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

Appellant was a former teacher in the town of Dracut, Massachusetts public schools. During the beginning of the 2009-2010 school year, Appellant failed to appear at school. Appellant subsequently applied for Family Medical Leave Act (FMLA) leave but did not notify the Dracut superintendent in writing of his request for FMLA leave, nor did he return a completed medical certification in accordance with Dracut's FMLA leave policy. On September 28, 2009, Appellant was terminated for abandoning his position. Appellant filed this suit in 2011 against individual decision-makers in the Dracut schools, alleging (1) violations of his rights under the FMLA; and (2) intentional infliction of emotional distress and intentional interference with advantageous business relations in violation of Massachusetts state law. The district court granted summary judgment for Defendants, concluding that Appellant had not worked enough to be eligible for FMLA leave and otherwise finding Appellant's claims meritless. The First Circuit Court of Appeal affirmed, holding (1) Appellant was not eligible for FMLA leave; (2) Appellant did not establish that Dracut's handling of his FMLA leave application caused him any harm; (3) Dracut did not unlawfully retaliate against Appellant; and (4) Appellant's state law claims against Defendants were without merit. View "McArdle v. Town of Dracut, Mass." on Justia Law

Plaintiff was employed by Pfizer Pharmaceuticals, LLC as an active pharmaceutical ingredient (API) group leader. In 2008, Plaintiff, member of the U.S. Navy, was called to active duty. During Plaintiff's tour of duty, Pfizer restructured its API department, eliminating the API group leader position and replacing it with two separate classifications, API team leader and API service coordinator. After being discharged from active military service, Plaintiff was appointed to the API service coordinator position. Plaintiff subsequently filed suit against Pfizer, asserting Uniformed Services Employment and Reemployment Rights Act claims and pendant state law claims, alleging, inter alia, that Pfizer violated his rights by failing to provide him with an opportunity to apply for the API team leader position. The district court concluded that because the API team leader was not an automatic promotion, the escalator principle and reasonable certainty test did not apply to Plaintiff's claim. The First Circuit Court of Appeals vacated the district court's judgment and remanded, holding that the escalator principle and reasonable certainty test apply regardless of whether the promotion at issue is automatic or non-automatic. View "Rivera-Melendez v. Pfizer Pharms., LLC" on Justia Law

Plaintiff was a teacher in the Manchester-Essex Regional School District until he was informed by the District Superintendent's intention to terminate his employment for inappropriate sexual conduct toward a student. Plaintiff sought review of the Superintendent's action. An arbitrator affirmed Plaintiff's dismissal. Plaintiff then filed suit in Massachusetts superior court challenging his dismissal and seeking to vacate the arbitrator's decision. Three weeks later, Plaintiff filed this complaint in federal court alleging state and federal law violations. The next day, Plaintiff amended his state-court complaint so it contained the exact same claims as his federal-court complaint. The state court rejected Plaintiff's claims and affirmed the arbitrator's decision. Later, the federal district court granted summary judgment against Plaintiff, finding that Plaintiff's claims were barred by res judicata. The First Circuit Court of Appeals affirmed, holding that none of the reasons presented by Plaintiff why res judicata did not bar his federal claims from adjudication in federal court were persuasive. View "Atwater v. Driscoll" on Justia Law

Plaintiff began working for INSEC in 1988. In 2003, employees under her charge began complaining of misconduct, mistreatment, and abuse. INSEC responded with progressive disciplinary sanctions, ultimately terminating her employment in 2009. Plaintiff sued, alleging violation of the Age Discrimination in Employment Act, 29 U.S.C. 621-634, and local law. In its initial scheduling order, the district court set a discovery deadline of October 30, 2011: more than a year after commencement of the action and more than seven months after the initial scheduling conference. The order contained a stern warning. On October 12, 2011, the plaintiff filed an unopposed motion to extend the discovery deadline to November 15. The district court allowed the extension. On November 15 the plaintiff claimed for the first time that documents produced during the extension were not responsive to her request. Two days later, the plaintiff moved for a further extension of the deadline. INSEC opposed the motion, maintaining that the plaintiff’s claimed plight was attributable to her own lack of diligence and that most of the requested documents did not exist and that others were so vaguely described that compliance was impossible. The district court entered summary judgment for INSEC. The First Circuit affirmed. View "Rivera-Almodovar v. Instituto Socioeconomico" on Justia Law

Appellant was placed on disability leave from work. Appellant was covered under a long term disability (LTD) policy that her employer obtained from Medical Group Insurance Services (MGIS). The policy was written by Sun Life Assurance Company (Sun Life). After leaving her job, Appellant filed a claim with MGIS seeing long term disability benefits. Sun Life denied Appellant's request for benefits. Appellant filed an action against Sun Life, asserting various state law claims. The federal district court dismissed the action based on ERISA preemption. Appellant then amended her complaint to add ERISA claims and asked the district court to apply de novo review in its evaluation of her ERISA claims. The court denied the motion and granted summary judgment for Sun Life, concluding that Sun Life's decision to deny benefits was not arbitrary and capricious, and thus complied with ERISA's requirements. The First Circuit Court of Appeals vacated the judgment, holding (1) the safe harbor exception to ERISA did not apply to the policy covering Appellant, and therefore, Appellant's state law claims were preempted; but (2) the benefits denial was subject to a de novo review, rather than the highly deferential "arbitrary and capricious" review prescribed for certain ERISA benefits decisions. Remanded. View "Gross v. Sun Life Assurance Co. of Canada" on Justia Law

Plaintiff filed a lawsuit against Defendant, her former employer, alleging that Defendant fired her in retaliation for her hemorrhoids-induced absences in violation of the Family and Medical Leave Act (FMLA). The district court granted summary judgment for Defendant, finding that Plaintiff failed to show she suffered a "serious health condition" as defined by the FMLA. Plaintiff moved for reconsideration, alleging that her medical records constituted newly discovered evidence that her hemorrhoids satisfied the definition of a serious health condition. The district court denied Plaintiff's motion, determining that almost all the records on which the motion relied upon had been emailed to Plaintiff's counsel, where they languished. Plaintiff moved for relief from the judgment, arguing that her counsel's failure to introduce the medical records was the product of either excusable neglect or fraud. The district court denied the motion. The First Circuit Court of Appeals affirmed, holding that exceptional circumstances did not warrant extraordinary relief. View "Nansamba v. North Shore Med. Ctr., Inc." on Justia Law

Plaintiffs, current and former employees of Boston Medical Center (BMC), brought this wage-and-hour action against BMC, BMC's former president and COE, and BMC's former senior human resources officer, alleging that Defendants deprived them of their wages through the use of timekeeping policies and employment practices that required them to put in extra work time in addition to their regularly scheduled work shifts and to work through their meal and rest periods. Plaintiffs asserted causes of action under the Fair Labor Standards Act (FLSA) and Massachusetts common law. The federal district court granted Defendants' motion to dismiss in its entirety. The First Circuit Court of Appeals (1) vacated the dismissal of the FLSA claim against BMC and its former CEO, the contract claims, and the money had and received, unjust enrichment, and conversion claims; (2) vacated the district court's order striking the class and collective action allegations; and (3) otherwise affirmed. Remanded. View "Manning v. Boston Med. Ctr. Corp." on Justia Law

Plaintiff terminated Defendant from employment. Thereafter, Defendant began arbitration proceedings seeking severance compensation he felt was contractually due. After arbitration hearings had commenced, the hearings were postponed for two months due to a medical situation afflicting Plaintiff's counsel. During the recess, Plaintiff formally requested pre-hearing and hearing third-party subpoenas directed at Defendant's current employer. The tribunal denied the issuance of the subpoenas. After the arbitration hearings resumed, the tribunal found Defendant was entitled to compensation pursuant to the terms of his employment agreement dealing with his termination without cause. The tribunal also found Defendant was entitled to pre-award interest. Plaintiff subsequently sought vacatur of the award, which the trial court denied. The First Circuit Court of Appeals affirmed, holding (1) the arbitration tribunal did not engage in misconduct by denying the issuance of the pre-hearing and hearing subpoenas; and (2) the tribunal did not exceed its authority in awarding pre-award interest to Defendant. View "Doral Fin. Corp. v. Garcia-Velez" on Justia Law

This case concerned the withdrawal liability for a pro rata share of unfunded vested benefits to a multiemployer pension fund of Scott Brass, Inc. (SBI), a bankrupt company. SBI had withdrawal pension obligations to the multiemployer pension fund (TPF), which sought to impose the obligations on two private equity funds (Plaintiffs). Plaintiffs asserted they were passive investors that indirectly controlled SBI and sought a declaratory judgment against the TPF. The TPF counterclaimed and sought payment of the withdrawal liability at issue. The district court entered summary judgment for Plaintiffs. The First Circuit Court of Appeals affirmed in part, reversed in part, and vacated in part, holding (1) at least one of the private equity funds that operated SBI sufficiently operated and was advantaged by its relationship with SBI, and further factual development was necessary as to the other equity fund; (2) the district court erred in entering summary judgment for Plaintiffs under the "trades or businesses" aspect of a two-part "control group" test under 29 U.S.C. 1301(b)(1); and (3) the district court correctly entered summary judgment for Plaintiffs on TPF's claim of liability on the ground that the funds had engaged in a transaction to evade or avoid withdrawal liability. Remanded. View "Sun Capital Partners III, LP v. New England Teamsters & Trucking Indus. Pension Fund" on Justia Law

Plaintiff served as the human resources director of two Puerto Rico governmental agencies. Plaintiff resigned one position and was terminated from the other. Plaintiff sued her former supervisors under 42 U.S.C. 1983 and Puerto Rico law, alleging that she was retaliated against due to her allegiance with a certain political faction disfavored by Defendants and because she refused to follow personnel-related orders that she considered illegal and politically motivated. The district court dismissed some of Plaintiff's claims and granted summary judgment on the remainder. The First Circuit Court of Appeals affirmed in all respects, holding that the district court did not err (1) in dismissing Plaintiff's First Amendment free speech claim, as Plaintiff's "speech" exclusively revolved around her professional duties as human resource director; (2) in dismissing a claim Plaintiff made under the Puerto Rico Whistleblowers Protection Act, as Plaintiff failed to raise her meritorious arguments regarding this claim in district court; and (3) in granting summary judgment on Plaintiff's freedom of association claim, as the First Amendment was inapplicable to Plaintiff's position as human resources director. View "O'Connell v. Marrero-Recio" on Justia Law