First Circuit affirmed the district court's denial of Appellants' motion to compel arbitration in this putative class action, holding that the Federal Arbitration Act's (FAA) exemption for "contracts of employment of seamen, railroad employees, or any other class of workers engaged in foreign or interstate commerce" encompasses the contracts of transportation workers who transport goods or people within the flow of interstate commerce.Plaintiff was a delivery driver for Amazon.com, Inc. and its subsidiary, Amazon Logistics, Inc. (collectively, Amazon) who collected packages for delivery in Massachusetts and did not cross state lines during the course of his deliveries. Plaintiff filed this putative class action asserting misclassification of Amazon's drivers contracted with through its smartphone application as independent contractors and violations of Massachusetts labor laws. Amazon moved to compel arbitration pursuant to the mandatory arbitration provision of Plaintiff's employment agreement with Amazon. The district court denied the motion in part, concluding that Plaintiff's agreement was exempt from the FAA and that the provision was unenforceable based on Massachusetts public policy. The First Circuit affirmed, holding (1) the FAA does not govern the enforceability of the dispute resolution section of the agreement; and (2) the district court rightly refused to compel arbitration pursuant to state law. View "Waithaka v. Amazon.com, Inc." on Justia Law