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

In this complaint by a former employee alleging violations of the American Disabilities Act (ADA) there was no error in the district court’s jury instructions.Plaintiff filed a complaint against his former employer alleging that his termination violated the ADA. Plaintiff was fired from his job in the Town of Brookline’s Department of Public Works for unjustified absences from work and failing to provide adequate documentation for his use of sick leave. In his complaint, Plaintiff alleged that he had been suffering from sleep apnea and that the Town violated the ADA by discriminating against him on the basis of his sleep apnea disability, denying him a reasonable accommodation, and failing to engage in an interactive dialogue as required under the ADA. The First Circuit affirmed, holding that, contrary to Plaintiff’s contentions, the district court did not err in its instructions to the jury. View "McDonald v. Town of Brookline, Massachusetts" on Justia Law

Plaintiff filed suit against the Secretary of Defense alleging discrimination on the basis of sex in violation of Title VII, 42 U.S.C. 2000e-2000e-17 based on his unsuccessful application for two teaching positions at an elementary school run by the Department of Defense. The district court granted summary judgment for Defendant. The First Circuit affirmed, holding that Plaintiff failed to offer any evidence establishing a genuine issue of material fact regarding whether Defendant’s proffered reason for not hiring Plaintiff was pretextual, and therefore, Plaintiff could not succeed in his challenge to the district court’s ruling dismissing his claim on summary judgment. View "Cruz v. Mattis" on Justia Law

This appeals arose from a dispute over whether application of the Massachusetts Earned Sick Time Law (MESTL), 2014 Mass. Legit. Serv. ch. 505 (West), to interstate rail carriers that employ workers in Massachusetts is preempted by the Railroad Unemployment Insurance Act (RUIA), 45 U.S.C. 351-369. The First Circuit affirmed in part and vacated in part the judgment of the district court, holding that the RUIA, preempts some parts of the MESTL as applied to employees of interstate rail carriers. However, this case must be remanded to determine whether other parts of the MESTL that are not within the preemptive reach of the RUIA and are not otherwise preempted by other federal law might still be applied to interstate rail carriers. View "CSX Transportation, Inc. v. Healey" on Justia Law

The First Circuit declined enforcement of the National Labor Relations Board’s (NLRB) order requiring 1199 SEIU United Healthcare Workers East (the Union) and Good Samaritan Medical Center to reinstate Camille Legley with back pay and rescind a workplace civility policy, holding that there was not substantial evidence on the record as a whole that Legley was discharged because of his protected conduct.Legley, a probationary employee hired by Good Samaritan, questioned a union delegate’s alleged remark during an orientation training that he had to join the Union in order to work at Good Samaritan. Good Samaritan terminated Legley’s employment the following day, claiming that Legley’s conduct had violated its civility policy. The NLRB found that the Union caused Good Samaritan to discharge Legally because of his protected conduct. In denying enforcement of the NLRB’s order the First Circuit held that the NLRB’s decision ignored a portion of the record and could not survive review under the substantial evidence standard. View "Good Samaritan Medical Center v. National Labor Relations Board" on Justia Law

The First Circuit affirmed the district court’s rejection of Appellant’s claims that she, among other things, suffered discrimination in violation of the Americans with Disabilities Act (ADA) and its Massachusetts state-law corollary when Defendants failed to accommodate her request for transfer to another position in the Plymouth Police Department after she suffered an on-the-job injury. The district court concluded that Appellant failed to raise a genuine issues of material fact regarding her discrimination claims. The First Circuit affirmed, holding (1) the district court correctly entered summary judgment on Appellant’s handicap discrimination claims and gender discrimination claim; and (2) even if the court were able to glean an ADA retaliation claim from Appellant’s complaint, Appellant waived it during summary judgment proceedings. View "Audette v. Town of Plymouth, Mass." on Justia Law

A plaintiff may not bring claims for damages under 42 U.S.C. 1981 against state actors, including defendants sued in their official capacities as government officials.The First Circuit affirmed the district court’s dismissal of Plaintiff's section 1981 claims against employees of the City of Boston. Plaintiff, who represented the estate of her late father, challenged her father’s termination from his employment with the Department of Public Works. The district court dismissed the section 1981 claims, concluding that section 1981 provides no implied private right of action for damages against state actors. The First Circuit affirmed, holding that Jett v. Dallas Independent School District compelled the result reached by the district court. View "Buntin v. City of Boston" on Justia Law

The First Circuit answered two questions of first impression regarding the Federal Arbitration Act (FAA) by holding (1) in a case where a federal district court is confronted with a motion to compel arbitration under the FAA and the parties have delegated questions of arbitrability to the arbitrator, the applicability of the FAA is a threshold question for the court to determine before compelling arbitration under the FAA; and (2) a provision of the FAA that exempts contracts of employment of transportation workers from the FAA’s coverage applies to a transportation-worker agreement that purports to establish an independent-contractor relationship. Accordingly, the First Circuit affirmed the district court’s order denying the motion to compel arbitration and dismissed this appeal for lack of appellate jurisdiction. View "Oliveira v. New Prime, Inc." on Justia Law

Plaintiff appealed the district court’s grant of summary judgment in favor of her former employer, AstraZeneca Pharmaceutical LP, on Plaintiff’s claims that AstraZeneca violated the Americans with Disabilities Act (ADA) and several provisions of Puerto Rico law. Plaintiff attempted to persuade the First Circuit that there existed several material factual disputes in this case. The First Circuit affirmed the summary judgment, holding (1) AstraZeneca was entitled to summary judgment on both Plaintiff’s ADA disability discrimination claim and her ADA retaliation claim; and (2) Plaintiff failed to shoulder her burden to proceed to trial on her claims sounding in Puerto Rico law. View "Delgado-Echevarria v. AstraZeneca Pharmaceutical LP" on Justia Law

Pan Am Railways, Inc. brought charges of dishonesty and insubordination and threats of dismissal against Jason Raye, an injured employee who had filed a complaint with the Occupational Safety and Health Administration (OSHA) under the Federal Railroad Safety Act (FRSA). Raye then filed an amended complaint to OSHA accusing Pan Am of violating the FRSA for filing his original OSHA complaint. OSHA concluded that Pan Am had unlawfully retaliated against Raye for bringing charges after Raye had filed his original OSHA complaint. An administrative law judge (ALJ) rejected Pan Am’s affirmative defense and awarded $250,000 in punitive damages, the maximum amount that the FRSA allows. The Department of Labor’s Administrative Review Board affirmed. The First Circuit denied Pan Am’s petition for review, holding (1) the ALJ did not err in rejecting Pan Am’s affirmative defense that it would have charged Raye with dishonesty even absent his protected activity; and (2) there was no abuse of discretion in the ALJ’s punitive damages award. View "Pan Am Railways, Inc. v. U.S. Department of Labor" on Justia Law

Plaintiff filed a complaint against Defendants, her former employer and the Commonwealth of Massachusetts, alleging that Defendants violated her rights under the Family and Medical Leave Act (FMLA), discriminated against her on the basis of a covered impairment, illegally required her to participate in prohibited political activity, and wrongfully terminated her with actual malice. The district court granted Defendants’ motion to dismiss the case under Fed. R. Civ. P. 12(b)(1) and 12(b)(6). Plaintiff appealed the portion of the district court’s order dismissing certain FMLA claims against her former employer under Rule 12(b)(6). The First Circuit affirmed, holding that the facts pleaded in Plaintiff’s complaint did not plausibly allege that her supervisor fired her because she sought leave protected by the FMLA. View "Germanowski v. Harris" on Justia Law