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

The First Circuit affirmed the judgment of the district court rejecting Plaintiffs’ motion to set aside an earlier federal district court decision granting summary judgment in favor of Defendants on Plaintiffs’ claims seeking to recover lost benefits from their former employer, holding that the district court properly found that the judgment was not procured by “fraud on the court.”Plaintiffs claimed in their motion that various defendants made deliberate material misstatements in their answers and various sworn statements. The district court determined that the allegations did not warrant vacating the judgment. The First Circuit affirmed, holding that, even assuming the truth of Plaintiffs’ allegations, the allegations were not sufficient to constitute “fraud upon the court.” View "Torres v. Bella Vista Hospital, Inc." on Justia Law

The First Circuit affirmed the order of the district court finding that an arbitration agreement between the parties in this case was enforceable, granting AT&T Mobility Puerto Rico, Inc.’s (AT&T) motion to compel arbitration and dismissing Nereida Rivera-Colon’s (Rivera) suit, holding that Rivera manifested her intent to accept the agreement to arbitrate legal grievances as per Puerto Rico law.Rivera filed suit against AT&T, her former employer, alleging age discrimination and wrongful termination. AT&T entered a special appearance and moved to stay the proceedings and compel arbitration. In response, Rivera argued that there was no valid arbitration agreement. The district court held that the arbitration agreement was enforceable and granted the motion to compel arbitration. The First Circuit affirmed, holding that, under Puerto Rico law, Rivera was bound by the arbitration agreement because she failed to opt out of the agreement. View "Rivera-Colon v. AT&T Mobility Puerto Rico, Inc." on Justia Law

The First Circuit affirmed in part and vacated and remanded in part the district court’s dismissal of Appellant’s complaint claiming that he was fired from his job in retaliation for accusing his employer of violating the Anti-Kickback Statute (AKS) and making false representations in customer contracts, holding that Appellant plausibly pleaded that he engaged in protected conduct within the meaning of a False Claims Act (FCA) retaliation claim.The district court dismissed the complaint after finding that Appellant did not allege sufficient facts to show he was engaged in protected conduct within the meaning of the retaliation provision of the FCA. The First Circuit affirmed as to the contractual language claim but vacated and remanded as to the AKS claim, holding that Appellant plausibly pleaded that the concerns he raised about certain payments could have led to an FCA action. View "Guilfoile v. Shields" on Justia Law

The First Circuit affirmed the judgment of the district court concluding that Plaintiff was not discriminated against but that Defendant’s decision to terminate her employment, rather than impose lesser discipline, was in retaliation for protected conduct, holding that the district court’s rulings were not erroneous or an abuse of discretion.In her complaint, Plaintiff, a former employee of the U.S. Postal Service, argued that her termination was unlawfully discriminatory due to her race and national origin and, independently, was in retaliation for her having filed earlier complaints. Defendant appealed the ruling that Defendant’s termination was in retaliation for protected conduct, and Plaintiff appealed the remedy awarded - back pay but not reinstatement or front pay. The First Circuit affirmed, holding that there was no error in the district court’s judgments. View "Anderson v. Brennan" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of Defendants on Plaintiff’s claim that Defendants conspired against him and violated the Massachusetts Civil Rights Act (MCRA), Mass. Gen. Laws ch. 12, 11H, 11I by depriving him of his protected property right of continued employment with the Salisbury Police Department (SPD), holding that summary judgment was properly granted.In 2010, Cornelius Harrington, the Salisbury town manager, hired Robert St. Pierre to investigate allegations of misconduct by the then-police chief. During the investigation, St. Pierre uncovered evidence of alleged wrongdoing by Plaintiff, an officer at the SPD. After a follow-up investigation, Harrington terminated Plaintiff from his employment. An arbitrator later reversed that decision. Plaintiff retired soon after and filed this lawsuit against Harrington and St. Pierre. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding that summary judgment was proper where Plaintiff offered little evidence beyond bald speculation for the existence of a conspiracy and failed to show that his constitutional rights ere interfered with by “threats, intimidation, or coercion,” as required by the MCRA. View "Thomas v. Town of Salisbury" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment to the City of Providence, Rhode Island (the City) as to Plaintiff’s complaint for discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and related state anti-discrimination laws, holding that the district court properly entered summary judgment on Plaintiff’s claims.Following an injury that he sustained while on duty, Plaintiff, a veteran police officer in the City, sued the City for discrimination. The district court granted summary judgment in favor of the City on all claims, concluding that Plaintiff had failed to establish that he was disabled within the meaning of the ADA and failed to show a cognizable disability as to his state-law claims. Although its reasoning differed from that of the district court, the First Circuit affirmed, holding that summary judgment was properly entered on Plaintiff’s claims. View "Mancini v. City of Providence" on Justia Law

The First Circuit vacated the judgment of the district court in part ruling in favor of Putnam Investments, LLC and other fiduciaries of Putnam’s defined-contribution 401(k) retirement plan on Plaintiffs’ lawsuit claiming that Defendants breached fiduciary duties to the plan's participants, clarifying several principles for the district court that should guide its subsequent rulings on remand.Plaintiffs, two former Putnam employees who participated in the Plan, brought this lawsuit on behalf of a now-certified class of other participants in the Plan and on behalf of the Plan itself pursuant to the civil enforcement provision of ERISA, see 29 U.S.C. 1132(a)(2), arguing that Defendants offered a range of mutual investments, including Putnam’s mutual funds, without regard to whether such funds were prudent investment options and that Defendants treated Plan participants worse than other investors in Putnam mutual funds. The district court ruled in favor of Defendants. The First Circuit (1) affirmed the district court’s dismissal of Plaintiffs’ prohibited transaction claim under 1106(a)(1)(C), breach of loyalty claim, and disgorgement claim; (2) vacated the court’s dismissal of Plaintiffs’ prohibited transaction claim under 1106(b)(3) and the finding that Plaintiffs failed as a matter of law to show loss; and (3) remanded for further proceedings. View "Brotherston v. Putnam Investments, LLC" on Justia Law

The First Circuit affirmed the district court’s judgment in favor of Stephen Elliott on his suit against American Capital Energy, Inc. (ACE) and its two principals (collectively, Appellants) claiming breach of contract and violations of the Massachusetts Wage Act, holding that Ellicott’s compensation constituted “wages” under the Wage Act and that the statute of limitations for his Wage Act claim was properly tolled.Elliott filed suit against Appellants seeking compensation for unpaid sales commissions. The jury found all three Appellants liable under the Wage Act and ACE liable for breach of contract. The First Circuit affirmed, holding (1) the jury could reasonably conclude that Ellicott’s sales commissions constituted wages under the Wage Act; (2) tolling the statute of limitations so as to allow Ellicott’s Wage Act claims against one of the principals was justified; and (3) the district court did not abuse its discretion in granting Ellicott’s motions in limine excluding evidence about whether Elliott had agreed to split his sales commissions. View "Ellicott v. American Capital Energy, Inc." on Justia Law

The First Circuit affirmed the district court’s grant of summary judgment to MVM, Inc. as to a former employee’s claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000, et seq., and related Puerto Rico laws, holding that the district court did not err in granting summary judgment as to these claims.Plaintiff, a former employee of MVM, Inc., brought a variety of federal and Puerto Rico law claims against MVM and other defendants. After dismissing several of Plaintiff’s claims, the district court granted summary judgment to MVM as to the remainder. The First Circuit affirmed the summary judgment ruling, holding that the district court did not err in granting summary judgment to MVM on Plaintiff’s hostile work environment claim, Plaintiff’s claim under Title VII that MVM had unlawfully subjected her to disparate treatment because of her gender, and Plaintiff’s claim under Title VII for retaliation. View "Bonilla-Ramirez v. MVM, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court for Regional School Unit 57 (RSU 57) on Charlene Richard’s claims that RSU 57 violated the Americans With Disabilities Act, Rehabilitation Act, Maine Human Rights Act, and Maine Whistleblower Protection Act, holding that there was no clear error in the district court’s findings.Richard, a former kindergarten teacher at Waterboro Elementary School, claimed that RSU 57 retaliated against her for her advocacy on behalf of students with disabilities. The district court concluded that Richard had not met her burden of proving that her advocacy had actually prompted the adverse actions against her and entered judgment for RSU 57. The First Circuit affirmed, holding (1) the district court did not improperly require Richard to present evidence of causation beyond that which supported her prima facie case; and (2) Richard’s remaining arguments were similarly unavailing. View "Richard v. Regional School Unit 57" on Justia Law