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

Articles Posted in Labor & Employment Law
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The First Circuit affirmed the entry of a preliminary injunction enforcing a covenant not to compete included in a restrictive covenant agreement (RCA) that Appellant signed in 2017, holding that the district court did not err in finding that the covenant not to compete was reasonable and in entering the preliminary injunction. After working almost three decades at CVS Pharmacy, Inc., Appellant accepted a new position at PillPack LLC, a direct competitor of CVS. CVS sued Appellant seeking to enforce the covenant not to compete. The district court entered a preliminary injunction enjoining Appellant from working at PillPack for eighteen months, finding that the covenant was reasonable and that Appellant's new position would violate the covenant. The First Circuit affirmed, holding that, under either the as-applied or the facial approach in evaluating the reasonableness of the restrictive covenant, CVS was likely to succeed on the merits of its claim for injunctive relief. View "CVS Pharmacy, Inc. v. Lavin" on Justia Law

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The First Circuit affirmed the district court's grant of summary judgment on Appellant's federal law claims under the Age Discrimination and Employment Act, and on the state-law claims for discrimination, retaliation based on a complaint of age discrimination, and failure to investigate and vacated the summary judgment on the state law claims for retaliation based on a report of gender discrimination, breach of contract, intentional interference with contractual relations, and defamation, holding that the court erred in granting summary judgment as to these claims. This lawsuit arose from events that led to Appellant's retirement from his position as Fire Chief for the Fire Department of the Town of Marshfield, Massachusetts. The district court granted summary judgment in favor of the Town on all of Appellant's federal and state law claims. The First Circuit affirmed in part and vacated in part, holding (1) summary judgment was properly granted as to some of Appellant's claims; but (2) as to the remaining state law claims, there was no analogue to the common law claims in the federal law claims that were addressed, and rather than attempt to resolve the state law issues that were in dispute as to these claims, their dismissal was directed without prejudice. View "Robinson v. Town of Marshfield" on Justia Law

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The First Circuit affirmed the judgment of the district court denying Plaintiff's claims of sex discrimination and retaliation on summary judgment and declining Plaintiff's request to alter or amend that ruling under Fed. R. Civ. P. 59(e), holding that there was no reversible error in the proceedings below. This complaint stemmed from Plaintiff's unsuccessful pursuit of tenure within Harvard University's Anthropology Department. Plaintiff alleged that Harvard denied her tenure on the basis of sex discrimination and retaliation for engaging in protected conduct in violation of several state and federal antidiscrimination laws. The district court dismissed Plaintiff's claims on summary judgment and then denied Plaintiff's Rule 59(e) motion to alter or amend the summary judgment. The First Circuit affirmed, holding (1) the district court did not err in finding that Plaintiff did not meet her burden of showing Harvard's stated reason for denying tenure was merely pretext for discrimination; (2) because Plaintiff could not establish a causal link between her protected activity and the adverse employment decision, her retaliation claims failed; and (3) the district court did not err in denying Plaintiff's Rule 59(e) motion. View "Theidon v. Harvard University" on Justia Law

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The First Circuit affirmed the judgment of the district court in favor of Sun Life Assurance Company of Canada finding that Sun Life properly permitted an offset of Appellant's benefits under tis employer-sponsored long-term disability insurance policy (the Plan) by the amount of Appellant's service-connection disability compensation (Veterans' Benefits), holding that the district court did not err. Specifically, the First Circuit held (1) Appellant's Veterans' Benefits fell squarely within the definition of "Compulsory Benefit Act or Law"; (2) that the district court did not err by concluding as a matter of law that Veterans' Benefits unambiguously qualify as a form of "Other Income Benefit" covered by the Plan's offset provision; and (3) the district court did not err by rejecting as a matter of law Appellant's assertion that Sun Life's offset determination was motivated, at least in part, by Appellant's military service in violation of the Uniformed Services Employment and Reemployment Rights Act. View "Martinez v. Sun Life Assurance Co. of Canada" on Justia Law

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The First Circuit affirmed the decision of the district court granting summary judgment to Defendants on Plaintiff's Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621, and relinquishing supplemental jurisdiction over his claims under Puerto Rico law, holding that a reasonable jury could not find pretext discrimination and that the district court did not abuse its discretion in declining to exercise continued supplemental jurisdiction. In his complaint, Plaintiff alleged that he was fired on account of his age. The district court concluded that Plaintiff failed to put forth evidence that he was complying with the legitimate job performance expectations for his position and therefore failed to make a prima facie showing of discrimination. The First Circuit affirmed, holding (1) assuming that Plaintiff established a prima facie case, Plaintiff failed to show that his poor performance reviews were pretextual; and (2) while retention was an option, the district court did not exceed the boundary of its discretion in declining to exercise continued supplemental jurisdiction. View "Santana-Vargas v. Banco Santander Puerto Rico" on Justia Law

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The First Circuit affirmed the decision of the district court granting summary judgment to the Administrator of the United States General Services Administration (GSA) and dismissing the discrimination and retaliation claim brought by Plaintiff, a former employee of that agency, holding that summary judgment was properly granted on Plaintiff's claims. Specifically, the Court held (1) the district court did not err in granting summary judgment to the GSA on Plaintiff's sex discrimination claims under Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq.; (2) the district court did not err in granting summary judgment to the GSA on Plaintiff's age discrimination claims under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621 et seq.; and (3) Plaintiff's retaliation claims under Title VII and the ADEA also lacked merit. View "Paul v. Murphy" on Justia Law

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The First Circuit affirmed the district court's order dismissing Plaintiff's disability discrimination and failure to accommodate claims on summary judgment, holding that the district court did not abuse its discretion in partially striking Plaintiff's affidavit submitted in support of his opposition to Defendant's motion for summary judgment and that Plaintiff failed to establish a prima facie case of disability discrimination or a claim for failure to accommodate. Specifically, the Court held (1) the district court did not clearly abuse its discretion in striking Plaintiff's inconsistent statements in his affidavit; and (2) the district court properly granted summary judgment because Plaintiff failed to establish a prima facie case of disability discrimination and that Plaintiff's failure to accommodate claims failed on the merits. View "Flaherty v. Entergy Nuclear Operations, Inc." on Justia Law

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The First Circuit affirmed the decision of the district court granting the Attorney General's motion to dismiss Plaintiffs' complaint alleging that the "Au Pair Program" at issue in this case impliedly preempts Massachusetts from requiring host families to comply with its wage and hour laws and ordering Plaintiff's case dismissed, holding that the district court did not err or abuse its discretion. The United States Department of State (DOS) administers the Au Pair Program, through which foreign nationals may obtain a special visa then provide in-home childcare services to host families in the United States while the foreign nationals pursue post-secondary school studies. Plaintiffs, a DOS-approved private placement agency based on Massachusetts, and two individuals, brought this lawsuit seeking declaratory and injunctive relief and alleging that state law measures are preempted insofar as they protect au pair participants by imposing obligations on their host families as their employer that may be enforced against the host families. The district court found that there was no preemption. The First Circuit affirmed, holding that Plaintiffs did not meet their burden to establish field or conflict preemption. View "Capron v. Massachusetts Attorney General" on Justia Law

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The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Defendant and dismissing Plaintiff's claims that Defendant terminated his employment to deprive him of a significant equity incentive, holding that no reasonable factfinder could conclude that when Defendant fired Plaintiff it deprived Plaintiff of compensation that he had already earned by virtue of his past services. In his complaint, Plaintiff alleged that Defendant breached the implied covenant of good faith and fair dealing. The district court granted summary judgment for Defendant, concluding that Plaintiff had not presented sufficient evidence to show that, at the time of his discharge, Plaintiff was deprived of compensation that he had fairly earned and legitimately expected by virtue of his past work. The First Circuit affirmed, holding that the district court did not err in entering summary judgment in favor of Defendant. View "Suzuki v. Abiomed, Inc." on Justia Law

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The First Circuit affirmed the decision of the district court granting Defendants' motion to dismiss Plaintiff's complaint seeking to invalidate a Maine statute that governs collective bargaining between the state's university system and its faculty on the ground that the statute violates the First Amendment, holding that the statute is not unconstitutional. Plaintiff, an economics professor at the University of Maine at Machias, brought this action challenging the University of Maine System Labor Relations Act, Me. Stat. tit. 26. 1021-1037. The district court dismissed Plaintiff's suit under Fed. R. Civ. P. 12(b)(6). The First Circuit affirmed, holding (1) section 1025(2)(E) is not properly read to designate the Associated Faculties of the Universities of Maine as Plaintiff's personal representative, as he argued; and (2) the Supreme Court's decision in Minnesota State Board for Community Colleges v. Knight, 465 U.S. 271 (1984), which the Court cited favorably in response to a similar challenge in D'Agostino v. Baker, 812 F.3d 240, disposes of Plaintiff's contention that the distinction between having a union represent a bargaining unit as an entity in collective bargaining and having it represent the employees within the unit individually is immaterial. View "Reisman v. Associated Faculties of the University of Maine" on Justia Law