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

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

The First Circuit affirmed the district court's denial of Novo Nordisk Inc.'s motion for a temporary restraining order and preliminary injunction against Thomas Russomano, one of its former employees, and BioMarin Pharmaceutical, Inc., Russomano's current employer, holding that the district court did not abuse its discretion in finding that Novo Nordisk could not show a likelihood of success on the merits.Novo Nordisk sought to enforce the terms of a confidentiality and non-compete agreement that Russomano signed when he was employed at Novo Nordisk. The agreement prohibited Russomano from working for a competitor for one year after the end of his employment at Novo Nordisk and from disclosing confidential information. The district found that Novo Nordisk was not likely to succeed on the merits. The First Circuit affirmed, holding that the district court did not err in concluding that Novo Nordisk's termination letter was unambiguous that Russomano's employment ended on August 2, 2018. View "Russomano v. Novo Nordisk Inc." on Justia Law

The First Circuit affirmed the order of the district court finding that Plaintiff was disabled as defined under 20 C.F.R. 404.1520 and awarding her benefits, holding that there was very strong evidence of Plaintiff's disability, without any contrary evidence, to justify an award of benefits.At age thirty-four, Plaintiff filed applications for Social Security Disability Benefits and Supplemental Security Income. The Commissioner of Social Security denied Plaintiff's applications. In an independent assessment of her claim, an ALJ agreed with the Commissioner's decision, finding that Plaintiff was not disabled as defined under the Social Security Act. A federal magistrate judge found that substantial evidence did not support the ALJ's denial of benefits and recommended reversing the Commissioner's decision and remanding the case for further development of the facts. The district court agreed with the magistrate judge's findings but bypassed the need for further fact-finding and awarded benefits. The First Circuit affirmed, holding that there was overwhelming evidence to support a finding of disability and an award of benefits and that a remand for further proceedings was unnecessary. View "Sacilowski v. Saul" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment for Defendants on Plaintiff's age discrimination and Older Workers Benefit Protection Act (OWBPA) claims, holding that Plaintiff's OWBPA-compliant waiver and release were knowing and voluntary under federal common law.Plaintiff, a former Winchendon police officer, decided to resign with a pension after the Defendants determined that he had made several threats against his former girlfriend. Plaintiff resigned instead of facing termination and the possibility of losing his pension and being criminally charged. Plaintiff signed a separation agreement agreeing to waive and release any claims he had against Defendants up and through signing the agreement. Plaintiff later brought a complaint alleging age discrimination, retaliation, and defamation, alleging that the waiver and release in his separation agreement violated the OWBPA and were thus invalid. The district court granted summary judgment on the age discrimination and OWBPA claims for Defendants, and a jury found for Defendants on the retaliation and defamation claims. The Supreme Court affirmed the district court's grant of summary judgment, holding (1) the waiver and release did not violate the OWBPA and were knowing and voluntary; and (2) Defendant's argument that the district court abused its discretion in withdrawing an exhibit at trial was meritless. View "Geoffroy v. Town of Winchendon" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment for Defendants on Plaintiff's claim under the Age Discrimination and Employment Act (ADEA), 29 U.S.C. 621-634, holding that Defendant put forward a legitimate, nondiscriminatory reason for its decision to terminate Plaintiff's employment.Plaintiff was let go from his position after a new, consolidated position went to another employee and because Plaintiff's performance ratings had declined over time. Plaintiff brought an age discrimination claim under the ADEA and under analogous Puerto Rico law. The district court granted Defendants' motion to dismiss the Puerto Rico law claims and granted summary judgment for Defendants on the ADEA claim. The First Circuit affirmed, holding that Plaintiff did not put forth evidence that sufficed to create a genuine issue of disputed material fact as to whether Defendant's proffered reason for selecting the other employee over him for the new, consolidated position was a pretext for age discrimination. View "Zabala-de Jesus v. Sanofi Aventis PR, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court entering summary judgment against Plaintiff and dismissing her complaint asserting claims under the Americans with Disabilities Act (ADA) and Age Discrimination in Employment Act (ADEA) for discrimination and retaliation, holding that the district court did not err in granting summary judgment as to the ADA and ADEA claims and in dismissing the claims under analogous Puerto Rico laws.Plaintiff, a teacher at the Robinson School in Puerto Rico, sued the school and two school administrators alleging that the school had discriminated and retaliated against her because of her age and perceived disability. The district court granted summary judgment for Defendants as to the ADA and ADEA claims and dismissed without prejudice the discrimination and retaliation claims under the analogous Puerto Rico laws against the school upon declining to exercise supplemental jurisdiction. The First Circuit affirmed, holding that the district court did not err. View "Lopez-Lopez v. Robinson School" on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's complaint alleging that Defendants, his former employer along with its administrators, conspired to deprive him of his First, Fourth, Fifth, and Fourteenth Amendment rights, holding that the district court correctly dismissed the claims but erred in dismissing the Puerto Rico law claims with prejudice.In his complaint, Plaintiff alleged that several adverse employment actions taken against him by his employer were done in retaliation for his whistleblowing activities. The First Circuit (1) summarily affirmed the district court's dismissal of four of Plaintiff's claims, holding that Plaintiff failed to "seriously develop" argument in their favor on appeal; (2) affirmed the district court's dismissal of the remaining claims; and (3) vacated the district court's dismissal of the Puerto Rico claims with prejudice, holding that those claims should have been dismissed without prejudice. View "Borras-Borrero v. Corporacion del Fondo del Seguro del Estado" on Justia Law

The First Circuit affirmed the district court's grant of summary judgment against Appellant and dismissing his race discrimination and retaliation claims against the Maine Department of Corrections (MDOC), holding that Appellant lacked the proof needed to reach trial.Appellant left his job with MDOC as a state corrections officer to apply for a position in the federal prison system. Appellant met the minimum qualification and interviewed for each open spot but was turned down each time. Appellant subsequently reapplied for his former job, but MDOC refused to rehire him. Appellant sued MDOC in federal court for race discrimination and retaliation. The district court judge granted summary judgment for MDOC. The First Circuit affirmed, holding that a reasonable jury could not find that MDOC's rejection of Appellant's application for reinstatement was a product of unlawful discrimination or made in retaliation for his complaint to the Maine Human Rights Commission. View "Brandt v. Fitzpatrick" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Employer in this disability discrimination case brought by Plaintiff, a former employee, holding that the district court did not err in entering summary judgment against Plaintiff on her claims.Plaintiff was a military veteran who suffers from post-traumatic stress disorder (PTSD). After she was discharged from her employment, Plaintiff sued Employer for disability discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and the Maine Human Rights Act, Me. Stat. tit. 5 4551-4634, alleging that she was wrongfully discharged based on her PTSD. Plaintiff also claimed that Employer unlawfully failed to accommodate her disability. The district court granted summary judgment for Employer. The First Circuit affirmed, holding that the district court properly granted summary judgment for Employer on Plaintiff's discriminatory discharge claim and failure to accommodate claim. View "Trahan v. Wayfair Maine LLC" on Justia Law

The First Circuit held that the New Hampshire Judicial Retirement Plan (Plan) does not allow a former judge who resigned with sufficient years of creditable service, but before reaching the minimum retirement age, to receive a Service Retirement Allowance (SRA) upon later reaching the retirement age.Plaintiff was fifty-four years old when she resigned from her position as a superior court justice for the state of New Hampshire. Plaintiff served in that position for sixteen-and-a-half years. At the age of sixty-one, Plaintiff applied for an SRA. The Board of Trustees of the Board of Trustees (Board) of the Plan denied her application. Plaintiff filed suit against the Plan seeking a declaratory judgment that she was eligible for an SRA. The district court granted summary judgment in favor of the Plan as to Plaintiff's claim for violation of N.H. Rev. Stat. 100-C, 5, concluding that the plain language of the statute requires a judge to be in active service when she elects to retire and claim a service retirement allowance. The First Circuit affirmed, holding that, under the circumstances of this case, Plaintiff was not eligible to receive an SRA on her application. View "Coffey v. New Hampshire Judicial Retirement Plan" on Justia Law