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

The worker is a Massachusetts resident, whose services were obtained through a temporary labor firm's offices in Massachusetts, and was injured while working for a construction company at the Newport Naval Station. The temporary firm, which maintains workers compensation insurance, filed a Rhode Island workers compensation claim on behalf of the worker, but without his knowledge. The worker received benefits for 17 weeks, then sought Massachusetts benefits. A Massachusetts administrative law judge ordered the Massachusetts insurance company to assume responsibility for future payments. The district court entered summary judgment, rejecting the worker's suit against the construction company and a co-worker. The First Circuit reversed and remanded. Applying Massachusetts choice-of-law rules, the court concluded that the states' laws conflict and that Massachusetts law applies because that state has a more significant connection to the parties and the occurrence. Massachusetts prohibits suits against direct employers only; Rhode Island prohibits suit against "special employers" who contract with a general employer for the worker's services. The immunity of co-employees derives from employer immunity and does not apply in this case.

A black police officer, assigned to the drug prevention division of the Puerto Rico police department, was reassigned to a less-desirable position after a lieutenant made racial slurs and statements that she did not want him. One position that subsequently opened in the drug prevention division was not filled; another position was filled by a white person with less education than the black officer. The district court dismissed civil rights claims (42 U.S.C. 1983) and claims under Title VII (42 U.S.C. 2000) against individual supervisors. The First Circuit vacated and remanded. Failure to name the police department as a defendant did not justify dismissal under Title VII; the supervisors acted as agents of the department. The complaint plausibly alleged equal protection violations.