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

Plaintiff, a retired employee of the Department of Veterans Affairs (VA), filed a civil action in the district court pursuant to Title VII’s anti-retaliation provision, alleging several claims. The district court granted partial summary judgment in favor of the VA dismissing all but one of Plaintiff’s retaliation claims, concluding that the majority of Plaintiff’s claims were untimely and, in regards to another, Plaintiff failed to show a prima facie case of retaliation. Plaintiff then requested voluntary dismissal with prejudice of her remaining claim. The district court granted the request and dismissed the entire complaint with prejudice. The First Circuit affirmed, holding that the continuing violation doctrine did not apply to Plaintiff’s claims and, thus, her claims were time-barred. View "Ayala v. Shinseki" on Justia Law

Plaintiff was a customer service employee at a Bank. When Plaintiff could no longer endure disparate treatment due to her bisexuality she received at the Bank, she stopped reporting to work. The Bank then terminated her for job abandonment. Thereafter, Plaintiff sued the Bank for employment discrimination under the Maine Human Rights Act (MHRA) and for defamation under Maine common law. The case was removed to federal court on the basis of diversity jurisdiction. The district court granted summary judgment to the Bank. The First Circuit (1) vacated summary judgment as to the wrongful termination and hostile work environment portions of Plaintiff’s discrimination claim, holding holding that a reasonable fact-finder could conclude that (i) the Bank’s explanation for firing Plaintiff was pretextual and that she was actually fired because of her sexual orientation, and (ii) Plaintiff had endured sufficiently pervasive harassment to alter the conditions of her employment; and (2) affirmed as to the balance of Plaintiff’s discrimination claim as well as on her defamation claims, holding that, in regards to these claims, the district court did not err in its judgment. View "Flood v. Bank of Am. Corp." on Justia Law

Plaintiff, the former head chef at the Villa Cofresi Hotel, was at least forty years old at the time he was suspended and then fired. Plaintiff filed suit in federal court against the Hotel and its general manager under the Age Discrimination in Employment Act and Puerto Rico employment law, alleging that he was fired because of his age and in retaliation for his efforts to assert his rights against this discrimination. The district court granted summary judgment for the defendants on both the federal age discrimination and retaliation claims. The First Circuit vacated the judgment of the district court, holding (1) Plaintiff put forth a sufficient prima facie case of age discrimination to survive summary judgment; (2) there is a triable issue of fact as to whether the defendants’ stated grounds for firing Plaintiff were in fact a pretext for age discrimination; (3) in regard to Plaintiff’s retaliation claim, the record gives rise to competing plausible inferences from which a rational jury could find for Plaintiff; and (4) the dismissal of Plaintiff’s pendent state law claims must also be vacated. Remanded. View "Soto-Feliciano v. Villa Cofresi Hotels, Inc." on Justia Law

Plaintiff was fired from his place of employment after his employer (Defendant) learned that Plaintiff had consistently falsified his time cards over the course of several years, costing the company “1.25 hours of labor per week.” Plaintiff filed suit, alleging that Defendant had terminated him in retaliation for taking family leave in violation of the Family and Medical Leave Act. The district court granted summary judgment for Defendant. The First Circuit affirmed, holding that because Plaintiff did not offer evidence of retaliatory animus sufficient to raise a disputed question of fact or to defeat Defendant’s right to judgment as a matter of law, Plaintiff did not meet his burden of proving that Defendant’s stated reason for his termination was a pretext. View "Ameen v. Amphenol Printed Circuits, Inc." on Justia Law

Plaintiffs in this case were fourteen maintenance, domestic, and warehouse workers who were abruptly fired from the Puerto Rico executive mansion shortly after Luis Fortuño-Burset (“Fortuño”), the newly-elected governor, took office. In 2009, Plaintiffs sued Fortuño, Fortuño’s wife, and two executive staffers, alleging that they were terminated in violation of the First Amendment because they affiliated with Fortuño’s rival political parties. The district court entered summary judgment dismissing Plaintiffs’ political discrimination claim. The First Circuit affirmed both the summary judgment dismissals of Plaintiffs’ First Amendment claim and the denial of their motion to reconsider, holding (1) the record lacked sufficient evidence that Defendants were aware of Plaintiffs’ political affiliations, and thus, Plaintiffs’ First Amendment claim failed on that ground; and (2) the district court did not err in denying Plaintiffs’ request to reconsider the judgment. View "Ocasio-Hernandez v. Fortuno-Burset" on Justia Law

Pamela Manning, who suffers from type I diabetes, resigned from her employment at Kohl’s Department Stores, Inc. after Kohl’s refused to grant her request for a steady work schedule. The Equal Employment Opportunity Commission brought this suit on Manning’s behalf, alleging that Kohl’s refused to provide Manning with reasonable accommodations in violation of the Americans with Disabilities Act (ADA) and constructive discharge. The district court entered summary judgment for Kohl’s. The First Circuit affirmed, holding that because Kohl’s made multiple offers to Manning after her resignation to discuss alternative reasonable accommodations, Manning had neither a claim for ADA discrimination nor a claim for constructive discharge. View "Equal Employment Opportunity Comm’n v. Kohl's Dep’t Stores, Inc." on Justia Law

In 1997, Appellant began working for Banco Popular de Puerto Rico (BPPR). After Appellant retired in 2009, BPPR made a final calculation of Appellant’s pension, which yielded monthly payments significantly lower than earlier estimates had suggested. Seeking the higher amount he had expected, Appellant brought claims under ERISA, a theory of estoppel, and Puerto Rico contract law. The district court (1) dismissed the ERISA and contract claims, concluding that Appellant failed to state a claim under ERISA and that ERISA preempted the commonwealth claims; and (2) granted summary judgment against Appellant on the estoppel claim, concluding that the unambiguous terms of the benefits plan precluded a claim for estoppel. The First Circuit affirmed, holding (1) Appellant could not recover under ERISA because he could not be awarded relief under the terms of BPPR’s retirement plan; (2) the district court properly held that Appellant’s commonwealth claims “relate to” the ERISA-regulated plan and, accordingly, they were preempted; and (3) because Appellant did not show any ambiguity in the plan, his equitable estoppel claim necessarily failed. View "Guerra-Delgado v. Banco Popular de P.R." on Justia Law

Appellants, Crystal Litz and Amanda Payne, earned more than $100,000 per year as project managers for The Saint Consulting Group, Inc. Appellants claimed unpaid overtime compensation under the Fair Labor Standards Act (FLSA). The district court granted summary judgment on the FLSA claim to Saint Consulting, concluding that Appellants were “highly compensated employees” and thus exempt from the overtime pay protections of the FLSA. The First Circuit affirmed, holding that Appellants were highly compensated employees exempt from the overtime protections of the FLSA, and therefore, the district court did not err in granting summary judgment for Saint Consulting. View "Litz v. Saint Consulting Group, Inc." on Justia Law

In this case involving a class action complaint filed against CVS Pharmacy Inc. in Massachusetts Superior Court for wage and hour violations, the First Circuit clarified the removal time periods and mechanisms under the Class Action Fairness Act of 2005. CVS filed a second notice of removal, claiming that there was a reasonable probability that the amount in controversy exceeded $5 million. The district court granted Plaintiffs’ motion to remand, holding (1) CVS’s notice of removal came too late to meet the thirty-day deadline in 28 U.S.C. 1446(b)(1), and the second thirty-day deadline in section 1446(b)(3) did not apply; and (2) CVS had not met its burden to establish the substantive amount in controversy requirement. The First Circuit reversed, holding (1) the time limits in section 1446(b) apply when the plaintiffs’ pleadings or the plaintiffs’ “other papers” provide the defendant with a clear statement of the damages sought or with sufficient facts from which damages can be readily calculated; (2) CVS’s second notice of removal was timely under section 1446(b)(3); and (3) CVS sufficiently demonstrated that the amount in controversy exceeded $5 million. View "Romulus v. CVS Pharmacy, Inc." on Justia Law

Brendon Lydon, a member of Local 103 of the International Brotherhood of Electrical Workers, sued Local 103 in district court, alleging that the union violated several federal labor laws by running its hiring hall in a discriminatory way, retaliating against him for complaining about the discrimination, and breaching its duty of fair representation. Local 103 moved to dismiss the complaint. The district judge granted a Fed. R. Civ. P. 12(b)(6) dismissal, concluding that Lydon’s complaint failed to allege a plausible theory of relief. The First Circuit affirmed, holding that the complaint failed to state a plausible claim. View "Lydon v. Local 103, Int’l Brotherhood of Elec. Workers" on Justia Law