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

The First Circuit affirmed the order of the district court granting summary judgment to Defendants - the Town of Abington, Massachusetts and leaders of the Abington Police Department (Department) - on Plaintiff’s federal and state law claims in which he alleged that Defendants retaliated against him while he was an officer in the Department.The Court held that the district court did not err in granting summary judgment as to (1) Plaintiff’s claims that he brought under 42 U.S.C. 1983 for retaliation against him for exercising his First Amendment rights; (2) Plaintiff’s other section 1983 claim that Defendants impermissibly retaliated against him for his protected union activity; and (3) Plaintiff’s pendent Massachusetts law claims. Finally, the district court did not abuse its discretion in granting the Massachusetts Office of Attorney General’s motion to quash a deposition subpoena. View "Delaney v. Town of Abington" on Justia Law

Employee’s failure to accommodate claim and retaliation claim under the Americans with Disabilities Act (ADA) failed.Employee, who was previously employed by Employer as an assistant manager of a Burger King, was attacked during the course and scope of his employment. In response to his diagnoses of post-traumatic stress disorder and major depression disorder, Employee requested that Employer provide him with a fixed work schedule and move him to a Burger King location in an area not prone to crime. When Employer did not comply, Employee brought this action alleging failure to accommodate under the ADA and hostile work environment. The district court concluded that Employee was not a qualified individual under the ADA and that the acts comprising his hostile work environment claim were insufficient to support his claim. The First Circuit affirmed, holding (1) the district court properly concluded that being able to work rotating shifts was an essential function of the assistant manager job; and (2) Employee did not demonstrate from an objective standpoint that Employer’s actions were sufficiently severe or pervasive to sustain a retaliatory work environment claim. View "Sepulveda-Vargas v. Caribbean Restaurants, LLC" on Justia Law

On the merits of the remaining portion of this appeal not dismissed as moot, the First Circuit held that the district court properly struck a local union (“UDEM”) as a plaintiff and dismissed this case brought challenging the validity of an international union’s (“ILA”) decision to place UDEM, one of ILA’s affiliates, into a trusteeship after UDEM opposed ILA’s plan to merge it with other local unions.When UDEM filed suit against ILA, the district court ruled that the trusteeship was lawfully imposed, denied UDEM’s motion for a preliminary injunction against the trusteeship, and struck UDEM as a party on the grounds that it did not have authorization from the trustee to sue ILA. Because the sole plaintiff was stricken, the district court dismissed the complaint. The First Circuit affirmed, holding (1) UDEM’s appeal from the denial of its motion for a preliminary injunction was moot due to the termination of the trusteeship; and (2) on the merits of the remainder of the appeal, UDEM’s vote to disaffiliate before the ILA placed it in trusteeship was invalid under the ILA constitution, and the trusteeship was legally imposed under the Labor-Management Reporting and Disclosure Act, leaving UDEM without authority to bring this lawsuit absent permission from the trustee. View "Union de Empleados de Muelles de Puerto Rico, Inc. v. International Longshoremen's Ass’n, AFL-CIO" on Justia Law

A trial court that wishes to us the McDonnell Douglas framework, see McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-804 (1973), as part of its jury instructions should translate it into everyday parlance and fit it to the facts and circumstances of a particular case.In this case alleging violations of federal and state law, including the Family and Medical Leave Act and the Rhode Island Civil Rights Act, the First Circuit affirmed the judgment of the district court entering a take-nothing verdict in favor of Defendants. Plaintiff moved for a new trial, arguing, among other things, that the district court erred in employing the McDonnell Douglas framework in its jury instructions. The First Circuit affirmed, holding that the district court’s jury instructions as a whole were satisfactory. View "Teixeira v. Town of Coventry" on Justia Law

The First Circuit affirmed the judgment of the trial court, entered after a jury trial, ruling in favor of Plaintiff on both her gender-based hostile work environment discrimination and retaliation claims. The court awarded Plaintiff emotional and front pay damages. Defendant, the City of Providence, appealed from the denial of its motion for judgment as a matter of law, making numerous arguments as to why the jury verdict should be set aside or, in the alternative, why the judge’s front pay award should be stricken. The First Circuit affirmed, holding that Defendant’s arguments and assignments of error were unavailing. View "Franchina v. Providence Fire Department" on Justia Law

The First Circuit affirmed the district court's dismissal of a complaint filed by unions representing the firefighters and police officers employed by the City of Cranston. The Unions filed a complaint claiming that legislation modifying various state-run pension plans for government employees, including a plan that covered municipal firefighters and police officers, unconstitutionally repudiated contractual obligations owed to the City employees. The district court dismissed the complaint. The First Circuit affirmed, holding (1) the complaint failed to allege that the legislation at issue unconstitutionally impaired any contractual rights of the Unions' members; (2) federal court was not the proper forum to litigate the Unions' undeveloped claims that the City was failing to abide by the terms of its ordinances or collective bargaining agreements; and (3) this lawsuit provided no opportunity to challenge the terms of a settlement by other parties in another lawsuit. View "Cranston Firefighters, IAFF v. Raimondo" on Justia Law

The First Circuit affirmed the decision of the district court granting the Rhode Island State Board of Election's motion for judgment on the pleadings with respect to Plaintiff's claims that his constitutional rights were violated by the manner in which his employment was brought to an end. The district court concluded that Plaintiff, a quondam employee of the Board, had not shown a deprivation of any constitutionally protected interest. The First Circuit affirmed, holding (1) Plaintiff failed to allege facts sufficient to show a constitutionally protected property interest in his job, and therefore, Plaintiff's loss-of-employment claim failed; and (2) Plaintiff failed to allege sufficient facts to make his claim that the Board stigmatized him plausible. View "Kando v. Rhode Island Board of Elections" on Justia Law

After a previous remand of this case, the First Circuit addressed whether the district court’s ruling in favor of Claimant on her claim for disability benefits based on chronic and severe pain was correct and whether the district court abused its discretion in failing to impose sanctions on one of Claimant’s attorneys.On the first appeal, the First Circuit remanded the case for additional administrative proceedings. On remand, Appellant again denied Claimant’s claim. Appellant appealed. The district court ruled in Claimant’s favor. On appeal, Appellant challenged the district court’s view of the expanded administrative record and the district court’s refusal to impose sanctions on one of Claimant’s attorneys. On cross-appeal, Claimant challenged the district court’s calculations of prejudgment interest and attorney’s fees. The First Circuit (1) affirmed the district court’s rulings on the disability claim and sanctions; but (2) vacated the prejudgment interest award and remanded for consideration of the appropriate rate of interest. View "Gross v. Sun Life Assurance Co. of Canada" on Justia Law

The First Circuit affirmed the district court’s denial of a motion for leave to amend a complaint after certain court proceedings, holding that the district court was not required to allow leave to amend.Plaintiffs filed suit against a group of healthcare entities alleging that Defendants’ compensation practices violated the Fair Labor Standards Act, the Employee Retirement Income Security Act, and the Racketeer Influenced and Corrupt Organizations Act. Defendants filed a motion for judgment on the pleadings. Plaintiffs opposed the motion, including a request to amend should the court grant the motion. The district court ultimately granted Defendants’ motion for judgment on the pleadings as to all of Plaintiffs’ claims and noted that Plaintiffs’ counsel had voiced the possibility that Plaintiffs might seek leave to amend but never followed through with a proper motion to amend. The First Circuit affirmed, holding that the district court did not abuse its discretion when it denied Plaintiffs’ motion for leave to amend the complaint. View "Hamilton v. Partners Healthcare System, Inc." on Justia Law

In this case concerning the application and operation of Article 31 of the Uniform Code of Military Justice, the First Circuit held that the exclusionary remedy limned in Article 31(d) applies to evidence offered in a trial by court-martial but not in a non-judicial punishment proceeding.Petitioner, a petty officer in the United States Navy, received a non-judicial punishment, rescission of his recommendation for promotion, and an adverse employment evaluation. Petitioner appealed, alleging, inter alia, that his waiver of Article 31 rights was involuntary. The Board of Correction of Naval Records upheld the adverse employment consequences. Petitioner sought judicial review. The district court refused to set aside the Board’s decision. The First Circuit affirmed, holding that the Board’s determination of voluntariness and its approval of the adverse employment consequences were in accordance with law. View "Sasen v. Spencer" on Justia Law