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

The First Circuit affirmed the judgment of the district court granting summary judgment to Gold Medal Bakery, Inc. and dismissing Robert Thompson's claims brought after he was fired, holding that the district court did not err or abuse its discretion.After he was fired, Thompson brought this complaint alleging that Gold Medal terminated his employment in violation of the anti-retaliation provision of the Family and Medical Leave Act (FMLA) and federal and state disability discrimination laws. The district court granted summary judgment to Gold Medal on all claims. The First Circuit affirmed, holding (1) the district court properly determined that, as a matter of law, Thompson could not establish that he was a "qualified individual" under the Americans with Disabilities Act at the time of his firing; (2) the district court did not err in granting summary judgment to Gold Medal on Thompson's FMLA retaliation claim; and (3) Thompson's remaining arguments were unavailing. View "Thompson v. Gold Medal Bakery, Inc." on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Defendants, the City of Framingham and Brian Simoneau, in this lawsuit raising Massachusetts Whistleblower Act claims and speech retaliation claims under Garcetti v. Ceballos, 547 U.S. 410 (2006), holding that the district court did not err.Vincent Stuart, a former Framingham police officer, brought this action alleging that the termination of his employment was in retaliation for his speech. The district court granted summary judgment for Defendants on both the First Amendment speech-retaliation and the Massachusetts Whistleblower Act claims. The First Circuit affirmed, holding that the district court did not err in concluding that there was not a triable question that Stuart's complaint was a substantial or motivating factor in his suspension and termination. View "Stuart v. City of Framingham, Massachusetts" on Justia Law

In this civil rights action alleging violations of 42 U.S.C. 1981, 1983, and 1985, the First Circuit affirmed the judgment of the district court dismissing with prejudice Plaintiff's claims against Stanley Spiegel and later granting summary judgment in favor of the remaining defendants, holding that the allegations against Spiegel failed to state a claim upon which relief can be granted.Defendant's second amended complaint named as defendants the Town of Brookline, Massachusetts, the Brookline Board of Selectmen, certain members of the Board, Spiegel (a town meeting member), and others. Plaintiff alleged that Defendants discriminated against him on the basis of race, retaliated against him for exercising his First Amendment rights, and conspired to enforce the Town's policy of opposing racial equality. After the district court disposed of Defendant's claims he appealed, arguing that the district court erred by dismissing his claims against Spiegel. The First Circuit affirmed, holding that there were no facts pleaded in the complaint sufficient to ground a reasonable inference that Spiegel was liable to Defendant for any of the causes of action he brought. View "Alston v. Town of Brookline, Massachusetts" on Justia Law

In this action brought under the Railway Labor Act (RLA), 45 U.S.C. 151 et seq., the First Circuit affirmed the judgment of the district court dismissing Plaintiff's claim against American Airlines, Inc. and later granting Allied Pilots Association's (APA) motion for summary judgment, holding that that APA did not breach its duty of fair representation and that Plaintiff could not maintain a claim against American Airlines.In 1999, Bryan's then-union submitted a grievance on his behalf alleging that his then-employer violated the terms of the applicable collective bargaining agreement and that APA, the successor to the previous union, breached its duty of fair representation under the RLA by withdrawing from pursuing his grievance to arbitration based on an allegedly inadequate investigation into the grievance's merits. Bryan also suit American Airlines, the successor to his previous employer, for his previous employer's alleged breach of the collective bargaining agreement. The district court disposed of the claims through dismissal and summary judgment. The First Circuit affirmed, holding (1) APA did not breach its duty of fair representation under the RLA; and (2) based on Bryan's own concession, he could not maintain a claim against American Airlines. View "Bryan v. American Airlines, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Employer and dismissing Employee's claims for retaliation in violation of the Family and Medical Leave Act (FMLA), 29 U.S.C. 2612, and disability discrimination in violation of the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and the Rhode Island Fair Employment Practices Act, R.I. Gen. Laws 28-5-7, holding that the district court did not err.Employee took leave from Employer under the FMLA to undergo preventive surgery and then took a second leave for a related surgery that same year. The following year, Employer eliminated Employee's position. As an alternative to termination, Employer offered Employee a newly created, lower level position with a lower salary. Employee declined the position, and Employer terminated her employment. Plaintiff then brought this action. The district court granted summary judgment in favor of Employer. The First Circuit affirmed, holding that summary judgment was properly granted. View "O'Rourke v. Tiffany & Co." on Justia Law

In this appeal from the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA) Title III court in Puerto Rico the First Circuit affirmed the dismissal of Petitioner's mandamus petition for failure to state a claim, holding that the Title III court correctly dismissed the petition for writ of mandamus.The petition at issue alleged that when the Puerto Rico Electric Power Authority (PREPA) announced that it would increase some medical co-pays while decreasing others in order to comply with its certified fiscal plan PREPA violated two provisions of a Puerto Rican statute. Petitioner, which represented the employees of PREPA, sought to compel PREPA to comply with the savings and pre-existing conditions provisions of Act No. 26-2107, P.R. Laws Ann. tit. 3, 9461 et seq. The Title III court denied mandamus relief, concluding that Petitioner did not meet its burden of showing that there were no adequate alternative remedies. The First Circuit affirmed, holding that the petition was correctly dismissed because Petitioner did not demonstrate that there was no adequate alternative remedy available for its members to recover from PREPA. View "Union de Trabajadores de la Industria Electrica y Riego v. Ortiz Vazquez" on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment against Matthew White and for Hewlett Packard Enterprise (HP), White's former employer, on White's claims based on Maine employment law, holding that the district court did not abuse its discretion.The district court held that controlling Maine Law Court decisions meant White's claims for accrued vacation pay and bonus pay were without merit and that White's remaining claims for equitable relief were unavailing. The First Circuit affirmed, holding (1) under Maine, law, White had no right to be paid for unused vacation time except as provided for in his employment agreement; (2) White's bonus compensation claims were meritless; (3) the district court was within its discretion to permit HP to produce an additional document before summary judgment; and (4) the district court did not abuse its discretion in commenting about the parties' statements of material facts. View "White v. Hewlett Packard Enterprise Co." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's disability discrimination suit against the United States Patent and Trademark Office and its director, holding that the district court did not err.The district court dismissed the action on the grounds that Plaintiff waived his discrimination claim in a settlement agreement that allowed him to resign from his job instead of being terminated. On appeal, Plaintiff argued that the district court erred in finding that his allegation of an unenforceable waiver was implausible. Specifically, Plaintiff argued that the agreement was void because he did not knowingly and voluntarily agree to it. The First Circuit disagreed, holding that the district court properly concluded that the waiver was binding. View "Perez-Tolentino v. Iancu" on Justia Law

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