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

Plaintiffs, a group of construction-industry employers’ associations and employers, sought relief from a broad category of enforcement actions that may be brought under the Massachusetts Earned Sick Time Law (ESTL). Plaintiffs did so before any action to enforce the ESTL had been filed against any employer who was a party to a collective bargaining agreement (CBA). Plaintiffs argued that the ESTL was preempted by section 301 of the Labor-Management Relations Act with respect to those employers in the state who are parties to CBAs. Plaintiffs sought a judgment, inter alia, prohibiting the Massachusetts Attorney General from granting private rights of action to employees who are members of collective bargaining units. The district court dismissed the suit for failure to state a claim insofar as it constituted a facial, preemption-based challenge to the ESTL, and for lack of jurisdiction insofar as it represented an as-applied preemption-based challenge that was not ripe for adjudication. The First Circuit dismissed the suit for want of jurisdiction, holding that Plaintiffs’ request for pre-enforcement relief was not ripe for adjudication. View "Labor Relations Division of Construction Industries of Massachusetts, Inc. v. Healey" on Justia Law

Plaintiff, an African-American, filed an employment discrimination case against Amtrak, his employer, alleging that his opportunities for overtime were reduced because of his race and that he was subjected to a hostile work environment. The district court granted summary judgment in favor of Amtrak. The First Circuit affirmed, holding (1) Plaintiff failed to meet his initial burden of establishing a prima facie case of disparate treatment discrimination; and (2) even if Plaintiff’s complaints rose to the level of a hostile work environment, Plaintiff failed to demonstrate that he was subjected to any complained-of actions because of his race. View "Garmon v. National Railroad Passenger Corp." on Justia Law

Plaintiff filed a complaint against his employer, the United States Postal Service (USPS), and his supervisor, Michael King, (together, Defendants), alleging that Defendants terminated him from the Brookline, Massachusetts Post Office in retaliation for taking Family Medical Leave Act (FMLA) leave. Appellant alleged FMLA interference and FMLA retaliation in violation of 29 U.S.C. 2615, among other claims. The district court granted summary judgment on all claims with the exception of the FMLA retaliation claim. After a bench trial, the district court entered judgment for Defendants, concluding that Defendants could not have acted with retaliatory animus because King, as the USPS decisionmaker, lacked the requisite knowledge that Plaintiff’s leave was protected under the FMLA. The First Circuit affirmed, holding that the district court properly found that King lacked the requisite knowledge necessary to hold to hold him liable for retaliation in violation of the FMLA. View "Chase v. United States Postal Service" on Justia Law

Appellant, an officer with the Puerto Rico Police Department (PRPD), filed an employment discrimination claim against the Commonwealth of Puerto Rico, the PRPD, and several of her coworkers, alleging violations of various federal and Puerto Rico statutes. Appellant sought compensatory and punitive damages and an injunction barring the PRPD from further incrimination. The district court granted summary judgment for Defendants on all of Appellant’s claims. The First Circuit affirmed without reaching the merits of Appellant’s claims, holding that Appellant failed to adhere to procedural requirements relating to the dispositions of a magistrate judge as set forth by Fed. R. Civ. P. 72(b) and Puerto Rico Local Rule 72(d). View "Santos-Santos v. Torres-Centeno" on Justia Law

The Federal Motor Carrier Safety Administration (FMSCA) maintains a database of inspection history and safety records relating to commercial motor vehicle operators. Appellants, a group of commercial motor vehicle operators, brought suit against the FMSCA and the Department of Transportation, arguing that the potential disclosure to employers of “non-serious” driver-related safety records contained in the database violates the Privacy Act. The district court granted the FMCSA’s motion to dismiss for failure to state a claim, concluding that 49 U.S.C. 31150 was ambiguous as to the agency’s authority to include non-serious driver-related safety violations in the database and, further, that the agency’s interpretation of section 31150 was a reasonable and permissible construction of the statute and was entitled to Chevron deference. The First Circuit affirmed, holding (1) section 31150 is ambiguous as to the question of non-serious driver-related safety violations; and (2) the agency’s interpretation of the statute is not arbitrary, capricious, or manifestly contrary to the statute. View "Flock v. United States Department of Transportation" on Justia Law

Plaintiff, an Army veteran, began working as a probationary patrol officer for the Billerica Police Department in 2009. Later that year, the town manager terminated Plaintiff’s employment. Plaintiff subsequently filed this action against the Town of Billerica and the chief of the police department under the Uniform Services Employment and Reemployment Rights Act, arguing that his status as veteran was a substantial or motivating factor in Defendants’ decision to terminate him. The district court entered judgment in favor of Defendants. Plaintiff appealed, identifying three evidentiary errors that he argued warranted a retrial. The First Circuit affirmed, holding that the challenged evidentiary rulings did not warrant a new trial. View "Angiuoni v. Town of Billerica" on Justia Law

Plaintiff - a former police officer with the City of Quincy, Massachusetts - brought this action against the City, its chief of police, and a police captain, (collectively, Appellees), alleging, among other claims, that Appellees retaliated against him for exercising his First Amendment rights by making statements to various news organizations regarding a dog ordinance issue. The district court granted summary judgment in favor of Appellees. The First Circuit affirmed, holding (1) Plaintiff failed to proffer sufficient facts to survive a motion for summary judgment on his 42 U.S.C. 1983 claim; (2) Plaintiff’s Massachusetts Civil Rights Act claim also failed at the summary judgment stage; and (3) Plaintiff’s defamation claim was properly subjected to summary judgment. View "McGunigle v. City of Quincy" on Justia Law

Plaintiffs, former employees of the Boulevard Motel Corporation, filed separate complaints alleging that Boulevard filed them in violation of the Maine Human Rights Act (MHRA) and the Maine Whistleblowers’ Protection Act (MWPA). The district court granted summary judgment in favor of Boulevard, concluding that a “job duties exception” applied under both the MWPA and the MHRA. After Plaintiffs filed their appeals, the First Circuit issued a decision in Harrison v. Granite Bay Care, Inc., in which the Court held that no “broad-based job duties exception” applied under the MWPA. The First Circuit reversed after both parties conceded that no “job duties exception” exists under either the MWPA or, by implication, the MHRA, holding that no other grounds supported the order granting summary judgment. View "Pippin v. Boulevard Motel Corp." on Justia Law

Plaintiffs, two high-profile medical researchers that held faculty appointments at Harvard Medical School and were intimately involved with a research laboratory at Brigham and Women’s Hospital, were investigated for alleged research misconduct. Responding to allegations that Plaintiffs used manipulated research data in articles reporting on studies supported by government funds, Harvard and Brigham triggered a unique federal statutory and regulatory scheme. Without awaiting the outcome of the administrative proceedings, Plaintiffs filed suit in federal court against the institutional defendants, alleging, inter alia, tortious interference with business relations, invasion of privacy, and unfair and deceptive business practices. The district court dismissed the action, concluding that the suit was premature because Plaintiffs had not exhausted their administrative remedies. The First Circuit affirmed as modified, holding (1) the district court correctly applied the doctrine of administrative exhaustion; but (2) on remand, the district court is directed to convert its order of dismissal to an order staying the case pending the timely resolution of administrative proceedings. View "Anversa v. Partners Healthcare Sys., Inc." on Justia Law

Plaintiffs, a putative class of unionized “visiting” nurses, sued their employer - Baystate Visiting Nurse association & Hospice, Inc. and Baystate Health, Inc. (collectively, “Baystate”) - in state court for unpaid wages and overtime pay. Plaintiffs conceded that they were subject to the terms of a collective bargaining agreement (CBA) between the union and Baystate. Baystate removed this action to federal court, citing the doctrine of complete preemption, under which claims requiring interpretation of a CBA are reclassified as federal claims. The district court denied Plaintiffs’ motion to remand, concluding that complete preemption applied. The district court then granted Defendants’ motion for judgment on the pleadings and dismissed Plaintiffs’ claims. The First Circuit affirmed, holding (1) resolving one of the claims would require a court to interpret the CBA, and therefore, the claim was completely preempted, and the entire action was removable to federal court; and (2) the CBA required Plaintiffs to raise their wage claims through the grievance procedure, and therefore, the district court properly entered judgment on the pleadings. View "Rueli v. Baystate Health, Inc." on Justia Law