Justia Labor & Employment Law Opinion Summaries

Union-affiliated benefit funds (collectively, the Fund) sued Employer to recover unpaid employee-related remittances allegedly due under a collective bargaining agreement (CBA). The Fund also sought attorneys’ fees and costs pursuant to both the CBA and ERISA. The district judge awarded the Fund $26,897 in damages, and, in a separate judgment, awarded $18,000 in attorneys’ fees and $16,688 in expenses. Both parties appealed. The First Circuit Court of Appeals reversed the district court’s determination of damages, but the Supreme Court reversed, concluding that the First Circuit lacked jurisdiction to review the damage judgment. On remand, the First Circuit reinstated the cross-appeals challenging the separate judgment for fees and costs and affirmed the district court’s order awarding attorneys’ fees and expenses, holding that the award was not an abuse of the judge’s discretion. View "Int'l Union v. Ray Haluch Gravel Co." on Justia Law

Plaintiff, who worked for Metropolitan Life Insurance Co. (“MetLife”), made a claim for long-term disability benefits (LTD). In 2005, the claim was approved. That same year, MetLife denied Plaintiff’s assertion that he was entitled to a larger payment calculation. In 2012, Plaintiff filed suit against MetLife under the Employee Retirement Income Security Act of 1974 (ERISA), claiming that MetLife had been underpaying his monthly benefits since 2005. The district court granted MetLife’s motion for summary judgment, concluding that Plaintiff’s suit was barred by the six-year statute of limitations. The First Circuit Court of Appeals affirmed, thus rejecting Plaintiff’s theory that the LTD plan must be analogized to an installment plan so as to alter the accrual date of his claim, holding that Plaintiff’s claim against MetLife was barred by the statute of limitations. View "Riley v. Metro. Life Ins." on Justia Law

After Plaintiff applied unsuccessfully to be a firefighter in the Puerto Rico Firefighters Corps of the Commonwealth of Puerto Rico (“the Corps”) Plaintiff sued the Commonwealth, claiming that the Corps refused to hire her because of her gender. The parties eventually signed a settlement agreement pursuant to which the Corps agreed to employ Plaintiff as a transitory firefighter until the next training academy was held and to hire Plaintiff as a firefighter if she graduated from the academy. Thereafter, Plaintiff again sued the Corps, alleging that, during her transitory employment, the Corps subjected her to abuse in retaliation for her earlier suit. The district court dismissed Plaintiff’s complaint for failure to state a claim. Plaintiff appealed the dismissal of her claim for unlawful retaliation. The First Circuit Court of Appeals vacated the district court’s order, holding that Plaintiff’s complaint stated a plausible claim of unlawful retaliation in violation of Title VII of the Civil Rights Act. Remanded. View "Rodriguez-Vives v. P.R. Firefighters Corps" on Justia Law

Plaintiff filed an action against her former employer (Employer) for violations of Title VII, 42 U.S.C. 2000e et seq., and Mass. Gen. Laws ch. 151B, alleging that she was subject to sexual harassment while working for Employer and that she was terminated in retaliation for reporting the harassment. The district court granted summary judgment in favor of Employer. The First Circuit Court of Appeals affirmed, holding (1) the district court did not err in concluding that no reasonable juror could conclude that Plaintiff was subjected to sexual harassment while an employee for Employer; and (2) even if Plaintiff had made a prima facie case of retaliation, which she did not, Plaintiff did not meet her burden of showing that Employer’s legitimate, non-retaliatory reason for the termination was mere pretext. View "Ponte v. Steelcase Inc." on Justia Law

Plaintiff, the former captain of a village fire department, filed this action against the department, its fire chief, and the board of fire commissioners (collectively, Defendants) after the board chose to terminate Plaintiff’s employment. Plaintiff alleged political discrimination in violation of the First Amendment and 42 U.S.C. 1983, retaliation in violation of the Massachusetts Whistleblower Act, and tortious interference with contractual relations. The district court granted summary judgment for Defendants on all counts. The First Circuit Court of Appeals affirmed, holding that Defendants presented legitimate, business-related grounds for their employment decisions, and Plaintiff failed to demonstrate that the proffered explanations were pretextual. View "Pierce v. Cotuit Fire Dist." on Justia Law

Appellant filed an action against her former employer, The Children Place (TCP) and the TCP district manager (collectively, Appellees), alleging that she was fired, harassed, and not rehired on the basis of race. The district court granted summary judgment in favor of Appellees. The First Circuit Court of Appeals affirmed, holding (1) the district court did not abuse its discretion when it denied three of Appellant’s discovery-related motions; and (2) the district court did not err by granting Appellees’ motion for summary judgment as to (i) Appellant’s claims of race discrimination where Appellant was unable to rebut Appellees’ legitimate, nondiscriminatory basis for her termination with evidence of pretext and discriminatory motive, and (ii) Appellant’s retaliation claim in light of her failure to establish a prima facie case. View "Pina v. Children's Place" on Justia Law

Petitioner, a citizen of Nigeria, entered the United States using a false name and fraudulently obtained visa. After the government commenced removal proceedings, Petitioner filed for withholding of removal and protection under the Convention Against Torture, citing fear of religious persecution. The immigration judge denied relief and ordered removal. The board of immigration appeals (BIA) affirmed. The BIA denied Petitioner's motion to reopen, which added a claim for asylum, and his subsequently filed motion to reconsider. The First Circuit Court of Appeals dismissed Petitioner's petition for review his motion to reopen and denied Petitioner's petition to review his motion to reconsider, holding that the BIA did not abuse its discretion or err in its judgment. View "Saka v. Holder" on Justia Law

Joseph Travers worked as a skycap for Flight Services & Systems, Inc., a company that provides services to airlines, including JetBlue. Travers filed a putative class lawsuit against JetBlue and Flight Services, alleging that Defendants violated the Fair Labor Standards Act (FLSA) by failing to pay the federal minimum wage. While a decision on Travers's motion to certify conditionally an opt-in class under the FLSA was pending, Flight Services fired Travers for allegedly violating company policy. Travers filed this action against Flight Services, asserting that he was fired in retaliation for his FLSA lawsuit. The district court granted summary judgment to Flight Services. The First Circuit Court of Appeals vacated the district court's grant of summary judgment, holding a reasonable jury could return a verdict for Travers without relying on inferences or speculation. Remanded. View "Travers v. Flight Servs. & Sys., Inc." on Justia Law

Appellant filed two amended qui tam actions against her employer, a pharmaceutical company and its subsidiary (collectively, Appellees), under the federal False Claims Act (FCA), alleging that Appellees failed adequately to disclose the risks associated with some of their drugs and that this failure resulted in the submission of false claims by third-party patients and physicians for government payment. The district court dismissed both of Appellant's actions under Fed. R. Civ. P. 9(b) for failure to plead fraud with particularity and under Fed. R. Civ. P. 12(b)(6) for failure to state a claim. Appellant subsequently sought to amend the second amended complaint, asserting more theories of FCA liability, but the district court refused to allow further amendment. The First Circuit Court of Appeals affirmed the district court's rulings regarding the dismissal of Appellant's claim under Rule 9(b) and the denial of Appellant's proposed amendments, holding (1) Appellant's claims on all theories which were presented failed under Rule 9(b); and (2) the district court did not err in denying Appellant's motion to amend. View "United States ex rel. Ge v. Takeda Pharm. Co. Ltd." on Justia Law

Under the Workforce Investment Act of 1998 (WIA), Maine obtained federal funding to strengthen local workforces. Plaintiff was the executive director of the Local Area I Workforce Investment Board (LWIB). Plaintiff reported to and received her salary from Aroostook County, and the County used WIA funds for this purpose. Federal monitors from the Department of Labor undertook a compliance review of the LWIB and found that Plaintiff's job description was not in compliance with federal program requirements because, absent an express agreement between the LWIB and the County, the County could not be Plaintiff's employer. Plaintiff transmitted results of the federal monitoring visit but did so as part of her job responsibilities. The Northern Maine Development Commission, Inc. (NMDC) was later designated as the fiscal agent for the LWIB, and Plaintiff's employment was terminated. Plaintiff applied for NMDC's director of workforce development petition was not hired. Plaintiff then filed this Maine Whistleblowers' Protection Act (MWPA) action against NMDC for violating the whistleblower law. The district court granted summary judgment for NMDC. The First Circuit Court of Appeals affirmed, holding that, on the undisputed facts, Plaintiff was not a whistleblower under the MWPA and so had no claim against NMDC. View "Winslow v. Aroostook County" on Justia Law