Justia U.S. 1st Circuit Court of Appeals Opinion SummariesArticles Posted in Labor & Employment Law
Modeski v. Summit Retail Solutions, Inc.
The First Circuit affirmed the judgment of the district court granting summary judgment ruling in favor of Defendant, a marketing company, holding that district court correctly concluded that Plaintiffs, who worked as "brand representatives" for Defendant, qualified as outside salespeople under governing law.Plaintiffs sued Defendant on behalf of themselves and other brand representatives, seeking to recover unpaid overtime wages under the Fair Labor Standards Act (FLSA) and analogous state wage laws, alleging that they failed to receiver overtime wages for working over forty hours per week. The district court granted summary judgment in favor of Defendant, concluding that Plaintiffs fell within the FLSA's outside sales exemption and thus were not entitled to overtime compensation. The First Circuit affirmed, holding that Plaintiffs fell within the outside sales exemption, 29 U.S.C. 213(a)(1). View "Modeski v. Summit Retail Solutions, Inc." on Justia Law
Reyes-Caparros v. Garland
The First Circuit affirmed the judgment of the district court rejecting the jury's advisory verdict in this case, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff, a former intelligence specialist, sued his former employer, the United States Attorney's Office for the District of Puerto Rico pursuant to Title VII of the Civil Rights Act, alleging discriminatory retaliation and constructive discharge resulting from a hostile work environment. After a jury returned a verdict on liability for retaliation and awarding the statutory maximum in damages, the district court charged the jury to return an advisory verdict on the issue of damages for constructive discharge. The jury returned a verdict in favor of Plaintiff as to that issue, and thereafter, Plaintiff sought a judgment of front and back pay. The district court rejected the jury's advisory verdict, concluding that the verdict was not supported by the evidence, that Plaintiff was not constructively discharged, and that Plaintiff was not entitled to front or back pay. The First Circuit affirmed, holding (1) Plaintiff waived his objection to the district court's decision to submit the constructive discharge issue to an advisory jury; and (2) the district court's factual findings were not clearly erroneous. View "Reyes-Caparros v. Garland" on Justia Law
Fincher v. Town of Brookline
The First Circuit affirmed the decision of the district court granting summary judgment in favor of the Town of Brookline, Massachusetts on Plaintiff's claim brought pursuant to 42 U.S.C. 1983 alleging discrimination on the basis of race in violation of the Fourteenth Amendment's Equal Protection Clause, holding that the district court did not err in granting summary judgment.Plaintiff brought this action alleging that Brookline violated his equal protection rights in terminating his employment. The district court granted summary judgment in favor of the Town. The First Circuit affirmed, holding that Plaintiff's evidence failed to establish that the Town's proffered reasons for failing to accommodate and then dismissing Plaintiff were a pretext for race discrimination. View "Fincher v. Town of Brookline" on Justia Law
Johnson Controls Security Solutions, LLC v. Int’l Brotherhood of Electrical Workers, Local 103
The First Circuit reversed the judgment of the district court in this dispute between the International Brotherhood of Electrical Workers, Local 103 (the Union) and Johnson Controls Security Solutions, LLC over Johnson Controls' compliance with the terms of the parties' collective bargaining agreement (CBA), holding that the district court erred by failing to order arbitration as called for by a clause in the CBA.Johnson Controls' Norwood, Massachusetts facility entered into a CBA with the Union, a labor organization that represented employees of the company, that contained an arbitration clause. The Union filed a grievance concerning Johnson Controls' reduction in its matching contribution to the company's 401(k) plan, which Johnson Controls denied. When the Union filed a demand for arbitration Johnson Controls brought this lawsuit seeking a declaratory judgment that the dispute was not arbitrable under the CBA. The district court concluded that the dispute was not arbitrable. The First Circuit reversed, holding that nothing in the record showed that the parties intended to exclude this type of dispute from the scope of the arbitration clause. View "Johnson Controls Security Solutions, LLC v. Int'l Brotherhood of Electrical Workers, Local 103" on Justia Law
Waters v. Day & Zimmermann NPS, Inc.
The First Circuit affirmed the decision of the district court denying Day & Zimmerman's (D&Z) motion to dismiss this lawsuit for lack of personal jurisdiction, holding that there was no error.Plaintiff filed suit in the United States District Court for the District of Massachusetts against D&Z, a company incorporated in Delaware that maintained its principal place of business in Pennsylvania, seeking overtime wages pursuant to section 216(b) of the Fair Labor Standards Act, 29 U.S.C. 201-219. Plaintiff alleged that D&Z failed to pay him and other similarly situated employees and former employees their FLSA-required overtime wages. D&Z moved to dismiss for lack of personal jurisdiction, citing Bristol-Myers Squibb v. Superior Court of California (BMS), 137 S. Ct. 1773 (2017) and claiming that the claims subject to the motion to dismiss could not be brought in a Massachusetts federal court. The district court denied the motion, thus declining to extend BMS's personal jurisdiction requirements to FLSA cases brought in federal court. The First Circuit affirmed, holding that the district court did not err in denying D&X's motion to dismiss the nonresident opt-in claims for lack of personal jurisdiction. View "Waters v. Day & Zimmermann NPS, Inc." on Justia Law
Perez-Sosa v. Garland
The First Circuit affirmed all but two of the district court's rulings in this dispute over the amount of attorneys' fees due to Plaintiff, the prevailing party in the underlying employment discrimination dispute, and vacated the attorneys' fees award, holding that the district court erred in part.Plaintiff, the former head of the appellate practice of the United States Attorney's Office for the District of Puerto Rico, alleging discrimination and retaliation under Title VII. The parties negotiated a settlement, under which Plaintiff received a lump-sum payment of $450,000 plus reasonable attorneys' fees. The district court awarded Plaintiff a total of $170,332 in attorneys' fees. The First Circuit affirmed all but two of the district court's rulings, which the court reversed, and vacated the fee award, holding (1) the district court erred in concluding that time expended in settlement negotiations and time expended in performing work that implicated other cases, distinct but related, must be categorically excluded from the fee award; and (2) Plaintiff's five remaining challenges were without merit. View "Perez-Sosa v. Garland" on Justia Law
Pineda v. Skinner Services, Inc.
The First Circuit affirmed the district court's entry of a preliminary injunction against Skinner Services, Inc., and four individuals (collectively, Skinner) to prevent Skinner's acceleration of efforts to insulate their individual and corporate assets to avoid a meaningful recovery for Plaintiffs in the underlying action, holding that the district court did not abuse its discretion.Plaintiffs, former low-wage employees of Skinner Demolition, sued Skinner on behalf of themselves and other similarly situated workers for unpaid wages. The court entered a protective order to prohibit Skinner from retaliating against any workers who participated in or assisted in the litigation. Skinner was subsequently held in contempt for violating the protective order. In the meantime, Skinner created four separate entities, which Plaintiffs alleged were used to dissipate or hide assets. The district court granted Plaintiffs' ensuing motion for injunctive relief, finding that Skinner likely had violated state and federal wage laws and was trying to transfer assets from its laborers' reach. The First Circuit affirmed, holding that the district court (1) had the authority to enter the preliminary injunction; and (2) did not abuse its discretion. View "Pineda v. Skinner Services, Inc." on Justia Law
Forbes v. BB&S Acquisition Corp.
The First Circuit affirmed the district court's entry of summary judgment in favor of BB&S Acquisition Corp. in this case brought by the personal representative of the estate of George Forbes, who was killed in an accident allegedly caused by Wiley Hooks, holding that the district court did not err.Before the accident, Hooks, the employee of Gregory Trucking, had delivered lumber to BB&S, which contracted with Gregory Trucking to transport a separate load of its treated lumber. After Hooks completed Gregory Trucking's contractual obligation to BB&S, Gregory Trucking hit a pick-up truck driven by George Forbes. Plaintiff brought this suit alleging that BB&S had negligently selected Gregory Trucking as an independent contractor to transport its lumber and that BB&S was the "statutory employer" of Hooks under 49 C.F.R. 390.5. The district court granted summary judgment for BB&S. The First Circuit affirmed, holding that the district court did not err in (1) concluding that BB&S could not be liable under Massachusetts common law for the actions of an independent contractor that occurred after the completion of the job; and (2) concluding that BB&S was not the "statutory employer" of Hooks. View "Forbes v. BB&S Acquisition Corp." on Justia Law
Diaz-Baez v. Alicea-Vasallo
The First Circuit affirmed the decision of the district court entering summary judgment against the political discrimination claims brought by Plaintiffs, former Automobile Accident Compensation Administration (AACA) employees, against Defendants, the AACA and its former executive director, holding that the district court did not err.Plaintiffs were laid off pursuant to an agency-wide, facially-neutral layoff plan based on seniority. Plaintiffs brought this action under 42 U.S.C. 1983 alleging violations of their rights under the First, Fifth, and Fourteenth Amendments, along with violations of Puerto Rico law. The district court adopted Puerto Rico court decisions concluding that it was the Board of Directors, and not the Executive Director, that was responsible for the layoff plan, and then granted summary judgment for Defendants. The First Circuit affirmed, holding that the district court correctly concluded that Plaintiffs were barred from arguing in this litigation that the executive director was responsible for the layoff plan. View "Diaz-Baez v. Alicea-Vasallo" on Justia Law
Together Employees v. Mass General Brigham Inc.
In this vaccination dispute, the First Circuit denied the motion brought by Appellants seeking an injunction pending appeal, holding that Appellants were not entitled to the injunction.Appellants, eight employees of Mass General Brigham, Inc. (MGB), challenged MGB's application of its mandatory vaccination policy to them individually. The policy was issued in June 2021 requiring all MGB employees to be vaccinated against COVID-19 unless they qualified for a medical or religious exemption. After Appellants' requests for exemptions were denied and they still refused to get vaccinated, MGB placed them on unpaid leave. Appellants sued under Title VII of the Civil Rights Act and the Americans with Disabilities Act, arguing that MGB unlawfully denied their individual exemption requests. The district court denied Appellants' motion for a preliminary injunction, which would have required Appellants' reinstatement from unpaid leave status. The First Circuit denied Appellants' motion for injunction pending appeal, holding that adequate legal remedies foreclosed injunctive relief. View "Together Employees v. Mass General Brigham Inc." on Justia Law