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

The First Circuit affirmed the decision of the district court denying motion for a preliminary injunction sought by Appellants, then-employees of Mass General Brigham, Inc. (MGB), to stop their employer's application of its mandatory COVID-19 vaccination policy to them, holding that the district court did not err.In November 2021, Appellants bought this action. The district court denied a preliminary injunction. Appellants then noticed an appeal and also sought emergency injunctive relief from the First Circuit. The First Circuit held that they had not met the requirements for an injunction pending appeal. Now that the merits of Appellants' appeal were before the Court, the First Circuit affirmed the denial of a preliminary injunction, holding that the district court correctly denied relief. View "Together Employees v. Mass General Brigham Inc." on Justia Law

The First Circuit reversed the judgment of the district court entering summary judgment against a group of jockeys who demanded higher wages and refused to rice and vacated the orders permanently enjoining the work stoppage and imposing $1,190,685 in damages, holding that the district court erred in granting Plaintiffs an injunction and summary judgment.Plaintiffs, an association of horse owners and the owner of a racetrack, brought this action against the jockeys and their spouses who refused to race, alleging that Defendants engaged in a group boycott in violation of federal antitrust law. The district court granted an injunction, concluding (1) the jockeys were independent contractors and had acted in concert to restrain trade, and (2) the jockeys could not benefit from the labor-dispute exemption because of their independent contractor status. The First Circuit reversed, holding (1) the labor-dispute exemption applied in this case; and (2) therefore, the district court erred in granting Plaintiffs and injunction and summary judgment. View "Confederacion Hipica de Puerto Rico v. Confederacion de Jinetes Puertorriqueños, Inc." on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendant, his former employer, and dismissing Plaintiff's complaint alleging that Defendant terminated his employment because of his age and because he received a liver transplant, holding that the district court did not err.Plaintiff filed a complaint alleging disability discrimination under the Americans With Disabilities Act (ADA) and age discrimination under the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment for Defendant and dismissed the complaint. The First Circuit affirmed, holding that the evidence on the record did not support either Plaintiff's ADA claim or his ADEA claim. View "Lahens v. AT&T Mobility Puerto Rico, Inc." on Justia Law

The First Circuit affirmed in part and reversed in part the district court's grant of summary judgment in favor of Defendant on Plaintiff's federal and Massachusetts state law employment discrimination claims, holding that that court erred in granting summary judgment as to several of Plaintiff's claims.Plaintiff, a former employee of Defendant, an online home furnishings company with a principal place of business in Massachusetts, sued Defendant bringing claims under both Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and Mass. Gen. Laws ch. 151B, 4.1, 4.4, and 4.4A. The district court granted summary judgment for Defendant on all claims. The First Circuit reversed in part, holding that the district court (1) correctly granted summary judgment to Defendant on Plaintiff's state and federal claims for failing to remedy sexual harassment; and (2) erred in granting summary judgment to Defendant on Plaintiff's remaining claims. View "Forsythe v. Wayfair, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment ruling in favor of Defendant, a marketing company, holding that district court correctly concluded that Plaintiffs, who worked as "brand representatives" for Defendant, qualified as outside salespeople under governing law.Plaintiffs sued Defendant on behalf of themselves and other brand representatives, seeking to recover unpaid overtime wages under the Fair Labor Standards Act (FLSA) and analogous state wage laws, alleging that they failed to receiver overtime wages for working over forty hours per week. The district court granted summary judgment in favor of Defendant, concluding that Plaintiffs fell within the FLSA's outside sales exemption and thus were not entitled to overtime compensation. The First Circuit affirmed, holding that Plaintiffs fell within the outside sales exemption, 29 U.S.C. 213(a)(1). View "Modeski v. Summit Retail Solutions, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court rejecting the jury's advisory verdict in this case, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff, a former intelligence specialist, sued his former employer, the United States Attorney's Office for the District of Puerto Rico pursuant to Title VII of the Civil Rights Act, alleging discriminatory retaliation and constructive discharge resulting from a hostile work environment. After a jury returned a verdict on liability for retaliation and awarding the statutory maximum in damages, the district court charged the jury to return an advisory verdict on the issue of damages for constructive discharge. The jury returned a verdict in favor of Plaintiff as to that issue, and thereafter, Plaintiff sought a judgment of front and back pay. The district court rejected the jury's advisory verdict, concluding that the verdict was not supported by the evidence, that Plaintiff was not constructively discharged, and that Plaintiff was not entitled to front or back pay. The First Circuit affirmed, holding (1) Plaintiff waived his objection to the district court's decision to submit the constructive discharge issue to an advisory jury; and (2) the district court's factual findings were not clearly erroneous. View "Reyes-Caparros v. Garland" on Justia Law

The First Circuit affirmed the decision of the district court granting summary judgment in favor of the Town of Brookline, Massachusetts on Plaintiff's claim brought pursuant to 42 U.S.C. 1983 alleging discrimination on the basis of race in violation of the Fourteenth Amendment's Equal Protection Clause, holding that the district court did not err in granting summary judgment.Plaintiff brought this action alleging that Brookline violated his equal protection rights in terminating his employment. The district court granted summary judgment in favor of the Town. The First Circuit affirmed, holding that Plaintiff's evidence failed to establish that the Town's proffered reasons for failing to accommodate and then dismissing Plaintiff were a pretext for race discrimination. View "Fincher v. Town of Brookline" on Justia Law

The First Circuit reversed the judgment of the district court in this dispute between the International Brotherhood of Electrical Workers, Local 103 (the Union) and Johnson Controls Security Solutions, LLC over Johnson Controls' compliance with the terms of the parties' collective bargaining agreement (CBA), holding that the district court erred by failing to order arbitration as called for by a clause in the CBA.Johnson Controls' Norwood, Massachusetts facility entered into a CBA with the Union, a labor organization that represented employees of the company, that contained an arbitration clause. The Union filed a grievance concerning Johnson Controls' reduction in its matching contribution to the company's 401(k) plan, which Johnson Controls denied. When the Union filed a demand for arbitration Johnson Controls brought this lawsuit seeking a declaratory judgment that the dispute was not arbitrable under the CBA. The district court concluded that the dispute was not arbitrable. The First Circuit reversed, holding that nothing in the record showed that the parties intended to exclude this type of dispute from the scope of the arbitration clause. View "Johnson Controls Security Solutions, LLC v. Int'l Brotherhood of Electrical Workers, Local 103" on Justia Law

The First Circuit affirmed the decision of the district court denying Day & Zimmerman's (D&Z) motion to dismiss this lawsuit for lack of personal jurisdiction, holding that there was no error.Plaintiff filed suit in the United States District Court for the District of Massachusetts against D&Z, a company incorporated in Delaware that maintained its principal place of business in Pennsylvania, seeking overtime wages pursuant to section 216(b) of the Fair Labor Standards Act, 29 U.S.C. 201-219. Plaintiff alleged that D&Z failed to pay him and other similarly situated employees and former employees their FLSA-required overtime wages. D&Z moved to dismiss for lack of personal jurisdiction, citing Bristol-Myers Squibb v. Superior Court of California (BMS), 137 S. Ct. 1773 (2017) and claiming that the claims subject to the motion to dismiss could not be brought in a Massachusetts federal court. The district court denied the motion, thus declining to extend BMS's personal jurisdiction requirements to FLSA cases brought in federal court. The First Circuit affirmed, holding that the district court did not err in denying D&X's motion to dismiss the nonresident opt-in claims for lack of personal jurisdiction. View "Waters v. Day & Zimmermann NPS, Inc." on Justia Law

The First Circuit affirmed all but two of the district court's rulings in this dispute over the amount of attorneys' fees due to Plaintiff, the prevailing party in the underlying employment discrimination dispute, and vacated the attorneys' fees award, holding that the district court erred in part.Plaintiff, the former head of the appellate practice of the United States Attorney's Office for the District of Puerto Rico, alleging discrimination and retaliation under Title VII. The parties negotiated a settlement, under which Plaintiff received a lump-sum payment of $450,000 plus reasonable attorneys' fees. The district court awarded Plaintiff a total of $170,332 in attorneys' fees. The First Circuit affirmed all but two of the district court's rulings, which the court reversed, and vacated the fee award, holding (1) the district court erred in concluding that time expended in settlement negotiations and time expended in performing work that implicated other cases, distinct but related, must be categorically excluded from the fee award; and (2) Plaintiff's five remaining challenges were without merit. View "Perez-Sosa v. Garland" on Justia Law