Justia U.S. 1st Circuit Court of Appeals Opinion SummariesArticles Posted in Labor & Employment Law
Ramos-Santiago v. WHM Carib LLC
The First Circuit affirmed the district court's partial entry of summary judgment in favor of Defendants on Plaintiff's age discrimination claim and his family's derivative tort claims and the denial of Plaintiff's motion for summary judgment, holding that the district court's summary judgment rulings were proper. Plaintiff and five of his family member brought this action under Puerto Rico law against Plaintiff's former employer and its insurance carrier alleging unjust dismissal and age discrimination in employment, his family asserting derivative tort claims arising from the alleged age discrimination. The district court granted summary judgment for Defendants on all but the unjust dismissal claim and denied Plaintiff's cross-motion for summary judgment. The First Circuit affirmed, holding that, under the facts of this case, summary judgment was properly granted. View "Ramos-Santiago v. WHM Carib LLC" on Justia Law
Hoffman-Garcia v. Metrohealth, Inc.
The First Circuit affirmed the judgment of the district court granting judgment as a matter of law to Defendant-employer on Plaintiff’s age discrimination claims and Puerto Rico law claims and granting in part Defendant’s summary judgment motion, holding that there was no error in the proceedings below. After Plaintiff was laid off as part of Defendant’s effort to cut costs, Plaintiff sued the hospital under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-634 and Puerto Rico antidiscrimination and tort law. The district court granted summary judgment in part for Defendant, finding that Defendant had facially legitimate, non-discriminatory grounds to terminate Plaintiff’s position. A jury trial ensued, but at the close of evidence the district court granted Defendant’s motion for judgment as a matter of law. The First Circuit affirmed, holding that there were fatal and uncontradicted defects in Defendant’s prima facie theory of liability as established by the evidence at trial. View "Hoffman-Garcia v. Metrohealth, Inc." on Justia Law
Villeneuve v. Avon Products, Inc.
The First Circuit affirmed the orders of the district court judge’s rulings dismissing Plaintiff’s sexual orientation discrimination claim and granting summary judgment for Defendant on Plaintiff’s unjust discharge and age discrimination claims and awarded Defendant its costs on this appeal, holding that the judge committed no reversible error. In this diversity case governed by Puerto Rico law, the district court judge dismissed Plaintiff’s claims against her former employer on Defendant’s motions to dismiss and for summary judgment. The First Circuit affirmed, holding (1) the judge properly dismissed Plaintiff’s sexual orientation discrimination claim because Plaintiff did not plausibly plead that her firing constituted sexual orientation discrimination; and (2) the judge properly granted summary judgment for Defendant on Plaintiff’s unjust discharge and age discrimination claims. View "Villeneuve v. Avon Products, Inc." on Justia Law
Bekele v. Lyft, Inc.
The First Circuit affirmed the decision of the district court granting Defendant’s motion to dismiss this putative class action in favor of arbitration of Plaintiff’s claim in his individual capacity after concluding that the parties had a valid and enforceable agreement to arbitrate, holding that the arbitration clause was enforceable because it was conscionable under Massachusetts law. Plaintiff drove for Lyft, Inc., the defendant. Plaintiff tapped “I accept” on his iPhone when presented with Lyft’s terms of service agreement, which contained a provision requiring that disputes between the parties be resolved by arbitration. In this putative class action Plaintiff alleged that Lyft misclassified its Massachusetts drivers as independent contractors under the Massachusetts Wage Act. Left removed the case to federal court and moved to dismiss in favor of individual arbitration. The district court granted the motion. The First Circuit affirmed, holding (1) Plaintiff waived his contract-formation argument; and (2) the arbitration clause was not substantively unconscionable and was thus enforceable. View "Bekele v. Lyft, Inc." on Justia Law
Garcia v. Director, Office of Workers’ Compensation Programs, United States Department of Labor
The First Circuit denied Petitioner’s petition for review of the decision of the U.S. Department of Labor Benefits Review Board (Board) affirming an administrative law judge’s (ALJ) denial of attorney’s fees and costs to Appellant, holding that Appellant's request for benefits did not result in a “successful prosecution” under the Longshore and Harbor Workers’ Compensation Act (LHWCA), 33 U.S.C. 901 et seq., so as to warrant an award of attorney’s fees. At a hearing before the ALJ it was undisputed that Appellant was entitled to medical benefits due to his back injury, including for surgery in Puerto Rico. The ALJ stated that Appellant could have the surgery done in New York but would have been responsible for the additional expenses he incurred. Appellant then submitted a request for attorney’s fees on the theory that his claim had been a victory because he obtained his “right to choose” to have the surgery in New York. The ALJ denied the request, determining that Appellant did not gain any additional benefit beyond what he would have received had he not initiated the claim. The Board affirmed. The First Circuit affirmed, holding that Appellant’s request for attorney’s fees and costs was properly denied because he did not secure any additional compensation by filing his claim. View "Garcia v. Director, Office of Workers’ Compensation Programs, United States Department of Labor" on Justia Law
Heagney v. Wong
The First Circuit affirmed in part and reversed in part the decision of the district court entering judgment for Plaintiff on Mass. Gen. Laws ch. 151B and defamation claims against the City of Fitchburg and its mayor and the award of punitive damages, holding that the award of punitive damages was improper and that the district court erred in entering judgment for Plaintiff on the defamation claim. Plaintiff brought this action against the City and its mayor after the mayor decided not to nominate Plaintiff for the position of the City police chief. Plaintiff alleged that the City violated his rights under Chapter 151B by deciding not to hire him because of his failure to disclose a criminal case against him of which he was later acquitted and that the mayor defamed him through statements she made to the media. A jury found for Plaintiff on both claims and awarded punitive damages. The First Circuit held (1) the district court erred in denying Plaintiff’s motion for judgment as a matter of law and for a new trial on Plaintiff’s defamation claim because the statement at issue was not false; (2) the evidence was sufficient with respect to the Chapter 151B claim; and (3) there was insufficient evidence to support the punitive damages award. View "Heagney v. Wong" on Justia Law
Gilbert v. City of Chicopee
The First Circuit affirmed the judgment of the district court dismissing Plaintiff’s claims under 42 U.S.C. 1983 and various state laws, holding that the district court properly dismissed Plaintiff’s claims under Fed. R. Civ. P. 12(b)(6). Plaintiff, a captain in the Chicopee Police Department, brought this action against the City, its police chief and mayor, a fellow police officer, and other defendants, alleging that his First Amendment rights were violated after Defendants improperly targeted him for “speaking out and participating in a government investigation.” The district court dismissed Plaintiff’s claimed under Rule 12(b)(6). The First Circuit affirmed, holding that the district court (1) properly dismissed Plaintiff’s First Amendment claim because al of Plaintiff’s speech was made within the scope of his official duties rather than as a citizen; and (2) did not err in dismissing the state law claims. View "Gilbert v. City of Chicopee" on Justia Law
Miceli v. JetBlue Airways Corp.
The First Circuit affirmed the decision of the district court granting summary judgment in favor of Employer on Plaintiff’s claims alleging handicap discrimination and retaliation under Massachusetts state law, holding that there was no probative evidence of discrimination or retaliation. While Employer maintained that Plaintiff was fired because she violated company policy on unexcused absences, Plaintiff argued in her claim that she was fired because of her disability and that Employer retaliated against her for filing a complaint with the Massachusetts Commission against Discrimination. The district court granted summary judgment in favor of Employer. The First Circuit affirmed, holding that neither of Plaintiff’s claims could survive summary judgment. View "Miceli v. JetBlue Airways Corp." on Justia Law
Roy v. Correct Care Solutions, LLC
The First Circuit reversed in part and affirmed in part the district court’s grant of summary judgment to all Defendants on Plaintiff’s claims of discrimination, unlawful retaliation, and violations of the Equal Protection Clause and the First Amendment, holding that summary judgment was properly granted as to Rodney Bouffard and Troy Ross but improperly granted as to Correct Care Solutions, LLC (CCS) and Maine Department of Corrections (MDOC). Plaintiff was employed by CCS at a MDOC prison. After MDOC revoked Plaintiff’s prison security clearance and CCS terminated Plaintiff’s employment, Plaintiff sued CCS, MDOC, and Bouffard, the warden, and Ross, the deputy warden, bringing claims under the Maine Human Rights Act (MHRA) and 42 U.S.C. 1983. The district court granted summary judgment for Defendants on all claims. The First Circuit held (1) a reasonable jury could find that Plaintiff’s work environment was hostile; (2) summary judgment was properly granted in favor of the warden and deputy warden based on qualified immunity; (3) an employer can be liable for a hostile work environment created by non-employees as long as the employer knew of the harassment and failed to take reasonable steps to address it; and (4) summary judgment was improper was to MDOC and CCS. View "Roy v. Correct Care Solutions, LLC" on Justia Law
Torres v. Bella Vista Hospital, Inc.
The First Circuit affirmed the judgment of the district court rejecting Plaintiffs’ motion to set aside an earlier federal district court decision granting summary judgment in favor of Defendants on Plaintiffs’ claims seeking to recover lost benefits from their former employer, holding that the district court properly found that the judgment was not procured by “fraud on the court.” Plaintiffs claimed in their motion that various defendants made deliberate material misstatements in their answers and various sworn statements. The district court determined that the allegations did not warrant vacating the judgment. The First Circuit affirmed, holding that, even assuming the truth of Plaintiffs’ allegations, the allegations were not sufficient to constitute “fraud upon the court.” View "Torres v. Bella Vista Hospital, Inc." on Justia Law