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

Plaintiff, an instructor in graphics who did not have a Ph.D., was denied a tenure-track position at the University of Puerto Rico. Three others, all of whom had Ph.D.s as the description required, did receive tenure-track positions. Plaintiff filed administrative discrimination charges, followed by a Title VII lawsuit against the University. The district court granted summary judgment for the University. The First Circuit Court of Appeals affirmed, holding that the Ph.D. requirement for tenure-track positions was a legitimate, nondiscriminatory reason for the University's actions and that Plaintiff did not meet her burden of showing that the articulated reason was pretextual. View "Johnson v. Univ. of P.R." on Justia Law

The United States Postal Services (USPS) terminated Plaintiff's employment contract after discovering, through a sting operation, that Plaintiff had stolen mail containing money. The Postal Service Board of Contract Appeals (PSBCA) convened an evidentiary hearing and determined that Plaintiff's breach of his employment contract justified the decision to terminate his contract. Plaintiff did not appeal this decision. Meanwhile, Plaintiff initiated a Federal Tort Claims Act (FTCA) suit against the United States for the actions of USPS employees on the date of the sting, alleging six torts. The district court dismissed three of the claims and granted summary judgment to the government on the remaining claims. The First Circuit Court of Appeals affirmed the district court as to all claims, holding (1) the district court correctly concluded that the PSCBA's findings precluded relitigation of the factual issues in Plaintiff's FTCA suit; and (2) summary judgment was properly granted as to Plaintiff's FTCA claims for negligent supervision, malicious prosecution, and invasion of privacy by postal inspectors. View "Rios-Pineiro v. United States" on Justia Law

After exhausting her administrative remedies, Plaintiff, together with her husband and their conjugal partnership, sued Employer under Title VII, alleging sex discrimination in the form of hostile-work-environment harassment, and retaliation for challenging the harassment. A magistrate judge entered summary judgment for Employer on all claims. The Supreme Court affirmed, holding (1) ultimately, Plaintiff had no sex discrimination claim against Employer and so summary judgment was appropriate on that claim; (2) the evidence did not show that Employer infracted Title VII by retaliating against Employee for alleging that Employer discriminated against her on the basis of sex; and (3) Plaintiff could not prevail on her claim that the federal court judge was "bound" by Puerto Rico's summary-judgment policy. View "Medina-Rivera v. MVM, Inc." on Justia Law

Former employees (Plaintiffs) of a failed bank taken into receivership by the Federal Deposit Insurance Corporation (FDIC) sued Banco Popular de Puerto Rico (BPPR), a bank that subsequently acquired the failed bank's deposits and certain assets on claims for severance pay. The FDIC intervened, asserting that the district court lacked jurisdiction over the claims because Plaintiffs either failed to file administrative claims with the FDIC or failed to challenge in federal court the FDIC's disallowance of their administrative claims. BPPR moved for summary judgment, arguing that it was not liable for any severance claims for at least three different merits-based reasons. The district court granted summary judgment for BPPR and did not address the question of whether it had jurisdiction. The First Circuit Court of Appeals vacated entry of summary judgment for Defendants and remanded with instructions to dismiss for lack of subject-matter jurisdiction, holding that Plaintiffs' failures to comply with the Financial Institutions Reform, Recovery, and Enforcement Act administrative claims process triggered the statutory bar, and Plaintiffs could not avoid the jurisdictional bar by failing to name the FDIC as a defendant. View "Acosta-Ramirez v. Banco Popular de Puerto Rico" on Justia Law

Plaintiffs were former employees of the Puerto Rico Administration of Juvenile Institutions. After an election that produced a regime change, Plaintiffs were ousted from their positions, notwithstanding solid qualifications and positive evaluations. Plaintiffs sued several government defendants, invoking 42 U.S.C. 1983 and alleged discrimination based on political affiliation in violation of the First Amendment. Plaintiffs also lodged pendent claims under Puerto Rico law. The district court ruled that the complaint failed to state a claim for relief because it did not assert facts sufficient to establish a prima facie case of political discrimination. The First Circuit Court of Appeals reversed in part, holding (1) the prima facie case is not the appropriate benchmark for determining whether a complaint has met the plausibility standard under Bell Atlantic v. Twombly; (2) the factual allegations in Plaintiffs' complaint, taken as true, state plausible section 1983 claims for political discrimination with respect to two of the defendants; and (3) the pendent claims against those two defendants, which were dismissed without prejudice when the district court declined to exercise supplemental jurisdiction, must be reinstated. Remanded. View "Rodriguez-Reyes v. Molina-Rodriguez" on Justia Law

Plaintiff, an Egyptian-American, filed a workplace discrimination suit against the Mohegan Council, Boy Scouts of America alleging that he was denied career advancement opportunities on account of his religion of Islam and his national origin. After a jury trial, the district court ruled in favor of Plaintiff. The First Circuit Court of Appeals affirmed, holding that the district court did not err in denying Mohegan Council's motion for judgment as a matter of law, where (1) the district court correctly found that Mohegan Council was an "employer" with the requisite fifteen or more employees under the Title VII of the Civil Rights Act of 1964; (2) Plaintiff's complaint with the Massachusetts Commission Against Discrimination was timely filed; and (3) sufficient evidence supported a finding of discrimination. View "Aly v. Mohegan Council, Boys Scouts of Am." on Justia Law

Plaintiff, an international affairs specialist at the Puerto Rico State Department, filed a complaint against the Department, ten of its employees, the Commonwealth (collectively, the State Department defendants), and the Puerto Rico Ports Authority. Plaintiff alleged that the State Department defendants had discriminated against her due to her political views and that they had denied her the rights and benefits to which she was entitled under federal and local law. As against the Ports Authority, Plaintiff alleged it slandered her by publishing false information regarding an arrest for marijuana, which prevented her from fulfilling her work duties. The district court found that Plaintiff's complaint failed to state a claim upon which relief could be granted and dismissed the complaint. Plaintiff appealed, requesting a reversal of the district court's refusal to grant leave to amend the complaint based upon its finding that amendment would be futile. The First Circuit Court of Appeals affirmed, holding that the district court did not abuse its discretion in denying the requested amendment. View "Flores-Silva v. McClintock-Hernandez" on Justia Law

Plaintiffs were several dismissed or demoted employees of the State Insurance Fund Corporation, a public corporation that administered Puerto Rico's workers' compensation program. Before the adverse employment actions took effect, Plaintiffs requested informal administrative hearings before the Corporation. Plaintiffs then filed administrative appeals before the Corporation's board of appeals. The board had not acted on the appeals when Plaintiffs sued the Corporation and several of its officers in the U.S. district court, alleging political discrimination and due process violations stemming from adverse employment actions. The district court abstained under Younger v. Harris and dismissed Plaintiffs' claims, finding that Plaintiffs voluntarily engaged the wheels of an administrative procedure before filing an action in federal court. The First Circuit Court of Appeals reversed, holding (1) the district court erred in abstaining based on Younger, and dismissal was not the remedy in any event; and (2) a stay of the federal proceedings was appropriate in this case pending the Puerto Rico Supreme Court's decision in Gonzales Segarra v. State Ins. Fund Corp. View "Casiano-Montanez v. State Ins. Fund Corp." on Justia Law

Plaintiff, a nurse working for Employer, was injured during a horseback riding accident. Plaintiff's employment was later terminated. Plaintiff filed a complaint against Employer, alleging Employer retaliated against her for requesting an accommodation in violation of the Americans with Disabilities Act (ADA) and the Maine Human Rights Act (MHRA). The district court granted summary judgment in favor of Employer, concluding that Plaintiff had failed to adduce evidence that Employer's stated basis for terminating Plaintiff was pretextual and that Plaintiff's evidence of retaliatory animus was too conclusory and speculative to take to trial. The First Circuit Court of Appeals vacated the entry of summary judgment on Plaintiff's retaliation claims under the ADA and MHRA, holding that Plaintiff presented sufficient evidence to bring to a jury. Remanded. View "Kelley v. Corr. Med. Servs., Inc." on Justia Law

Plaintiff was a partner in a medical practice where she served as a staff anesthesiologist. When Plaintiff's dependence on opioids came to light, her employer had in force a group employee benefit plan, underwritten and administered by Union Security Insurance Company & Management Company for Merrimack Anesthesia Associates Long Term Disability Plan (USIC), which included long-term disability (LTD) benefits. When Plaintiff applied for those benefits, USIC refused to pay benefits past the point when Plaintiff was discharged from a treatment center, finding that Plaintiff's risk for relapse was not the same as a current disability. Plaintiff brought suit in the federal district court. The district court ultimately awarded Plaintiff LTD benefits for the maximum time available under the plan, concluding that categorically excluding the risk of drug abuse relapse was an unreasonable interpretation of the plan. The First Circuit Court of Appeals affirmed, holding that, in an addiction context, a risk of relapse can be so significant as to constitute a current disability. View "Colby v. Union Sec. Ins. Co." on Justia Law