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

Plaintiff brought suit against his employers in the District of Puerto Rico, alleging, inter alia, violations of the Age Discrimination in Employment Act. The employers moved to dismiss the complaint, asserting that a forum selection clause in Plaintiff’s separation agreement provided exclusive jurisdiction in the Court of First Instance, San Juan Division. Plaintiff argued that the forum selection clause was invalid because he did not affirmatively waive his Seventh Amendment Right to a jury trial. The district court concluded that the forum selection clause was valid but entered a declaratory judgment stating that the Commonwealth of Puerto Rico must afford civil litigants the Seventh Amendment right to a jury trial. The First Circuit vacated the portion of the district court’s judgment declaring that the Commonwealth must afford civil litigants a jury trial, holding that this action was in contravention of binding Supreme Court precedent. Remanded. View "Gonzalez-Oyarzun v. Commonwealth of P.R." on Justia Law

The National Labor Relations Board entered an order requiring NSTAR Electric Company, an electric and gas company, to bargain with a Union that seventeen of the company’s dispatch-center workers voted to join. The Board filed an application in the First Circuit to enforce that order. NSTAR filed a cross-petition for review, contending that the electrical workers’ responsibilities made them either “supervisors” or “manager[s]” rather than “employees,” and therefore, the National Labor Relations Act, which requires a company to bargain with a union that represents “employees” of that company, did not protect the workers’ right to have the Union represent them. The First Circuit granted the Board’s petition to enforce the Board’s order and denied the company’s cross-petition for review, holding that substantial evidence supported the Board’s finding that the NSTAR failed to show that the workers were either supervisors or managers, even though the workers were highly skilled and charged with critical tasks. View "NLRB v. NSTAR Elec. & Gas Co." on Justia Law

Plaintiff worked for the Town of Camden for thirty-one years prior to being laid off. The collective bargaining agreement (CBA) between the police union and the Town provided for recall of qualified employees based on seniority. During the twelve-month period after Plaintiff was laid off, vacancies opened in the Camden Police Department, but the Town did not recall Plaintiff. Plaintiff and his wife brought this action under 42 U.S.C. 1983 alleging that the Town had deprived Plaintiff, without due process of law, of his property interest in his right to be recalled. The district court dismissed Plaintiff’s complaint for failure to state a claim. The First Circuit vacated the dismissal and remanded. On remand, the district court entered judgment for the Town, concluding that the CBA contained a condition precedent requiring Plaintiff to submit his address and phone number to the Town after his layoff in order to assert his recall rights and that Plaintiff did not submit such information post-layoff. The First Circuit vacated the judgment and remanded, holding that the CBA recall provision did not unambiguously create a condition precedent, and therefore, further fact-finding was necessary. View "Clukey v. Town of Camden, Maine" on Justia Law

Hector Luis Roman-Oliveras (Roman) was dismissed from his job after working for the Puerto Rico Electric Power Authority (PREPA) for over twenty years. Roman, along with his wife and mother, brought suit against PREPA and two individual supervisors, alleging that Defendants unlawfully targeted Roman due to his medical disability and his union activities. In 2012, the parties held settlement negotiations, which took place in the district judge’s chambers. The judge memorialized an account of the discussions in a minute entry recounting that the parties had reached a binding oral settlement agreement. The parties, however, did not submit a final written agreement. Another district judge later dismissed the case with prejudice on the basis of the settlement agreement. Plaintiffs appealed, arguing that “an agreement had never been reached,” and, assuming such a settlement had been reached, the district court lacked subject matter jurisdiction to enforce it. The First Circuit affirmed, holding that the district court did not err in finding that the talks conducted in 2012 produced a binding oral settlement agreement that the district court had jurisdiction to enforce. View "Roman-Oliveras v. P.R. Elec. Power Auth." on Justia Law

Labonte Drywall Company signed a statewide agreement with Union, which allowed Labonte Drywall to hire Union carpenters for its business. The agreement required Labonte Drywall to allow an audit of its records. After Labonte Drywall did not respond to certain audit requests, Plaintiffs, the trustees for a group of Union-related benefits funds and their collection agency, filed this action against Labonte Drywall under ERISA and the Labor Management Relations Act, seeking enforcement of the agreement. After a bench trial, the district court found that Labonte Drywall had terminated the agreement, and therefore, Plaintiffs had no legal right to conduct the requested audit. The First Circuit affirmed, holding (1) the district court did not clearly err in finding that the Union had actual notice of Labonte Drywall’s letter terminating its obligations under the agreement; and (2) Labonte Drywall had no duty to submit to Plaintiffs’ audit requests. View "New England Carpenters Central v. Labonte Drywall Co., Inc." on Justia Law

Plaintiffs were employees of Puerto Rico National Processing Service Center (PR-NPSC), which is now closed, 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, which reduced the number of work days for each employee, and in eventually closing the facility discriminated against them on the basis of national origin and 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 (i) Plaintiffs expressly disavowed any claim of intentional discrimination, and under relevant caselaw, claims of different treatment based on location absent a claim of intentional discrimination do not establish liability under 42 U.S.C. 2000e-2(h), and (ii) 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

This case involved a series of shifting employment arrangements between Plaintiff and Defendant, TSI Semiconductors America, LLC (TSA). In 2009, Plaintiff began working for Tejas Silicon, Inc. under a written employment agreement (Agreement). In 2011, corporate restructuring led to Plaintiff’s termination with Tejas and the offer of new employment with TSA. The parties amended the Agreement in certain respects. After Plaintiff was furloughed in 2012, Plaintiff sued TSA in a California state court alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and California state law claims. TSA removed the case to federal district court. The district court entered summary judgment in favor of TSA, concluding that neither the reorganization, the non-renewal of the Agreement, nor the layoff constituted a termination without cause that triggered the duty to pay severance under the Agreement. The First Circuit reversed in part, affirmed in part, and remanded, holding (1) because genuine issues of material fact permeated the record, the district court erred in granting summary judgment for TSA on Plaintiff’s claim for severance benefits arising out of the 2011 reorganization; and (2) the district court did not err in granting summary judgment on Plaintiff’s claims regarding the 2012 non-renewal and the 2012 layoff. View "Mason v. Telefunken Semiconductors America, LLC" on Justia Law

Plaintiff Sonia Velez-Velez, a Popular Democratic Party (PDP) member, lost her job with the Puerto Rico Highway and Transportation Authority after an election returned the opposing political party, the New Progressive Party (NPP), to office. Plaintiff was informed on February 11, 2010 that she would be terminated under the new NPP administration’s ruling that one set of hiring policies under which Plaintiff was hired was unlawful and therefore, those employees hired under the erroneous determinations must be terminated. Plaintiff requested a hearing, and on November 8, 2010 the Examining Officer recommended affirming the decision to terminate Plaintiff’s employment. On December 20, 2011, Plaintiff and her husband filed this complaint, alleging claims for political discrimination, among other claims. The district court granted summary judgment for Defendants, concluding that the discrimination claim was time-barred. Plaintiff appealed, claiming that the clock did not begin to run until she was formally terminated after the hearing. The First Circuit affirmed, holding that the statute of limitations began to run when Plaintiff was informed on February 11, 2010 of the re-interpretation of policy. View "Velez-Velez v. P.R. Highway & Transp. Auth." on Justia Law

In Sprint Commc’ns, Inc. v. Jacobs, the Supreme Court revisited the doctrine of abstention enunciated in Younger v. Harris. That doctrine requires federal courts, in the absence of extraordinary circumstances, to refrain from interfering with certain state proceedings. In this case, David Knight, an employee of Sirva Relocation, LLC, filed a charge of discrimination with the Massachusetts Commission Against Discrimination (MCAD) alleging that Sirva and Aetna Life Insurance Company (together, Appellants) had discriminated against him on the basis of disability in violation of Mass. Gen. Laws ch. 151B and the Americans with Disabilities Act (ADA). Appellants filed a federal complaint against the Commonwealth of Massachusetts, the MCAD, its commissioners, and Knight, asking the court to enjoin the MCAD proceeding on the basis that ERISA preempted the chapter 151B claim. The MCAD and Knight moved to dismiss the complaint, entreating the district court to abstain. While the case was pending, the Supreme Court decided Sprint. The district court dismissed the federal court action, concluding that Younger abstention was appropriate in this case. The First Circuit affirmed the district court’s decision to abstain and further clarified its own case law concerning the exception to the Younger doctrine for facially conclusive claims of preemption. View "Sirva Relocation, LLC v. Golar Richie" on Justia Law

Plaintiff, a sales representative for Wyndham Vacation Resorts, Inc., brought this claim of retaliation under Title VII of the Civil Rights Act of 1964 alleging that her supervisor subjected her to a hostile work environment on the basis of race and national origin and that Wyndham retaliated against her for complaining about the supervisor’s conduct. The magistrate judge recommended that the district court grant summary judgment for Wyndham. The district court summarily affirmed the recommendation. The First Circuit affirmed, holding that Plaintiff did not present sufficient evidence to establish a retaliation claim under Title VII. View "Planadeball v. Wyndham Vacation Resorts, Inc." on Justia Law