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

Plaintiff received benefits under her employer’s long-term disability benefit plan before the administrator for the long-term disability program determined she was no longer eligible for benefits. The administrator denied Plaintiff’s appeal as untimely for her failure to appeal within the benefit plan’s 180-day deadline. Plaintiff filed suit under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that her failure to comply with the 180-day deadline should have been excused because the benefit plan’s written instrument did not mention the deadline. The district court dismissed Plaintiff’s benefits challenge as well as her two other ERISA claims for statutory penalties and for breach of fiduciary duty. The First Circuit affirmed, holding that the district court did not err in (1) dismissing Plaintiff’s benefits challenge, as Plaintiff failed to meet the deadline for appealing internally the decision to cut off her long-term disability benefits, and the benefit plan had expressly incorporated that deadline into the benefit plan’s written instrument; and (2) ruling that Plaintiff could not recover statutory penalties against the administrator or that she had waived her claim for breach of fiduciary duty. View "Tetreault v. Reliance Standard Life Ins. Co." on Justia Law

After Plaintiff retired from his employment with the United States Immigration and Customs Enforcement (ICE) in the Department of Homeland Security (DHS) he filed an administrative claim for employment discrimination, alleging that he was constructively discharged on the basis of his age or national origin. Plaintiff’s claim was denied. Thereafter, Plaintiff filed this action claiming liability under the Age Discrimination in Employment Act, Title VII of the Civil Rights Act of 1964, 42 U.S.C. 1983, the Federal Tort Claims Act (FTCA), and Puerto Rico law. The district court granted summary judgment for Defendants, finding the action time-barred. The First Circuit affirmed, holding (1) to the extent Plaintiff’s complaint asserted an FTCA claim, it must be dismissed on the grounds that Plaintiff did not present an FTCA claim in his administrative complaint; and (2) Plaintiff’s remaining claims were time-barred. View "Acevedo-Perez v. United States" on Justia Law

At issue in this case was a popular restaurant in Puerto Rico owned by Lorraine Enterprises, Inc. The corporation was owned by Defendant Lorraine Lago and her husband. The Secretary of Labor sued the restaurant, Lago, and the restaurant’s general manager, alleging that Defendants were liable for violating the Fair Labor Standards Act’s (FLSA) minimum wage, overtime, and recordkeeping requirements. Specifically, the Secretary alleged that the restaurant took advantage of the reduced federal minimum wage established by the FLSA for the restaurant industry without complying with the concomitant requirements. The district court granted summary judgment for the Secretary and, thereafter, denied Defendants’ motion to alter or amend the judgment. The First Circuit affirmed, holding that the district court (1) did not err in determining that no infringement of Defendants’ due process rights had occurred; (2) did not err in granting summary judgment on the minimum wage claim; and (3) did not abuse its discretion in refusing to vacate the judgment as to the individual defendants. View "Solis v. Lorraine Enters., Inc." on Justia Law

Plaintiff, who had signed an agreement with FedEx classifying him as an independent contractor, filed two claims under Massachusetts law that apply only to employees. The district court dismissed Plaintiff’s claim that FedEx engaged in unfair or deceptive business practices in violation of Mass. Gen. Laws ch. 93A, concluding that the statute generally does not apply to employer/employee relationships. The district court then dismissed Plaintiff’s wage law claim, concluding that Plaintiff was not an employee under the statute. Plaintiff appealed the district court’s dismissal of his Chapter 93A claim. The First Circuit affirmed, holding that, regardless of whether Plaintiff was an employee, the facts in the complaint still failed to plead a violation of Chapter 93A because the allegations did not plausibly establish that Plaintiff and FedEx were interacting in “trade or commerce” within the meaning of Chapter 93A. View "Debnam v. FedEx Home Delivery" on Justia Law

Plaintiff, who suffered from Crohn’s disease, brought suit against the University of Puerto Rico, her former employer, and Marisol Gomez-Mouakad (Gomez), her former supervisor, alleging that the defendants did not renew her employment contract in retaliation for her complaining about disability-discrimination. Plaintiff filed a retaliation against both defendants under the Americans with Disabilities Act and asserted a First Amendment free-speech retaliation claim against Gomez under 42 U.S.C. 1983. The district court granted summary judgment for the defendants. The First Circuit affirmed, holding (1) Plaintiff failed to show that the defendants’ legitimate, nonretaliatory reasons for not renewing her contract were pretextual; and (2) Plaintiff failed to show that her speech was both protected and a substantial or motivating factor in the defendants’ adverse-employment decision.View "Collazo-Rosado v. Univ. of P.R." on Justia Law

Michael Dunn worked for Boston University (BU) from 1992 until 2010, at which time Dunn’s job was allegedly eliminated due to restructuring. Dunn brought suit against BU in Massachusetts superior court, claiming age discrimination in violation of both state and federal law. BU removed the case to federal district court. The district court granted summary judgment in favor of BU, concluding that Dunn had not made out a prima facie case that he was laid off because of his age. The First Circuit affirmed without ruling on the sufficiency of Dunn’s prima facie showing, holding that, even assuming that Dunn made a prima facie showing of age discrimination, Dunn failed to demonstrate a genuine issue of material fact as to whether BU’s stated reasons for discharging him were a pretext for unlawful discrimination.View "Dunn v. Trs. of Boston Univ." on Justia Law

Appellant, a seaman, was diagnosed with aplastic anemia, a blood condition that preventing him from continuing to work. Appellant brought a personal injury action against his employer, alleging negligence under the Jones Act and maritime claims of unseaworthiness and maintenance and cure. The district court granted summary judgment for the employer. On appeal, Appellant challenged only the dismissal of his cause of action for maintenance and cure, arguing that he was entitled to that remedy until he “reaches maximum medical recovery.” The First Circuit vacated the district court’s ruling, holding that Appellant adduced sufficient evidence to support a finding that his aplastic anemia arose or became aggravated during his service on the ship and, hence, triggered the duty of maintenance and cure. Remanded.View "Ramirez v. Carolina Dream, Inc." on Justia Law

Plaintiff filed a complaint against his employer, the U.S. Army, alleging that his direct supervisor harassed and discriminated against him on account of his disability. The Army dismissed the complaint as untimely, and the Equal Employment Opportunity Commission (EEOC) affirmed. Plaintiff subsequently filed a complaint with the district court, asserting discrimination, hostile work environment, and retaliation claims. The district court construed these claims as claims brought pursuant to the Rehabilitation Act. The district court found that Plaintiff’s administrative complaint was untimely filed and ordered that Plaintiff’s claimed be dismissed because Plaintiff failed to exhaust his administrative remedies and did not qualify for equitable tolling. The First Circuit affirmed the dismissal of Plaintiff’s claims, holding that the district court correctly found that Plaintiff’s administrative filing was untimely and did not abuse its discretion when it denied Plaintiff’s request for equitable tolling on the insufficiently supported basis of mental illness.View "Vazquez-Rivera v. Figueroa" on Justia Law

Maribel Vazquez-Robles (Plaintiff) commenced a civil action in a federal district court against CommoLoCo, Inc. (Defendant), her former employer, alleging workplace discrimination claims. Plaintiff served the summons and complaint on Prentice-Hall Corporation System Puerto Rico, which she believed to be Defendant’s registered agent for service of process. When no answer was filed, Plaintiff obtained an entry of default, and a jury awarded Plaintiff nearly $1 million in damages. Plaintiff procured a writ of execution, and the full amount of the judgment was seized from Defendant’s bank account. Defendant immediately moved to vacate the judgment as void, arguing that Prentice was not its registered agent and that it had no prior knowledge of the action. The district court denied the motion. The First Circuit vacated the judgment of the district court, holding that, in this case, the district court never acquired jurisdiction over Defendant, as Prentice was not Defendant's registered agent at the time the service of process was attempted by Plaintiff.View "Vazquez-Robles v. CommoLoco, Inc." on Justia Law

In 2011, the Maine Legislature made certain amendments to Maine’s public employee retirement system. In general, the retired Maine employees stood to be paid significantly less cost-of-living adjustments as a result of the amendments. Plaintiffs - retired Maine employees, public school teachers, and members of the Maine Association of Retirees and the Maine State Employees Association - filed suit, arguing that the amendments violated the Contract Clause and Taking Clause of the United States Constitution. The district court granted summary judgment against Plaintiffs. The First Circuit affirmed, holding that the 2011 amendments did not violate the Contract Clause. View "Me. Ass’n of Retirees v. Bd. of Trustees" on Justia Law