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

Plaintiff filed an action against her former employer (Employer) for violations of Title VII, 42 U.S.C. 2000e et seq., and Mass. Gen. Laws ch. 151B, alleging that she was subject to sexual harassment while working for Employer and that she was terminated in retaliation for reporting the harassment. The district court granted summary judgment in favor of Employer. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in concluding that no reasonable juror could conclude that Plaintiff was subjected to sexual harassment while an employee for Employer; and (2) even if Plaintiff had made a prima facie case of retaliation, which she did not, Plaintiff did not meet her burden of showing that Employer’s legitimate, non-retaliatory reason for the termination was mere pretext. View "Ponte v. Steelcase Inc." on Justia Law

Plaintiff, the former captain of a village fire department, filed this action against the department, its fire chief, and the board of fire commissioners (collectively, Defendants) after the board chose to terminate Plaintiff’s employment. Plaintiff alleged political discrimination in violation of the First Amendment and 42 U.S.C. 1983, retaliation in violation of the Massachusetts Whistleblower Act, and tortious interference with contractual relations. The district court granted summary judgment for Defendants on all counts. The First Circuit Court of Appeals affirmed, holding that Defendants presented legitimate, business-related grounds for their employment decisions, and Plaintiff failed to demonstrate that the proffered explanations were pretextual. View "Pierce v. Cotuit Fire Dist." on Justia Law

Appellant filed an action against her former employer, The Children Place (TCP) and the TCP district manager (collectively, Appellees), alleging that she was fired, harassed, and not rehired on the basis of race. The district court granted summary judgment in favor of Appellees. The First Circuit Court of Appeals affirmed, holding (1) the district court did not abuse its discretion when it denied three of Appellant’s discovery-related motions; and (2) the district court did not err by granting Appellees’ motion for summary judgment as to (i) Appellant’s claims of race discrimination where Appellant was unable to rebut Appellees’ legitimate, nondiscriminatory basis for her termination with evidence of pretext and discriminatory motive, and (ii) Appellant’s retaliation claim in light of her failure to establish a prima facie case. View "Pina v. Children's Place" on Justia Law

Petitioner, a citizen of Nigeria, entered the United States using a false name and fraudulently obtained visa. After the government commenced removal proceedings, Petitioner filed for withholding of removal and protection under the Convention Against Torture, citing fear of religious persecution. The immigration judge denied relief and ordered removal. The board of immigration appeals (BIA) affirmed. The BIA denied Petitioner's motion to reopen, which added a claim for asylum, and his subsequently filed motion to reconsider. The First Circuit Court of Appeals dismissed Petitioner's petition for review his motion to reopen and denied Petitioner's petition to review his motion to reconsider, holding that the BIA did not abuse its discretion or err in its judgment. View "Saka v. Holder" on Justia Law

Joseph Travers worked as a skycap for Flight Services & Systems, Inc., a company that provides services to airlines, including JetBlue. Travers filed a putative class lawsuit against JetBlue and Flight Services, alleging that Defendants violated the Fair Labor Standards Act (FLSA) by failing to pay the federal minimum wage. While a decision on Travers's motion to certify conditionally an opt-in class under the FLSA was pending, Flight Services fired Travers for allegedly violating company policy. Travers filed this action against Flight Services, asserting that he was fired in retaliation for his FLSA lawsuit. The district court granted summary judgment to Flight Services. The First Circuit Court of Appeals vacated the district court's grant of summary judgment, holding a reasonable jury could return a verdict for Travers without relying on inferences or speculation. Remanded. View "Travers v. Flight Servs. & Sys., Inc." on Justia Law

Appellant filed two amended qui tam actions against her employer, a pharmaceutical company and its subsidiary (collectively, Appellees), under the federal False Claims Act (FCA), alleging that Appellees failed adequately to disclose the risks associated with some of their drugs and that this failure resulted in the submission of false claims by third-party patients and physicians for government payment. The district court dismissed both of Appellant's actions under Fed. R. Civ. P. 9(b) for failure to plead fraud with particularity and under Fed. R. Civ. P. 12(b)(6) for failure to state a claim. Appellant subsequently sought to amend the second amended complaint, asserting more theories of FCA liability, but the district court refused to allow further amendment. The First Circuit Court of Appeals affirmed the district court's rulings regarding the dismissal of Appellant's claim under Rule 9(b) and the denial of Appellant's proposed amendments, holding (1) Appellant's claims on all theories which were presented failed under Rule 9(b); and (2) the district court did not err in denying Appellant's motion to amend. View "United States ex rel. Ge v. Takeda Pharm. Co. Ltd." on Justia Law

Under the Workforce Investment Act of 1998 (WIA), Maine obtained federal funding to strengthen local workforces. Plaintiff was the executive director of the Local Area I Workforce Investment Board (LWIB). Plaintiff reported to and received her salary from Aroostook County, and the County used WIA funds for this purpose. Federal monitors from the Department of Labor undertook a compliance review of the LWIB and found that Plaintiff's job description was not in compliance with federal program requirements because, absent an express agreement between the LWIB and the County, the County could not be Plaintiff's employer. Plaintiff transmitted results of the federal monitoring visit but did so as part of her job responsibilities. The Northern Maine Development Commission, Inc. (NMDC) was later designated as the fiscal agent for the LWIB, and Plaintiff's employment was terminated. Plaintiff applied for NMDC's director of workforce development petition was not hired. Plaintiff then filed this Maine Whistleblowers' Protection Act (MWPA) action against NMDC for violating the whistleblower law. The district court granted summary judgment for NMDC. The First Circuit Court of Appeals affirmed, holding that, on the undisputed facts, Plaintiff was not a whistleblower under the MWPA and so had no claim against NMDC. View "Winslow v. Aroostook County" on Justia Law

This case concerned a plumbers and pipefitters union ("the Union"), which established employee benefits plans. Among the pension benefits promised to Union employees were "banked hour" benefits, which were retroactively conferred during the course of employment. The Pension Trust sought to eliminate the benefits in an attempt to meet its obligations to a larger group of plan participants. Plaintiffs, now-retired union employees, filed this action against the Trustees, alleging that the cuts, which were effectuated through a plan amendment, violated the anti-cutback provisions ERISA, which protects "accrued benefits" against reduction by amendment. The district court entered summary judgment for Plaintiffs. The First Circuit Court of Appeals affirmed, holding that Plaintiffs' benefits were in fact "accrued" and that the plan amendment, if implemented, would violate the anti-cutback provisions of ERISA. View "Bonneau v. Plumbers & Pipefitters Local Union 51 Pension Trust Fund" on Justia Law

Verizon New England, Inc. ("Verizon") had a collective bargaining agreement (CBA) with Local 2327, International Brotherhood of Electrical Workers, AFL-CIO (the "Union") that was originally signed in 2003. When, in 2008, FairPoint Communications ("FairPoint") purchased Verizon's telecommunication operations in Vermont, New Hampshire, and Maine, FairPoint agreed to hire all former Verizon employees, represented by the Union, in those states. In 2010, the Union filed a grievance against FairPoint based on allegedly wrongful transfer of work. An arbitration panel entered an award against FairPoint, concluding that the facts constituted a wrongful conveyance. FairPoint filed suit in district court, arguing that the arbitral panel had exceeded its authority by wrongfully adding and subtracting terms from the CBA. The district court granted summary judgment in favor of the Union. Nonetheless, the district court denied costs and fees pursuant to Fed. R. Civ. P. 11. The First Circuit Court of Appeals affirmed, holding (1) no grounds existed on which to vacate the arbitral award; and (2) the district court did not abuse its discretion by denying costs and fees. View "N. New England Telephone Operations LLC v. Local 2327, Int'l Brotherhood of Elec. Workers, ALF-CIO" on Justia Law

Plaintiff, the Chairman of the Trustees of the Rhode Island Bricklayers Benefits Funds (the Funds), sued Union Stone Inc., alleging that Union Stone had failed to pay the full amount of fringe benefit contributions due for work performed in Massachusetts and Connecticut by members of the International Union of Bricklayers and Allied Craftworkers pursuant to a collective bargaining agreement. After a trial, the district court entered judgment in favor of the Funds, awarding the unpaid contributions, interest, and attorneys' fees. The First Circuit Court of Appeals affirmed, holding that the district court did not err in (1) refusing to enforce a purported settlement agreement between the parties; (2) admitting certain evidence on the ground that it was tainted by violations of the discovery rules; (3) declined to impose sanctions; and (4) awarding interest and attorneys' fees. View "Enos v. Union Stone, Inc." on Justia Law