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

Plaintiff was fifty-five years old when he was hired to work as an assistant manager at Walgreens. In 2011, Walgreens terminated Plaintiff’s employment after Plaintiff failed to provide what Walgreens considered to be adequate customer service. Plaintiff filed suit in federal court, alleging that his employment was terminated because of his age, in violation of the Age Discrimination in Employment Act and Mass. Gen. Laws ch. 151B, 4(1B). The district court granted summary judgment for Walgreens. The First Circuit Court of Appeals affirmed, holding that Plaintiff (1) did not raise any genuine issue as to whether Walgreens believed the truth of its stated reason for terminating him; (2) did not demonstrate pretext through a showing that Walgreens violated its policy to uniformly enforce the rules; and (3) did not demonstrate that Walgreens’ proffered reason for terminating him was pretext designed to disguise age discrimination. View "Adamson v. Walgreen Co." on Justia Law

Plaintiffs found engineering jobs through Advanced Technology Innovation Corporation (“the company”), a recruiting firm. Plaintiffs were paid by the company. In 2012, Plaintiffs filed suit, alleging that the company violated 29 U.S.C. 207(a)(1)-(2) by failing to pay the required overtime rate of at least one-and-a-half times their regular rate of pay. Specifically, Plaintiffs contended that the company wrongly labeled part of their regular hourly wage a “per diem” and excluded the per diem when it calculated the rate for overtime. After examining the company’s formula for calculating the per diem, the district court granted summary judgment in favor of the company. The First Circuit Court of Appeals reversed, holding that the company’s formula was impermissibly based upon and thus varied with the number of hours worked per week, depriving Plaintiffs of overtime pay. Remanded for entry of partial summary judgment in Plaintiffs’ favor as to liability. View "Newman v. Advanced Tech. Innovation Corp." on Justia Law

Plaintiff was hired by Employer in 1983. Plaintiff was covered by a short-term disability plan, and the Life Insurance Company of North America (“LINA”) had the authority to decide questions of eligibility for coverage or benefits under the plan. After Plaintiff underwent back surgery in 2009, LINA at first granted but then denied Plaintiff disability benefits. In 2010, Plaintiff sued LINA, Employer, and others in Puerto Rico court, seeking review of the benefits denial. LINA later removed the action to the District of Puerto Rico. Ultimately, the district court (1) found LINA’s decision was not arbitrary and capricious because Plaintiff failed to produce sufficient medical evidence of disability, and (2) dismissed Plaintiff’s claim against Employer for failure to plead it with specificity. Plaintiff appealed. The First Circuit Court of Appeals dismissed Plaintiff’s appeal on procedural grounds because Plaintiff committed numerous procedural errors, which precluded intelligent review. View "Gonzalez-Rios v. Hewlett Packard PR Co." on Justia Law

In 2011, the then-Governor of Puerto Rico appointed Plaintiff to the position of Advocate for Persons with Disabilities. In 2013, new legislation established an Office of the Ombudsman for Personal with Disabilities. Plaintiff was subsequently informed that an Ombudsman had been appointed and that his position had been abolished by legislative act. Plaintiff sued the Governor and other officials for attempting to oust him from his job as Advocate, claiming that it was unconstitutional for Puerto Rico to abolish the Advocate position without an individualized hearing. The district court issued a preliminary injunction in favor of Plaintiff. The First Circuit Court of Appeals vacated the district court’s order, concluding that the court erred in finding that Plaintiff had demonstrated a likelihood of success on the merits where there was no viable claim that the abolition of the Advocate Office independently violated some constitutional proscription. View "Diaz-Carrasquillo v. Garcia-Padilla" on Justia Law

Plaintiff’s employment with Employer was terminated due to what Plaintiff alleged was disability discrimination and retaliation. Plaintiff filed a discrimination complaint against Employer with the Equal Employment Opportunity Commission (EEOC) but did not file a civil action against Employer within ninety days after he received a right-to-sue letter from the EEOC. Plaintiff filed a new administrative charge against Employer two months after the first right-to-sue letter issued adding a second charge for retaliation. Less than a month after the transmittal of the second right-to-sue letter, Plaintiff sued Employer and other defendants in federal district court for discrimination and retaliation under the Americans with Disabilities Act (ADA). The district court dismissed both federal claims on the grounds that they were time barred, as (1) the discrimination claim was not brought within ninety days of Plaintiff’s receipt of the first right-to-sue letter, and (2) the retaliation claim had been filed too late with the EEOC. The First Circuit Court of Appeals affirmed, holding that the district court did not err in dismissing both charges due to Plaintiff’s failure to meet applicable time limits. View "Rivera-Diaz v. Humana Health Plans of P.R." on Justia Law

Plaintiff was a long-time employee of the Internal Revenue Service (IRS). Plaintiff was separated from her employment as a result of her inability to return to the workplace resulting from severe depression. Plaintiff filed a complaint against the IRS alleging that she had been constructively discharged on account of her disability in violation of the Rehabilitation Act and the Americans with Disabilities Act. The district court dismissed Plaintiff’s complaint on the ground that Plaintiff had not lodged her administrative complaint within forty-five days of the incident, as statutorily required, thereby rejecting Plaintiff’s contention that equitable tolling applied to her claim. The First Circuit Court of Appeals affirmed, holding that Plaintiff did not establish that equitable tolling should be applied to save her untimely administrative action. View "Bartlett v. Dep't of Treasury" on Justia Law

Plaintiff filed a charge of gender discrimination with the Equal Employment Opportunity Commission (EEOC) alleging that the Municipality of Carolina discriminated against her because of her gender by refusing to hire her as a firefighter. The EEOC concluded that Carolina had discriminated against Plaintiff in its hiring process. Carolina subsequently hired Plaintiff as a firefighter. Thereafter, Plaintiff sued the Municipality and Mayor of Carolina, asserting claims for sex discrimination and retaliation under Title VII of the Civil Rights Act of 1964, as well as pendent state law claims, based on Defendants’ pre- and post-hire conduct. The district court dismissed Plaintiff’s complaint for failure to state a claim. The First Circuit Court of Appeals reversed in part and dismissed in part, holding (1) Plaintiff waived her right to the review of her claims against the Mayor and her post-hire discrimination claims; and (2) the district court erred in dismissing Plaintiff’s pre-hire discrimination claims and post-hire retaliation claims against Carolina, as the claims asserted met the plausibility standard. View "Garayalde-Rijos v. Municipality of Carolina" on Justia Law

Union-affiliated benefit funds (collectively, the Fund) sued Employer to recover unpaid employee-related remittances allegedly due under a collective bargaining agreement (CBA). The Fund also sought attorneys’ fees and costs pursuant to both the CBA and ERISA. The district judge awarded the Fund $26,897 in damages, and, in a separate judgment, awarded $18,000 in attorneys’ fees and $16,688 in expenses. Both parties appealed. The First Circuit Court of Appeals reversed the district court’s determination of damages, but the Supreme Court reversed, concluding that the First Circuit lacked jurisdiction to review the damage judgment. On remand, the First Circuit reinstated the cross-appeals challenging the separate judgment for fees and costs and affirmed the district court’s order awarding attorneys’ fees and expenses, holding that the award was not an abuse of the judge’s discretion. View "Int'l Union v. Ray Haluch Gravel Co." on Justia Law

Plaintiff, who worked for Metropolitan Life Insurance Co. (“MetLife”), made a claim for long-term disability benefits (LTD). In 2005, the claim was approved. That same year, MetLife denied Plaintiff’s assertion that he was entitled to a larger payment calculation. In 2012, Plaintiff filed suit against MetLife under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that MetLife had been underpaying his monthly benefits since 2005. The district court granted MetLife’s motion for summary judgment, concluding that Plaintiff’s suit was barred by the six-year statute of limitations. The First Circuit Court of Appeals affirmed, thus rejecting Plaintiff’s theory that the LTD plan must be analogized to an installment plan so as to alter the accrual date of his claim, holding that Plaintiff’s claim against MetLife was barred by the statute of limitations. View "Riley v. Metro. Life Ins." on Justia Law

After Plaintiff applied unsuccessfully to be a firefighter in the Puerto Rico Firefighters Corps of the Commonwealth of Puerto Rico (“the Corps”) Plaintiff sued the Commonwealth, claiming that the Corps refused to hire her because of her gender. The parties eventually signed a settlement agreement pursuant to which the Corps agreed to employ Plaintiff as a transitory firefighter until the next training academy was held and to hire Plaintiff as a firefighter if she graduated from the academy. Thereafter, Plaintiff again sued the Corps, alleging that, during her transitory employment, the Corps subjected her to abuse in retaliation for her earlier suit. The district court dismissed Plaintiff’s complaint for failure to state a claim. Plaintiff appealed the dismissal of her claim for unlawful retaliation. The First Circuit Court of Appeals vacated the district court’s order, holding that Plaintiff’s complaint stated a plausible claim of unlawful retaliation in violation of Title VII of the Civil Rights Act. Remanded. View "Rodriguez-Vives v. P.R. Firefighters Corps" on Justia Law