Justia U.S. 1st Circuit Court of Appeals Opinion SummariesArticles Posted in Labor & Employment Law
Covidien LP v. Esch
In this appeal arising from a contract action, the First Circuit affirmed the judgment of the district court denying Appellants' post-trial request for a declaratory judgment, holding that the district court did not abuse its discretion.Appellants, Covidien LP and Covidien Holding Inc. (collectively Covidien), brought this action against Brady Esche, a former employee, who assigned medical device patent rights to a company he subsequently founded, seeking declaratory judgment to the effect that Esch assign his rights, title, and interest in the patent applications to Covidien. Covidien also alleged that Esch breached his obligations under employment and/or separation agreements he signed. The jury found that Esch breached confidential information and awarded Covidien damages. Covidien subsequently moved for a declaratory judgment asking that Esch be required to assign to Covidien the inventions he subsequently made. The district court denied the request. The First Circuit affirmed, holding that the district court did not abuse its discretion in denying Appellants' post-trial declaratory judgment request. View "Covidien LP v. Esch" on Justia Law
Bosse v. New York Life Insurance Co.
The First Circuit reversed the decision of the district court refusing to enforce arbitration clauses in the employment agreement between New York Life Insurance Company and Ketler Bosse, which expressly required that any disputes about arbitrability be referred to the arbitrator, holding that the district court abused its discretion.After New York Life terminated its business relationship with him Bosse brought this action alleging race discrimination in violation of 42 U.S.C. 1981 and 1985 and other state law claims. New York Life asked the court to compel arbitration and stay or dismiss the lawsuit, but the district court refused. The First Circuit reversed, holding (1) the district court's analysis contravened the Supreme Court's holdings in Henry Schein, Inc. v. Archer & White Sales, Inc., 139 S. Ct. 524 (2019), First Options of Chicago, Inc. v. Kaplan, 514 U.S. 938 (1995) and other cases; and (2) the arbitration clause was clear, unmistakable, and unambiguous and should have been enforced on those terms. View "Bosse v. New York Life Insurance Co." on Justia Law
Puig Martinez v. Novo Nordisk Inc.
The First Circuit affirmed the order of the district court granting summary judgment in favor of Novo Nordisk Inc. and dismissing Plaintiffs' age discrimination claims, holding that the district court did not err.During a global reorganization, Novo Nordisk terminated Plaintiffs from their jobs based in Puerto Rico and did not select Plaintiffs for post-reorganization positions. Plaintiffs brought this complaint alleging that Novo Nordisk violated Puerto Rico's statutes prohibiting age discrimination in employment and penalizing termination without just cause. The district court granted summary judgment in favor of Novo Nordisk on all of Plaintiffs' claims. The First Circuit affirmed, holding that summary judgment was properly granted. View "Puig Martinez v. Novo Nordisk Inc." on Justia Law
Knous v. Broadridge Financial Solutions, Inc.
The First Circuit affirmed the judgment of the district court granting summary judgment in favor of Broadridge Financial Solutions, Inc. and dismissing Plaintiff's lawsuit claiming a violation of the Massachusetts Wage Act, Mass. Gen. Laws ch. 149, 148, 150, holding that the district court did not err.Plaintiff claimed that Broadbridge failed to make timely payment under the Act, arguing that, as a matter of statutory interpretation, the day an employee is discharged from employment under the Wage Act is the day the employee is told to stop performing work for his employer. The district court disagreed. The Supreme Court affirmed, holding that the day of discharge is the time for a final accounting and payment, the day of an employee's official discharge. View "Knous v. Broadridge Financial Solutions, Inc." on Justia Law
Posted in: Labor & Employment Law
Capriole v. Uber Technologies, Inc.
The First Circuit dismissed this appeal from the United States District Court for the District of Massachusetts denying Appellant's first preliminary injunction motion, holding that this Court had no appellate jurisdiction.Appellant filed a class action complaint in the Massachusetts district court under the Class Action Fairness Act, 28 U.S.C. 1332(d)(2) alleging that Uber Technologies, Inc. misclassified him and other drivers as independent contractors instead of employees. Appellant filed a motion for a preliminary injunction requiring Uber to alter its classification. The district court denied the motion. The First Circuit affirmed, holding that, due to the procedural posture of this case, this Court did not have jurisdiction to hear the appeal. View "Capriole v. Uber Technologies, Inc." on Justia Law
Emmanuel v. Handy Technologies, Inc.
The First Circuit affirmed the judgment of the district court granting Handy Technologies, Inc.'s motion to dismiss this putative class action and to compel individual arbitration, holding that the district court did not err in dismissing Maisha Emmanuel's suit.Emmanuel, who worked as a cleaner for Handy Technologies, Inc., brought this complaint on behalf of individuals who had worked for Handy as cleaners, alleging that Handy had misclassified the putative class members as independent contractors rather than employees, in violation of the Fair Labor Standards Act and Mass. Gen. Laws ch. 151, 1. Handy moved to dismiss and compel arbitration, arguing that the Independent Contractor Agreement that Emmanuel signed required arbitration of the claims at issue. The district court granted Handy's motion to compel arbitration and dismissed Emmanuel's putative class action claim. The First Circuit affirmed, holding (1) the district court did not err in ruling that, under Massachusetts law, Emmanuel had entered into an agreement to arbitrate; and (2) Emmanuel's unconscionability-based challenged to the ruling below failed. View "Emmanuel v. Handy Technologies, Inc." on Justia Law
Cuesta-Rojas v. Garland
The First Circuit vacated the judgment of the Board of Immigration Appeals (BIA) affirming the denial of Petitioner's application for asylum, withholding of removal, and protection under the Convention Against Torture (CAT), holding that substantial evidence did not support the BIA's decision.The immigration judge (IJ) determined that Petitioner was not a credible witness and therefore found that he had failed to establish his burden of proof with respect to his application. The BIA dismissed Petitioner's appeal, thus declining to remand the case in light of new evidence submitted for the first time on appeal. The First Circuit vacated the BIA's decision, holding that the IJ's adverse credibility finding was not supportable. View "Cuesta-Rojas v. Garland" on Justia Law
Gonzalez-Bermudez v. Abbott Laboratories P.R. Inc.
The First Circuit affirmed in part and reversed in part the judgment of the district court granting judgment in favor of Plaintiff in this discrimination and retaliation action, holding that Defendant was entitled to judgment as a matter of law in part.Plaintiff filed suit against Abbott Laboratories alleging age discrimination and retaliation under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-34, Puerto Rico Law 100 and Puerto Rico Law 155. A jury found for Plaintiff and awarded $4 million for emotional distress and $250,000 for back pay. The district court entered judgment against Abbott on all counts but reduced the damages to just over $500,000. The First Circuit reversed in part, holding (1) Abbott was entitled to judgment as a matter of law on Plaintiff's ADEA claims and her corresponding claims under Law 100 and Law 115; but (2) Abbott failed to preserve its challenge to a separate finding that Abbott retaliated against Plaintiff for reporting to the State Insurance Fund. View "Gonzalez-Bermudez v. Abbott Laboratories P.R. Inc." on Justia Law
Casco, Inc. v. John Deere Construction & Forestry Co.
The First Circuit affirmed the judgment of the district court dismissing Casco, Inc.'s claim for dolus under Article 1902 of the Puerto Rico Civil Code, P.R. Laws Ann. tit. 31, 3408, awarding relief to Casco on its claims for unjust impairment and unjust termination under Puerto Rico's Dealer Protection Act, P.R. Laws Ann. tit. 10, 278 (Law 75) and granting judgment on John Deere Construction & Forestry Company's counterclaim to recover amounts owed to it by Casco, holding that Casco was not entitled to relief on its allegations of error.Specifically, the First Circuit held (1) the jury's findings of liability against Deere under Law 75 were not unreasonable, and the district court correctly denied Deere's post-judgment motions regarding the Law 75 claims; (2) the district court properly dismissed Casco's dolus claim as not legally viable; (3) the district court correctly granted relief on Deere's counterclaim; and (4) the district court did not abuse its discretion by declining to upset the jury award or order a new trial on damages. View "Casco, Inc. v. John Deere Construction & Forestry Co." on Justia Law
Joseph v. Lincare, Inc.
The First Circuit vacated the order of the district court granting summary judgment in favor of Lincare, Inc. and rejecting Jeffrey Joseph's racial discrimination challenge to the termination of his employment, holding that the district court erred in excluding several documents from the summary judgment record and that Joseph had enough evidence to warrant a trial.On appeal, Joseph argued, among other things, that the district court erred in excluding several documents as unauthenticated hearsay evidence and in granting summary judgment. The First Circuit agreed and remanded the case for further proceedings, holding (1) the district court erred in excluding the documents as "unauthenticated and hearsay evidence," and the error was not harmless; and (2) the record, supplemented with the stricken documents, provides a reasonable basis for a jury finding in Joseph's favor. View "Joseph v. Lincare, Inc." on Justia Law