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

Verizon New England, Inc. was a party to a collective bargaining agreement (CBA) with six electrical workers unions. After Verizon and the unions were unable to reach a new agreement before the CBA expired, the union members commenced a large-scale work stoppage. After the employees returned to work, several members of various unions employed by Verizon in Rhode Island applied for unemployment benefits. The Rhode Island Department of Labor and Training (RIDLT) denied unemployment benefits, but the RIDLT's board of review reversed. Verizon subsequently filed a federal court action against RIDLT and claimant union members, arguing that the board's decision to award unemployment benefits should not be enforced, as it was preempted by the National Labor Relations Act (NLRA). The district court dismissed the complaint, holding (1) the NLRA does not preempt a state's ability to provide strikers unemployment benefits; and (2) the action must be dismissed under the Younger absention doctrine. The First Circuit Court of Appeals affirmed but on the singular ground that the dismissal was warranted under the Younger absention doctrine. View "Verizon New England, Inc. v. R.I. Dep't of Labor & Training" on Justia Law

After Plaintiff was suspended, he was discharged from his employment with the Massachusetts Bay Transportation Authority (MBTA). An arbitrator ruled that the MBTA had lacked just cause to terminate him, and the MBTA subsequently reinstated Plaintiff to his former position. Thereafter, Plaintiff filed a complaint against the MBTA, alleging, among other things, that his discharge constituted racial discrimination and that the MBTA unlawfully retaliated against him for writing a letter to Senator Edward Kennedy after MBTA officials recommended firing Plaintiff. The district court granted summary judgment to the MBTA on all claims. The First Circuit Court of Appeals affirmed, holding (1) MBTA's merely questionable behavior did not show minimally sufficient evidence of pretext sufficient to support a discrimination claim; and (2) the district court correctly held that there was no causal link between Plaintiff's letter and his termination. View "Pearson v. Mass. Bay Transp. Auth." on Justia Law

This appeal concerned the decade-long litigation of Relator's qui tam action against Defendant for alleged violations of the federal False Claims Act (FCA). The claims arose from Defendant's efforts to promote the pharmaceutical drug Procrit. The First Circuit Court of Appeals reversed and remanded as to the district court's determination that Relator's kickback claims in Count I of the amended complaint were not pled with sufficient particularity. On remand, the district court imposed limitations on the scope of Relator's discovery for the kickback claims. At the discovery's conclusion, Relator agreed it had not identified any admissible evidence to support the remaining Count I claims, and the district court granted summary judgment for OBP on that basis. The First Circuit affirmed, holding that the discovery limitations imposed by the district court were proper, and therefore, the district court did not err in granting OBP's motion for summary judgment on the basis of Relator's stipulation that she did not possess evidence to support her remaining Count I claims. View "United States ex rel. Duxbury v. Ortho Biotech Prods., LP" on Justia Law

Plaintiff was terminated from his employment with Employer, ostensibly for his failure to properly investigate, document, and ameliorate the misconduct of an employee under his supervision. The termination occurred just months before Plaintiff was to receive a $60,000 bonus. Plaintiff filed an action against Employer to recover the bonus on the grounds that he was terminated without good cause. The U.S. district court granted summary judgment to Employer on Plaintiff's Massachusetts Wage Act claim and allowed Defendant's breach of contract claim to go to the jury. The jury found for Plaintiff. The First Circuit Court of Appeals (1) reversed the jury verdict, holding that whether Plaintiff was terminated without good cause and thus remained eligible for the bonus was a decision within the ambit of the sole and final decision-making authority of Employer's Employment Benefits Committee under the company's "Commitment to Success Bonus Plan"; and (2) affirmed the summary judgment order in Employer's favor, as Employer was under no obligation to pay the bonus. View "Weiss v. DHL Express, Inc." on Justia Law

Appellant, on behalf of the United States, brought a qui tam action under the False Claims Act (FCA) against Guidance Corporation and Boston Scientific Corporation (BSC), alleging they engaged in a kickback scheme to promote the sale and use of their cardiac rhythm management devices. However, a former employee of BSC had previously filed a qui tam action against BSC, which was later dismissed, alleging similar claims. The district court dismissed Appellant's complaint for lack of subject matter jurisdiction on the basis that the earlier-filed complaint barred consideration of Appellant's complaint under the first-to-file rule of the FCA, 31 U.S.C. 3730(b)(5). Appellant appealed, arguing that the earlier-filed complaint could not serve as a preclusive first-filed complaint to trigger the first-to-file bar because it did not meet the heightened pleading standard under Fed. R. Civ. P. 9(b). The First Circuit Court of Appeals affirmed, holding that section 3730(b)(5) does not require the first-filed complaint to meet the heightened pleading standards of Rule 9(b) to bar a later-filed complaint. View "United States ex rel. Heineman-Guta v. Guidant Corp." on Justia Law

When a tire company closed its plant in Puerto Rico, it offered its employees severance pay contingent upon the execution of general releases. Plaintiff, a former employee of the company, accepted the severance package and signed the proffered release. Almost one year later, Plaintiff sued the company, asserting claims for unjust dismissal under Puerto Rico law. The district court dismissed the case. Plaintiff appealed the dismissal of his claim under a protective Puerto Rico statute, P.R. Laws Ann. Tit. 29, 185a-185m, known as Law 80. The First Circuit Court of Appeals vacated the order of dismissal as to the Law 80 claim and remanded, holding that, in the interests of comity and federalism, the antecedent issue about whether Law 80 applied at all to Plaintiff's discharge should be decided before the question of statutory interpretation raised by the parties. View "Ruiz-Sanchez v. Goodyear Tire & Rubber Co." on Justia Law

Plaintiff was a police dispatcher with the Town of Camden Police Department for thirty-one years until his department was eliminated and he was laid off. In the year following Plaintiff's termination, at least two positions opened with the police department for which Plaintiff was qualified. The Town did not recall Plaintiff to either position. Plaintiff subsequently brought a procedural due process against the Town under 42 U.S.C. 1983, alleging that the Town deprived him of a constitutionally protected property interest in his right to be recalled to employment. The district court dismissed Plaintiff's complaint. The First Circuit Court of Appeals vacated the district court's order, holding (1) the district court correctly found that Plaintiff's complaint alleged a protected property interest in his recall right; but (2) the district court erred in concluding that Plaintiff's potential recourse to state law foreclosed his section 1983 claim, as Plaintiff's injury could not be fully redressed by recourse to a state law breach of contract claim or the grievance procedures in a collective bargaining agreement. Remanded. View "Clukey v. Town of Camden" on Justia Law

Plaintiff, an employee of Defendant, filed claims against Defendant for unlawful employment retaliation under Title VII of the Civil Rights Act. Plaintiff alleged that she was subject to several adverse employment actions that were taken in retaliation for occasions on which Plaintiff called attention to Defendant's purportedly discriminatory employment practices. The district court granted summary judgment for Defendant, concluded that, as to the two aspects of her employment at issue, Plaintiff had neither established a prima facie case of retaliation nor shown that Defendants' stated rationales for their purportedly unlawful actions toward her were pretextual. The First Circuit Court of Appeals affirmed, holding that no reasonable fact-finder could resolve the issues in Plaintiff's favor. View "Colon v. Tracey" on Justia Law

Appellant was a probationary public employee of the Town of Smithfield, Rhode Island. The Town hired Appellant on the condition that he obtain his building official certification. After Appellant failed to obtain the certification, the Town terminated Appellant. Appellant filed a complaint against the Town and its officials, alleging that he received insufficient procedural due process in violation of the Fourteenth Amendment when his employment was terminated and that the Town violated the Rhode Island Constitution and Rhode Island Whistleblowers' Protection Act when it fired him. Defendants removed the case to federal court. The district court granted Defendants' motion for summary judgment on all counts. The First Circuit Court of Appeals affirmed, holding (1) Appellant received constitutionally adequate procedural due process; and (2) the district court acted within its discretion in reaching and resolving the state law claims after ruling against Appellant on the sole federal claim. View "Senra v. Town of Smithfield" on Justia Law

Plaintiff was hired by Employer in 2000 and began working as part of a five-person sales team. In 2009, Employer reduced the sales team to two employees and terminated Defendant. Plaintiff was fifty-five years old at the time. Plaintiff subsequently file a complaint with the Massachusetts Commission Against Discrimination (MCAD), alleging age discrimination. MCAD dismissed Plaintiff's complaint for a lack of probable cause. Plaintiff then brought suit in state court, claiming age discrimination under Massachusetts law. Employer removed the case to the U.S. district court based on diversity jurisdiction. Thereafter, the district court granted Employer's motion for summary judgment. The Supreme Court affirmed, holding that the district court did not err (1) in partially denying Plaintiff's third motion to compel; (2) in quashing deposition notices for three of Employer's employees; and (3) in granting summary judgment to Employer. View "Woodward v. Emulex Corp." on Justia Law