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

Plaintiffs, two former managers of Dunkin’ Donuts stores in Massachusetts, filed this action claiming that they were improperly denied overtime pay under the Fair Labor Standards Act (FLSA). The defendant employers moved for summary judgment. The magistrate judge recommended that the motion be denied, finding a genuine issue of material fact as to whether Plaintiffs were “bona fide executive[s]” excluded from the FLSA’s overtime pay requirement. The district rejected the recommendation of the magistrate judge and granted summary judgment for Defendants. The First Circuit reversed, holding that a reasonable fact-finder could conclude that Defendants failed to meet their burden of showing that Plaintiffs fell within the “bona fide executive” exception to the FLSA’s overtime pay requirement. View "Marzuq v. Cadete Enters., Inc." on Justia Law

Plaintiff was formerly employed by the Civilian Health Promotion Services Program at Hanscom Air Force Base in Bedford, Massachusetts. After the government contractor that employed Plaintiff terminated her employment, Plaintiff filed this lawsuit against the government contractor that employed her, her supervisor, and several government agencies and officials that Plaintiff believed were involved in her termination. Plaintiff asserted a claim under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics for violation of her First Amendment rights and a claim of gender discrimination under Title VII. Plaintiff’s Bivens claims was dismissed, and summary judgment was granted against Plaintiff on her Title VII claim. The First Circuit affirmed, holding (1) Plaintiff’s Bivens claim failed to plausibly demonstrate her right to recover against any of the defendants it named, and therefore, its dismissal was proper; and (2) the entry of summary judgment against Plaintiff on her Title VII claim was proper. View "Casey v. Dep’t of Defense" on Justia Law

Plaintiff filed suit against officials at the University of Massachusetts at Dartmouth after the university had commenced termination proceedings against him, alleging, inter alia, claims under 42 U.S.C. 1983 for violations of his First and Fourteenth Amendment rights. Plaintiff then filed a second amended complaint along with an amended motion for preliminary injunction requesting that the termination proceedings be halted and Plaintiff be reinstated to his position. Defendants moved to dismiss the amended complaint. The district court granted in part and denied in part the motion to dismiss and sua sponte combined the motion for preliminary injunction with a trial on the merits. The university subsequently terminated Plaintiff. During the pendency of Plaintiff’s interlocutory appeal of the district court’s order combining the preliminary injunction hearing with the trial, the district court proceeded with the case. The First Circuit dismissed the appeal, holding that the Court had no jurisdiction over the underlying decision to consolidate the motion for preliminary injunction with trial. Therefore, the Court also lacked jurisdiction over the district court’s denials of Plaintiff’s motions to reconsider its order. View "Nwaubani v. Grossman" on Justia Law

In 2008, Employee was fired from his employment with Employer on the grounds that Employee failed to “meet job performance standards.” Employee subsequently sued Employer, claiming that Employer did not have cause to fire him. The district court dismissed the complaint for failure to state a claim. Defendant appealed the dismissal of his claim under section 301 of the Labor Management Relations Act (LMRA) for breach of a Collective Bargaining Agreement. The district court concluded that the only way Employee could bring his LMRA claim against Employer was by bringing a hybrid claim, one that alleged breach of contract by the Hospital as well as breach of the duty of fair representation by Employee’s union. The court concluded that because Employee did not bring a hybrid claim he was barred from bringing his LMRA claim. The court also concluded that even if Employee’s complaint could be construed as bringing a hybrid claim, the complaint was filed outside the six-month statute of limitations for hybrid claims. The First Circuit reversed, holding that Employee was not required to bring a hybrid claim, and therefore, the six-year statute of limitations for breach of contract claims applied. View "DeGrandis v. Children's Hospital Boston" on Justia Law

Plaintiffs were employees of Puerto Rico National Processing Service Center (PR-NPSC), run by the Federal Emergency Management Agency (FEMA). Plaintiffs filed this lawsuit alleging that FEMA’s actions in implementing a rotational staffing plan at the PR-NPSC and in eventually closing the facility discriminated against them on the basis of national origin and constituted unlawful retaliation in violation of Title VII. The district court granted summary judgment to Defendants. The First Circuit affirmed, holding (1) Plaintiffs’ disparate impact claims failed because the challenged actions were job-related and consistent with business necessity, and Plaintiffs failed to show that there were alternatives available to FEMA that would have had less disparate impact and served FEMA’s legitimate needs; and (2) both retaliation claims failed because Plaintiffs did not show that the allegedly adverse employment actions were causally related to any protected conduct. View "Abril-Rivera v. Johnson" on Justia Law

Plaintiff was fired from Servicios Legales de Puerto Rico, Inc. (SLPR), a non-profit legal services organization where she had worked for nearly twenty-eight years. Plaintiff was sixty-three years old at the time she was terminated. Plaintiff filed an employment discrimination complaint in federal court alleging that SLPR wrongfully terminated her on the basis of her age in violation of the Age Discrimination in Employment Act. The district court entered summary judgment in favor of SLPR. The First Circuit affirmed on the ground that Plaintiff failed to establish a prima facie case for age discrimination. View "Del Valle-Santana v. Servicios Legales de P.R., Inc." on Justia Law

Employer terminated Employee for engaging in sexually inappropriate workplace conduct. Employee sued Employer and the company’s Puerto Rico Human Resources manager (collectively, Defendants), claiming unjust termination under Puerto Rico’s Law 80 and that he had been the victim of sexual harassment by the Human Resources manager in violation of Title VII of the Civil Rights Act and analogous Puerto Rico law. The district court granted Defendants’ motion for summary judgment. The First Circuit affirmed, holding that the district court properly granted summary judgment to Defendants on Employee’s federal claims and correctly granted summary judgment to Defendants on the Law 80 claim. View "Perez v. Horizon Lines, Inc." on Justia Law

Employee worked for Employer as a salesman. Employer is incorporated and headquarters in Kansas. The employment contract contemplated that Employee, a Massachusetts resident, would work from Massachusetts. Employer facilitated Employee’s work from Massachusetts by, inter alia, registering a sales office with Massachusetts and providing him with equipment. Employee brought this action in state court against Employer and its president (collectively, Defendants), alleging that Defendants violated the Massachusetts Wage Act by failing to pay him a commission he alleged he was due. Defendants removed the case to federal district court and then moved to dismiss for lack of personal jurisdiction. The district court granted the motion. The First Circuit reversed, holding Employee met the requirements of both the Massachusetts long-arm statute and the Due Process clause in establishing personal jurisdiction over Defendants. View "Cossart v. United Excel Corp." on Justia Law

Plaintiff was an associate at a Boston law firm (Defendant) when he was informed that his Defendant would not advance him for further consideration as a partner. Plaintiff filed an action pursuant to Title VII in federal district court, contending that Defendant’s decision was the result of racial discrimination and that Defendant retaliated against him after he filed a complaint with the Equal Employment Opportunity Commission. The district court granted summary judgment to Defendant on the discrimination claim. After a trial, the jury concluded that Defendant had not unlawfully retaliated against Plaintiff. The First Circuit affirmed, holding (1) the district court did not err in instructing the jury in connection with Plaintiff’s retaliation claims; and (2) the district court properly granted summary judgment to Defendant on Plaintiff’s discrimination claim. View "Ray v. Ropes & Gray LLP" on Justia Law

Plaintiff filed a complaint against the Municipality of Carolina in the federal district court of Puerto Rico alleging gender-based employment discrimination and retaliation. Before trial, Carolina extended to Plaintiff what it labeled as an offer of judgment pursuant to Fed. R. Civ. P. 68. Later that day, Carolina informed the district court that no settlement had been reached. One half of an hour later, Plaintiff informed the court that she was accepting Carolina’s offer of judgment. The district court entered judgment for Plaintiff. Carolina appealed, arguing that because Plaintiff had rejected the offer of judgment prior to informing the court of her acceptance, the district court erred in entering judgment. The First Circuit affirmed, holding that because even an express rejection of a Rule 68 offer of judgment does not terminate a Rule 68 offeree’s power to accept the offer within the fourteen-day period, the district court did not err in entering judgment for Plaintiff. View "Garayalde-Rijos v. Municipality of Carolina" on Justia Law