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

In the case before the United States Court of Appeals for the First Circuit, a collective of long-haul truck drivers, led by Juan Carlos Montoya, contended that their employer, CRST Expedited and CRST International (collectively referred to as "CRST"), violated the Fair Labor Standards Act (FLSA) by not compensating them for time spent in a truck's sleeper berth exceeding eight hours within a 24-hour period. CRST operates a "team driving model" where two drivers alternate between driving and resting in the sleeper berth of the truck, allowing the vehicle to be in near-continuous motion. The drivers argued that the time spent in the sleeper berth was "on duty" time, as defined by Department of Labor regulations, and thus should be compensated as work. The district court granted summary judgment for the drivers, determining that such time was indeed compensable work. The Court of Appeals affirmed this decision, holding that the time drivers spend in the sleeper berth that exceeds eight hours per day is compensable work under the FLSA. The Court reasoned that the drivers' confinement to the sleeper berth, the importance of continuous travel to CRST's business model, and the potential burdens placed on the drivers suggest that the time predominantly benefits the employer. Furthermore, the Court interpreted the Department of Labor regulations to allow an employer to exclude a sleeping period of no more than eight hours from hours worked in a 24-hour period. View "Montoya v. CRST Expedited, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment in favor of the U.S. Department of Veterans Affairs (VA) in this lawsuit alleging disability discrimination, hostile work environment, and other claims, holding that there was no error in the proceedings below.Plaintiff filed this action claiming disability discrimination under the Rehabilitation Act (RA), hostile work environment under the RA and Americans with Disabilities Act, retaliation in violation of Title VII, and failure to accommodate under the RA. The district court granted summary judgment in favor of the VA on all counts. The First Circuit affirmed, holding that the district court (1) correctly concluded that 5 U.S.C. 8461(d) did not bar its review of Plaintiff's claims at summary judgment; (2) did not err in rejecting Plaintiff's preclusion claim; and (3) did not err in granting summary judgment. View "Dixon-Tribou v. McDonough" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment for Defendant on Plaintiff's claims for disability discrimination, in violation of Title I of the Americans with Disabilities Act (ADA) and Mass Gen. Laws ch. 151B, and for age discrimination, in violation of Mass. Gen. Laws ch. 151B, holding that there was no error.The district court (1) concluded that Plaintiff had failed to carry her burden to make out a prima facie case that she was a "qualified individual" under the ADA and thus also failed to do so under chapter 151B; and (2) concluded that Plaintiff had failed to demonstrate a genuine dispute of material fact as to whether Defendant's proffered reason for her termination was pretextual. The First Circuit affirmed, holding (1) Defendant was entitled to summary judgment on Plaintiff's ADA and Mass. Gen. Laws ch. 151B disability discrimination claims; and (2) the district court did not err in granting summary judgment for Defendant on Plaintiff's claim of age discrimination under Mass. Gen. Laws ch. 151B. View "Der Sarkisian v. Austin Preparatory School" on Justia Law

The First Circuit reversed the judgment of the district court concluding that the City of Malden had violated the Massachusetts Wage Act, Mass. Gen. Laws ch. 149, 148 (the Wage Act) and Mass. Gen. Laws ch. 44, 53C (the Municipal Finance Law), holding that there was no violation of the Wage Act or Municipal Finance Law in this case.Plaintiffs, City of Malden police officers, sued the City, arguing that a term in the collective bargaining agreement (CBA) that set the hourly rate for police detail work aligned with how they were historically paid and that a ten percent deduction for an administrative fee resulted in a reduction in their wages as set forth in the CBA, in violation of the Wage Act. The district court ruled that the contract term was ambiguous and, after hearing witness testimony, ruled that the City violated the Municipal Finance Law and the Wage Act. The First Circuit reversed, holding (1) the contract term was unambiguous in favor of the City; (2) any reduction in the calculated rate still resulted in a higher payout than contemplated in the CBA, and therefore, there was no Wage Act violation; and (3) the district court clearly erred in finding that the City had violated the Municipal Finance Law. View "Owens v. City of Malden" on Justia Law

The First Circuit affirmed in part and vacated in part the judgment of the district court denying Appellants' request for preliminary injunctive relief from the COVID-19 vaccine policy of Woods Hole, Martha's Vineyard and Nantucket Steamship Authority, holding that remand was required.At issue was Executive Order No. 595, which the Governor of the Commonwealth of Massachusetts issued in response to the COVID-19 pandemic. In response to the order, the Authority issued its own vaccine policy requiring all Authority employees to be fully vaccinated. Appellants, Authority employees, submitted timely requests for religious exemptions from the policy, but the requests were denied. Appellants brought this action under 42 U.S.C. 1983 claiming Appellees denied their rights under the Free Exercise Clause of the First Amendment and also pleading state-law claims. The district court denied relief. The First Circuit affirmed in part and vacated in part, holding that the district court's "likelihood of success" ruling was erroneous. View "Brox v. Woods Hole" on Justia Law

The First Circuit affirmed the judgment of the district court denying Plaintiff's claims against Defendant, Tufts University, on summary judgment and refusing to alter to amend that ruling under Fed. R. Civ. P. 59(e), holding that there was no error.Plaintiff sued Tufts, her former employer, alleging that she was denied a full professor position on the basis of sex discrimination and/or retaliation for engaging in protected conduct in violation of federal and state anti-discrimination laws, specifically, for her filing a claim of sexual harassment. The district court granted summary judgment for Tufts. The First Circuit affirmed, holding that the district court (1) correctly entered summary judgment in favor of Tufts on Plaintiff's discrimination and retaliation claims; and (2) did not err in denying Plaintiff's motion for an altered or amended judgment pursuant to Rule 59(e). View "Ing v. Tufts University" on Justia Law

The First Circuit certified to the Massachusetts Supreme Judicial Court (SJC) the unresolved question of what is meant, in the context of a franchise agreement, by "performing any service," as that phrase is used in the Massachusetts Independent Contractor Law (ICL), Mass. Gen. Laws ch. 149, 148B(a).Plaintiffs, owners and operators of 7-Eleven franchises in Massachusetts, filed a putative class action against 7-Eleven, Inc. for alleged violations of the Massachusetts ICL, the Massachusetts Wage Act, and the Massachusetts Minimum Wage Law, challenging 7-Eleven's decision to classify them as independent contractors rather than employees. The district court ruled in favor of 7-Eleven and then, after remand, ruled for 7-Eleven again. At issue was whether Plaintiffs performed "any service" for 7-Eleven under the Massachusetts ICL. The First Circuit certified to the Massachusetts SJC the following question: Do Plaintiffs perform "any service" for 7-Eleven within the meaning of the Massachusetts ICL where they perform various contractural obligations under their franchise agreement and 7-Eleven receives a percentage of the franchise's gross profits. View "Patel v. 7-Eleven, Inc." on Justia Law

The First Circuit affirmed the district court's order entering summary judgment in favor of Defendant with respect to Plaintiff's assertion that he was wrongfully deprived of thousands of dollars in commissions he alleged he was due, holding that there was no error.After he resigned, Plaintiff brought suit against Defendant, his former employer, asserting claims for nonpayment of wages under the Act, breach of contract, unjust enrichment, and quantum meruit. Defendant successfully removed the action to federal district court, which granted summary judgment in favor of Defendant. The First Circuit affirmed, holding that the district court (1) did not err in granting in part Defendant's motion to strike certain portions of his response to the summary judgment motion; and (2) did not err in granting summary judgment against Plaintiff on his claims. View "Klauber v. VMware, Inc." on Justia Law

The First Circuit affirmed in part and reversed in part the order of the district court in the underlying action originally brought by Peter Marcus against the American Contract Bridge League (ACBL), where Marcus was formerly employed, holding that the district court erred in part.In the underlying amended complaint, Marcus and his co-plaintiffs sought unpaid overtime wages under the Fair Labor Standards Act (FSLA), 29 U.S.C. 207(a), and Marcus asserted that he was wrongfully discriminated and retaliated against for requesting his claimed pay. The district court entered summary judgment for certain plaintiffs and, as to Marcus's retaliation claim, entered summary judgment for ACBL. The First Circuit reversed in part and remanded the case, holding that the district court (1) erred in denying Plaintiffs' motion to substitute a party; (2) correctly granted judgment in favor of ACBL on Marcus's retaliation claim; (3) erred in granting judgment with respect to the FSLA overtime claims of certain plaintiffs; and (4) otherwise did not err. View "Marcus v. American Contract Bridge League" on Justia Law

The First Circuit affirmed the rulings of the district court requiring Timothy Day to pay NuVasive, Inc., his former employer, more than $1.7 million in damages and attorney's fees for breach of contract and spoliation of evidence, holding that the district court did not err or abuse its discretion.NuVasive brought suit against Day making claims arising from Day's business interactions with NuVasive's customers on behalf of Alphatec Spine, Inc., Day's new employer, in violation of non-competition and non-solicitation obligations in Day's contract with NuVasive. After the district court entered its final judgment Day appealed, arguing that the court erred in finding the requisite causal nexus between Day's improper solicitations and the decisions of certain NuVasive customers to switch to Alphatec as their primary supplier of spine-related surgical products. The First Circuit affirmed, holding that there was no error in the damages award or the sanctions-based award of attorney's fees and costs. View "NuVasive, Inc. v. Day" on Justia Law