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

Articles Posted in Labor & Employment Law
by
The First Circuit affirmed the judgment of the district court dismissing Plaintiff's lawsuit brought against Defendant, the local district attorney, after Plaintiff was terminated from his employment with a police department by the Town Manager in a town in Penobscot County, Maine, holding that dismissal was proper.Plaintiff's complaint against Defendant alleged that Defendant violated his due process rights by failing to provide him with meaningful notice and opportunity to dispute allegations about his misconduct that Defendant made and allegedly sent in a letter to the Department's police chief that led the Town to its decision. The district court dismissed on state law grounds. The First Circuit affirmed on different grounds, holding that Plaintiff failed to state a claim for a due process violation under either the United States or Maine Constitution. View "Roe v. Lynch" on Justia Law

by
The First Circuit resolved a portion of Appellant's appeal in this opinion addressing the district court's grant of summary judgment in favor of the Town of Brookline, Massachusetts, the Brookeline Board of Selectmen, the Town's counsel and Human Resources director, and select members of the board, holding that the summary judgment is affirmed in part, vacated in part and remanded for further proceedings.Plaintiff, black man, brought this suit alleging that during his employment as a firefighter, he had been discriminated against and retaliated against for reporting discriminatory conduct. The district court entered summary judgment in favor of Defendants. The First Circuit affirmed in part and vacated in part the summary judgment granted in favor of Defendants, holding that the district court erred in granting summary judgment as to Plaintiff's retaliation claims under 42 U.S.C. 1983 against the Town, the Board, and certain members of the Board, in their personal and official capacities. The Court then remanded the case for further proceedings. View "Alston v. Town of Brookline, Mass." on Justia Law

by
The First Circuit affirmed the judgment of the district court granting summary judgment to Defendant on Plaintiff's challenge to an arbitration award in favor of Defendant, holding that the district court did not err.After Plaintiff was summarily dismissed from his employment he challenged his dismissal by filing a complaint and submitting the grievance to arbitration pursuant to his union's collective bargaining agreement with the union. The arbitrator issued an arbitral award dismissing Plaintiff's complaint. The district court dismissed Plaintiff's petition for judicial review. The First Circuit affirmed, holding that the district court did not err in finding that the arbitrator's ruling was not in manifest disregard of the law. View "Torres-Burgos v. Crowley Liner Service, Inc." on Justia Law

by
The First Circuit affirmed the district court's grant of summary judgment in favor of Defendants - the City of Framingham and Chief of the Framingham Police Department - in this Garcetti speech-retaliation and Massachusetts Whistleblower Act action brought by Plaintiff, an FPD detective, holding that the district court did not err.Plaintiff brought this lawsuit challenging allegedly retaliatory employment actions, including a five-day suspension and his being put on paid administrative leave during an investigation. The district court granted summary judgment for Defendants, concluding that Defendants met their burden to show that the adverse employment decisions would have occurred despite Plaintiff's protected speech. The First Circuit affirmed, holding that Defendants met their burden to prove an independent non-retaliatory basis for Plaintiff's discipline. View "Gutwill v. City of Framingham" on Justia Law

by
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

by
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

by
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

by
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

by
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

by
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