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

The “B Prong” of the Massachusetts Independent Contractor Statute, Mass. Gen. Laws ch. 149, 148B(a)(2), requires that workers perform a service outside the usual course of the employer’s business to be classified as independent contractors. The Massachusetts Delivery Association (MDA) filed an action for a declaration that the B Prong is preempted by the Federal Aviation Administration Act (FAAAA), and for an injunction barring the Attorney General from enforcing section 148B(a)(2) against the MDA’s members. The FAAAA preempts state laws that “relate to” the prices, routes, or services of a motor carrier “with respect to the transportation of property.” The district court held that the FAAAA does not preempt section 148B(a)(2). The First Circuit reversed, holding that the district court incorrectly interpreted the preemption test under the FAAAA and incorrectly applied the test to section 148B(a)(2). Remanded. View "Mass. Delivery Ass’n v. Coakley" on Justia Law

Appellants, employees of Puerto Rico’s Department of Transportation and Public Works and members of Puerto Rico’s Popular Democratic Party, were relieved of their job responsibilities and lost supervisory authority upon the change in political administration to the New Progressive Party in Puerto Rico (NPP). Appellants filed suit against Appellees, members of the NPP, claiming that Appellees discriminated on the basis of political affiliation in violation of the First Amendment. The district court dismissed Appellants’ First Amendment claims against the appellees who received Appellants’ cease and dismiss letters, concluding that Appellants’ letters did not identify Appellants’ political affiliation or refer to discriminatory conduct based on political animus, and therefore, Appellants did not adequately allege all elements of a First Amendment political discrimination claim. The First Circuit vacated the district court’s dismissal of Appellants’ First Amendment claims, holding that each appellant stated a plausible First Amendment claim against the appellees who received that appellant’s letter. View "Medina-Velazquez v. Hernandez-Gregorat" on Justia Law

Plaintiff, an African-American woman who was serving in the United States Coast Guard Housing Office at Air Station Cape Cod, filed an employment discrimination action against the Secretary of Homeland Security, asserting that the Secretary failed to promote her to the position of housing manager because of her race and gender. The district court granted summary judgment in favor of the Secretary, concluding that Plaintiff failed to generate a genuine issue of material fact as to whether the Secretary’s non-discriminatory reason for choosing another candidate was pretextual. The First Circuit Court of Appeals affirmed, holding (1) the district court acted within the bounds of its discretion in denying Plaintiff’s motion to reopen discovery shortly after retaining counsel; and (2) the Secretary was entitled to summary judgment because Plaintiff failed to generate a genuine issue of material fact on the issue of pretext. View "Hicks v. Napolitano" on Justia Law

When an investigation was initiated into corruption at the Puerto Rico Electrical Power Authority’s (PREPA) Aguadilla Technical Office, Plaintiff, an employee of PREPA at the Aguadilla Technical Office, testified and provided information for the investigation. Plaintiff alleged that after she testified, her employer and supervisors retaliated against her by threatening her, unjustly disciplining her, depriving her of benefits owed to her under the Family and Medical Leave Act (FMLA), and ultimately firing her. The district court dismissed Plaintiff’s FMLA complaint for failure to state a claim. The First Circuit Court of Appeals affirmed the dismissal of Plaintiff’s FMLA claims with prejudice, holding that Plaintiff did not state a plausible claim of FMLA retaliation or FMLA interference based on Defendants’ adverse actions. View "Carrero-Ojeda v. Autoridad de Energia Electrica" on Justia Law

When control of the Puerto Rican government changes parties, the political party assuming office often terminates the employment of public employees affiliated with the party going out of power and fills the vacancies with its own members. Plaintiff, a Popular Democratic Party (PDP) activist, was employed with a trust position at Puerto Rico’s State Insurance Fund Corporation (SIFC) while the PDP was in power. Plaintiff was moved into a career position at the SIFC when it became clear the opposing party would win an upcoming election. Had Plaintiff remained in a trust position, his employment could have been terminated without violating the First Amendment. A subsequent audit of employees performed by the new administration revealed that Plaintiff’s appointment did not conform with Puerto Rican law. Plaintiff’s reclassification to a career position was subsequently annulled, and he was dismissed. Plaintiff filed suit against SIFC and other defendants, alleging that he was terminated because of his political association in violation of the First and Fourteenth Amendments. The district court concluded that Defendants were entitled to summary judgment under the Mt. Healthy doctrine. The First Circuit affirmed, holding that Plaintiff failed to produce any evidence that undermined Defendants’ proffered nondiscriminatory reasons for his reclassification and later termination. View "Reyes-Perez v. State Ins. Fund Corp." on Justia Law

Plaintiff worked in a luggage factory in France that was owned by Samsonite. Samsonite was controlled by an investment group led by Bain Capital, LLC. Bain wanted to shut down the factory, and to avoid paying millions of dollars in post-termination benefits to the laid-off employees of the factory, Bain and Samsonite hired a third party, HB Group, to buy the factory. In 2007, a French court ordered the judicial liquidation of the factory. Because HB Group had no resources to pay Plaintiff and her coworkers, Plaintiff commenced this putative class action in 2012 seeking to hold Bain liable for losses suffered by the factory’s workers as a result of the sale and liquidation. The district court dismissed the complaint as untimely under the relevant three-year statute of limitations. The First Circuit affirmed, holding that there was no basis to conclude that the statute of limitations was tolled in this case. View "Abdallah v. Bain Capital, LLC" on Justia Law

Plaintiff brought sex discrimination and retaliation claims under Title VII of the Civil Rights Act against his former employer, DDR Corp., after his employment was terminated. Specifically, Plaintiff claimed that DDR discriminated against him on the basis of sex by terminating him after his co-worker, whose sexual advances he refused, maligned his job performance. The district court granted summary judgment to DDR. The First Circuit (1) vacated the portion of the district court’s judgment granting summary judgment against Plaintiff on his sex discrimination claim, holding (i) a reasonable jury could find that the jilted co-worker’s discriminatory efforts were the proximate cause of Plaintiff’s termination, and (ii) although the co-worker was not Plaintiff’s direct supervisor, DDR could nonetheless be found liable for negligently allowing the co-worker’s discriminatory acts to cause Plaintiff’s firing; and (2) otherwise affirmed the judgment of the district court. Remanded. View "Velazquez-Perez v. Developers Diversified Realty" on Justia Law

Appellant, a Muslim and a native of Algeria, filed an amended complaint alleging that he was denied a promotion at the U.S. Department of Homeland Security (“Department”) based on his religion, race, and national origin. The district court granted summary judgment in favor of Appellee, the Secretary of the Department, concluding that Appellant failed to rebut the Department’s legitimate non-discriminatory reason for rejecting Appellant’s promotion. The First Circuit vacated the district court’s judgment and remanded, holding that Appellant’s proffered evidence raised material disputes of fact that would allow a jury to infer that Appellant was the victim of intentional discrimination. View "Ahmed v. Napolitano" on Justia Law

Plaintiffs in this case were former officers and a former cadet of the Boston Police Department (Department) who were fired after testing positive for cocaine, a current officer who tested positive and underwent rehabilitation as an alternative to termination, and a former applicant whose contingent job offer was revoked after a positive test. Each Plaintiff was black. Plaintiffs filed suit against the Department, alleging, inter alia, that the Department’s drug testing program, which used hair samples to test for illegal drug use, caused a disparate impact on the basis of race in violation of Title VII of the Civil Rights Act. The district court granted summary judgment to the Department on all claims. The First Circuit Court of Appeals (1) vacated the grant of summary judgment as to Plaintiffs’ Title VII claim and reversed the district court’s denial of Plaintiffs’ motion for partial summary judgment on the question of whether they had proved a prima facie case of disparate impact under Title VII, holding that Plaintiffs proved beyond reasonable dispute a prima facie case of disparate impact under Title VII; and (2) otherwise affirmed. View "Jones v. City of Boston" on Justia Law

Plaintiff filed a lawsuit against his former employer, a school district alleging that the school district violated the Family and Medical Leave Act of 1993 (FMLA) when it reassigned Plaintiff to a new position after he took an extended leave of absence for medical reasons. The district court granted summary judgment in favor of the school district, holding (1) the school district’s FMLA eligibility and designation notices were inadequate and untimely, but Plaintiff had failed to demonstrate that he suffered harm from the lack of notice; and (2) the school district’s request for a medical opinion as to Plaintiff’s ability to return to work did not interfere with his FMLA rights or constitute retaliation. The First Circuit Court of Appeals affirmed, holding that the district court did not overlook genuine issues of material fact, misapply the parties’ burdens of production, or rely upon inadmissible evidence in granting summary judgment for the school district. View "Bellone v. Southwick-Tolland Reg'l Sch. Dist." on Justia Law