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

Plaintiff was a supervisor at the Programmatic Area of the Department of Education’s Special Education Center in Bayamon when the New Progressive Party came to power in Puerto Rico. Plaintiff claimed that, as a result of his membership in the Popular Democratic Party, he was subject to impermissible political discrimination when he was reassigned to a new position, a diminution of his supervisory responsibilities, and other adverse employment actions. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding (1) Plaintiff failed to generate facts that would allow a rational jury to conclude that Plaintiff’s reassignment was an act of political discrimination or that his job responsibilities were diminished in his new position; and (2) Plaintiff’s remaining allegations of workplace discrimination were insufficient to constitute adverse employment actions. View "Santiago-Diaz v. Rivera-Rivera" on Justia Law

Plaintiff filed this lawsuit against his employer asserting a claim for unpaid overtime under the Fair Labor Standards Act (FLSA). Specifically, Plaintiff alleged that his employer engaged in commerce within the meaning of the FLSA and generated annual gross sales of not less than $500,000. The employer moved for summary judgment on the FLSA claim, arguing that Plaintiff had not established fact sufficient to meet his burden of proving that his employer’s sales were high enough to trigger coverage under the FLSA. In response, Plaintiff submitted an affidavit claiming that he himself engaged in interstate travel and phone calls sufficient to establish individual coverage under the Act. The district court granted summary judgment against Plaintiff on his FLSA claim and for the employer on Plaintiff’s various state-law claims. The First Circuit affirmed, holding that Plaintiff was not entitled to relief on his FLSA claim or on his state-law claims. View "Martinez v. Petrenko" on Justia Law

Respondent was the widow of an employee of Battelle Memorial Institute (BMI). The decedent was stationed in Tbilisi, Georgia when he died in an automobile accident while traveling by taxi to shop for groceries. Respondent filed a claim for death benefits under the Defense Base Act (DBA). An administrative law judge (ALJ) held in favor of the widow. The Benefits Review Board affirmed. BMI petitioned for review. At issue before the First Circuit was whether the Board correctly found that the zone of special danger doctrine applied in this case and that the decedent’s death was compensable under the Act. The First Circuit affirmed, holding that substantial evidence supported the ALJ’s findings and ensuing conclusions that the zone of special danger doctrine applied and that the decedent’s death was compensable under the Act. View "Battelle Mem’l Inst. v. Dicecca" on Justia Law

Le Fort Enterprises, Inc., which provides cleaning services to homeowners in and around Boston, Massachusetts, employs twenty-nine housekeepers. Some of the housekeepers decided to attempt to unionize. The National Labor Relations Board asserted jurisdiction and conducted a secret-ballot election among the twenty-nine housekeepers. The employees voted to select the International Association of Bridge, Structural, Ornamental and Reinforcing Iron Workers, Local 7, AFL-CIO (the Union) as their exclusive collective-bargaining representative. The Board certified the Union in accord with the employees’ vote. Le Fort, however, refused to bargain with the Union, which led to a charge of unfair labor practices. The Board subsequently ordered Le Fort to bargain. The Board petitioned the First Circuit to enforce the Board’s unfair labor practice order. The First Circuit granted the petition, holding that there was no evidence to warrant setting aside the election results. View "Nat’l Labor Relations Bd. v. Le Fort Enters., Inc." on Justia Law

This suit arose after American Airlines began charging passengers $2 per bag to use curbside check-in services. A class of skycaps - airport porters who assist passengers with curbside check-in - working at airports throughout the country sued American Airlines. Plaintiffs alleged that American failed adequately to notify customers that skycaps would not receive the proceeds from the new charge and that the compensation decreased significantly following the introduction of the new charge. On behalf of the Massachusetts skycaps, Plaintiff sued for violations of the Massachusetts Tips Law. Plaintiffs also sued on behalf of the class for tortious interference with a contract and unjust enrichment or quantum meruit. The district court dismissed the action, concluding that the federal Airline Deregulation Act preempted each of the skycaps’ claims. The First Circuit affirmed, holding that federal law preempted the skycaps’ state statutory and common law claims. View "Overka v. American Airlines, Inc." on Justia Law

Plaintiff, an employee of a nursing facility (Defendant), was informed that she was terminated for diverting drugs from patients. Plaintiff filed suit, alleging that Defendant violated Maine’s Whistleblowers’ Protection Act by firing her for complaining about one of her supervisors. The district court entered summary judgment in favor of Defendant, concluding that Defendant terminated Plaintiff’s employment for the legitimate, nondiscriminatory reason of suspected drug diversion. The First Circuit affirmed, holding that Plaintiff failed to make out a trialworthy issue on her claim that Defendant terminated her because of her role as a whistleblower. View "Murray v. Kindred Nursing Centers West LLC" on Justia Law

Appellant was eligible for disability benefits through an employee welfare benefit plan underwritten by Aetna Life Insurance Company. Appellant successfully applied for long-term disability (LTD) benefits under his plan in 2009. Later that year, Appellant’s LTD benefits were terminated. Appellant brought this suit against Aetna under the Employee Retirement Income Security Act of 1974 alleging wrongful termination of benefits. The federal district court granted summary judgment for Aetna on the benefits-termination claim but applied a $5,000 penalty against Aetna for its failure to produce all relevant plan documents within the statutorily prescribed time. The First Circuit (1) vacated summary judgment with respect to the termination of disability benefits and remanded the issue for further consideration by the claims administrator, holding that Aetna’s decision to terminate Appellant’s LTD benefits was not a reasoned determination; and (2) affirmed the district court’s imposition of a $5,000 penalty for the belated production of a plan document, holding that the amount of the penalty imposed was within the district court’s discretion. View "McDonough v. Aetna Life Ins. Co." on Justia Law

Plaintiffs, current and previous employees of the Puerto Rico State Insurance Fund Corporation (SIFC), filed two similar lawsuits alleging that Defendants, the SIFC and its administrators, selectively enforced Puerto Rico’s merit principle against them in violation of the Equal Protection Clause. The district courts granted summary judgment to Defendants, concluding that Plaintiffs failed to identify similarly situated individuals treated differently by Defendants. The First Circuit affirmed on the same basis, holding that Plaintiffs’ Equal Protection claims failed as a matter of law because Plaintiffs failed to identify employees of a similar category that were similarly situated but who were treated differently by Defendants. View "Aponte-Ramos v. Alvarez-Rubio" on Justia Law

Jorge L. Vaello-Carmona worked for Siemens Medical Solutions USA, Inc. from 1991 until his dismissal in 2009. In 2011, Vaello-Carmona filed a complaint against Siemens alleging disability discrimination and unlawful termination in violation of Title I of the Americans with Disabilities Act (ADA) and Puerto Rico’s general employment discrimination and employment disability discrimination statutes. Vaello-Carmona died one month after filing his complaint. Appellants subsequently moved to substitute themselves as plaintiffs in this case. The district court denied the motion and dismissed Vaello-Carmona’s complaint, concluding that Vaello-Carmona’s employment discrimination claims were not inheritable. The First Circuit vacated the judgment of the district court, holding that Vaello-Carmona’s claims were inheritable under Puerto Rico law. View "Vaello-Carmona v. Siemens Med. Solutions USA, Inc." on Justia Law

Appellant was associated with Appellee, Raymond James Financial Services, as a securities broker. After Appellee decided to terminate Appellant’s contract, Appellant brought an arbitration proceeding before the Financial Industry Regulatory Authority, alleging that he had been fired because of his sexual orientation and his status as a recovering alcoholic, in violation of Vermont law. After granting the parties’ request that Florida law be applied to the proceedings, an arbitration panel awarded Appellant $600,000 in back pay on his claim of discrimination based on disability. The district court vacated the award, concluding that the arbitrators lacked authority to grant the remedy because Appellant brought no claims under Florida law. The First Circuit reversed, holding that although the arbitration decision may have been incorrect as a matter of law, the arbitrators’ decision to impose liability on Appellee under Florida law did not willfully flout the governing law or otherwise exceed the bounds of the arbitrators’ authority to resolve the parties’ dispute. Remanded for entry of an order confirming the arbitration award. View "Raymond James Fin. Servs., Inc. v. Fenyk" on Justia Law