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

The First Circuit affirmed the judgment of the district court summarily affirming an arbitration award dismissing Union Interacional UAW, Local 2415's wage grievance claim against Bacardi Corporation, holding that the Union did not identify an error in the arbitration award so egregious as to permit this Court to vacate it.The arbitrator found that the Union's claim was not procedurally arbitrable because the Union failed to comply with the contractual wage grievance procedure. On appeal, the Union argued that either the arbitrator should have deemed the procedural arbitrability defect waived or that the procedural defect did not justify dismissing the entire claim. The First Circuit affirmed, holding that, while the Union's waiver arguments had merit, the arbitrator acted within the scope of his authority in dismissing the entire claim for lack of procedural arbitrability. View "Union Internacional, UAW Local 2415 v. Bacardi Corp." on Justia Law

The First Circuit certified a question to the Massachusetts Supreme Judicial Court pursuant to Massachusetts Supreme Judicial Court Rule 1:03, holding that the outcome of this appeal depended upon a question of Massachusetts law, upon which the Massachusetts courts have not spoken.Plaintiffs, owners of 7-Eleven franchise operated in Massachusetts, alleged that 7-Eleven misclassified them was independent contractors rather than employees, in violation of Massachusetts law. At issue was a conflict between the Massachusetts Independent Contractor Law (ICL), Mass. Gen. Laws ch. 149, 148B, and the Federal Trade Commission's Franchise Rule making it allegedly impossible for 7-Eleven to satisfy federal law. The district court held that, due to this conflict, the ICL did not apply and therefore, its franchisees were properly classified as independent contractors. The First Circuit certified a question to the Massachusetts Supreme Judicial Court regarding the issue and retained jurisdiction pending resolution of the certified question. View "Patel v. 7-Eleven, Inc." on Justia Law

The First Circuit affirmed the order of the district court dismissing Plaintiff's suit brought against Defendant, his employer, asserting claims of age-based discrimination under the Age Discrimination in Employment Act (ADEA) and Puerto Rico's statutory analog, holding that this Court will not adopt any version of the single filing rule that would excuse the procedural failings associated with Plaintiff's suit.In moving to dismiss the complaint, Defendant asserted that Plaintiff neglected to first file a complaint with the Equal Employment Opportunity Commission and therefore failed to exhaust his administrative remedies before filing suit. Plaintiff argued in response that the district court should adopt and apply the "single filing rule," otherwise known as the "piggyback rule," which would allow him to vicariously satisfy his exhaustion obligation by relying upon a timely-filed administrative complaint against his employer made by a similarly-situated plaintiff. The district court declined to adopt the single filing rule, dismissed Plaintiff's ADEA claims, and declined to exercise supplemental jurisdiction over his Puerto Rico law claims. The First Circuit affirmed, holding that the district court correctly dismissed the complaint. View "Perez-Abreu v. Metropol Hato Rey LLC" on Justia Law

The First Circuit affirmed the judgment of the district court granting Defendant's motion for judgment on the pleadings holding that this case came within the jurisdictional reach of the Labor Management Relations Act, 29 U.S.C. 185(a), and that the district court did not err either in denying Plaintiff's motion to remand or in granting judgment for the pleadings for Defendant.Plaintiff, an employee of Defendant, brought this action in a Massachusetts state court asserting violations of the Commonwealth's labor laws. Plaintiff sought recovery of compensation for unpaid wages and expenses, unpaid overtime, and damages for Defendant's alleged failure to account for her travel time and to maintain required payroll records. Defendant removed the suit to federal district court. Plaintiff moved to remand the case, arguing that her claims arose exclusively under state law. The district court denied the remand motion and subsequently granted Defendant's motion for judgment on the pleadings. The First Circuit affirmed, holding that there was no error in the proceedings below. View "Rose v. RTN Federal Credit Union" on Justia Law

The First Circuit vacated the judgment of the district court granting summary judgment in favor of Defendant in this case alleging a violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e et seq., holding that genuine issues of material fact precluded summary judgment.Plaintiff, who was Black, sued Bridgewater State university's Board of Trustees and Office of Equal Opportunity and a University administrator (collectively, Defendants) alleging that she was not hired for a University position because of her race. The district court granted summary judgment in favor of Defendants. The First Circuit reversed, holding that Plaintiff's aggregate package of proof sufficed to survive Defendants' motion for summary judgment. View "Taite v. Bridgewater State University" on Justia Law

The First Circuit reversed the order of the district court excluding two documents from the summary judgment record and granting summary judgment for Defendant on all of Plaintiff's claims, holding that the district court erred in excluding the two documents from the summary judgment record.Defendant terminated Defendant's employment after he had been employed for thirty-three years. Plaintiff brought this lawsuit alleging wrongful termination of his employment under state law and age discrimination under federal and state law. Defendant moved to strike two of Plaintiff's documents on the grounds that they had been produced after the discovery cut-off date and that they were not properly authenticated. The district court granted the motion to strike the documents and then granted Defendant's motion for summary judgment. The First Circuit reversed the order excluding the documents and vacated the entry of summary judgment, holding that the court erred in striking the documents and that material issues of fact precluded summary judgment. View "Zampierollo-Rheinfeldt v. Ingersoll-Rand de Puerto Rico, Inc." on Justia Law

The First Circuit granted the application of the National Labor Relations Board for enforcement of one of its orders and struck those portions of the order requiring Maine Coast Regional Health Facilities, d/b/a Maine Coast Memorial Hospital (MCMH) to post repudiation notices at facilities operated by other corporate entities, holding that the Board improperly extended its remedy to MCMH's parent corporation.The Board concluded the MCMH violated violated federal labor laws but firing an employee after she wrote a letter to the editor of a local newspaper and committed a separate violation by maintaining a media policy prohibiting contact between employees and the media. The Board extended its remedy to Eastern Maine Healthcare Systems (EMHS), MCMH's parent corporation, which was not a party to the proceeding. The Board then sought enforcement of its order. The First Circuit granted the application but struck the pertinent portions of the order, holding that there was no basis for concluding that EMHS was joined as a party or that MCMH consented to extending the remedy beyond its corporate borders. View "National Labor Relations Board v. Maine Coast Regional Health Facilities" on Justia Law

The First Circuit resolved a portion of Appellant's appeal in this opinion addressing the district court's grant of summary judgment in favor of the Town of Brookline, Massachusetts, the Brookline Board of Selectmen, the Town's counsel and Human Resources director, and select members of the Board, holding that the summary judgment is affirmed in part, vacated in part and remanded for further proceedings.Plaintiff, black man, brought this suit alleging that during his employment as a firefighter, he had been discriminated against and retaliated against for reporting discriminatory conduct. The district court entered summary judgment in favor of Defendants. The First Circuit affirmed in part and vacated in part the summary judgment granted in favor of Defendants, holding that the district court erred in granting summary judgment as to Plaintiff's retaliation claims under 42 U.S.C. 1983 against the Town, the Board, and certain members of the Board, in their personal and official capacities. The Court then remanded the case for further proceedings. View "Alston v. Town of Brookline, Mass." on Justia Law

The First Circuit affirmed the judgment of the district court dismissing Plaintiff's lawsuit brought against Defendant, the local district attorney, after Plaintiff was terminated from his employment with a police department by the Town Manager in a town in Penobscot County, Maine, holding that dismissal was proper.Plaintiff's complaint against Defendant alleged that Defendant violated his due process rights by failing to provide him with meaningful notice and opportunity to dispute allegations about his misconduct that Defendant made and allegedly sent in a letter to the Department's police chief that led the Town to its decision. The district court dismissed on state law grounds. The First Circuit affirmed on different grounds, holding that Plaintiff failed to state a claim for a due process violation under either the United States or Maine Constitution. View "Roe v. Lynch" on Justia Law

The First Circuit resolved a portion of Appellant's appeal in this opinion addressing the district court's grant of summary judgment in favor of the Town of Brookline, Massachusetts, the Brookeline Board of Selectmen, the Town's counsel and Human Resources director, and select members of the board, holding that the summary judgment is affirmed in part, vacated in part and remanded for further proceedings.Plaintiff, black man, brought this suit alleging that during his employment as a firefighter, he had been discriminated against and retaliated against for reporting discriminatory conduct. The district court entered summary judgment in favor of Defendants. The First Circuit affirmed in part and vacated in part the summary judgment granted in favor of Defendants, holding that the district court erred in granting summary judgment as to Plaintiff's retaliation claims under 42 U.S.C. 1983 against the Town, the Board, and certain members of the Board, in their personal and official capacities. The Court then remanded the case for further proceedings. View "Alston v. Town of Brookline, Mass." on Justia Law