Justia Labor & Employment Law Opinion Summaries

The plaintiff, Carmen Quintana-Dieppa, a 62-year-old Puerto Rican woman, worked for the Department of the Army since 1988 and served as a Child Youth and School Services Coordinator at Fort Buchanan, Puerto Rico, since 2009. In 2014, she filed a complaint with the EEOC alleging national origin discrimination. While her complaint was pending, the Army conducted two investigations into her management style, finding that she fostered a toxic work environment. Consequently, she was reassigned to a nonsupervisory role in 2017. Quintana claimed this reassignment was discriminatory and retaliatory.The United States District Court for the District of Puerto Rico granted summary judgment in favor of the Army, finding no genuine issues of material fact. The court determined that Quintana failed to properly contest the Army's Statement of Facts according to Local Rule 56, and thus, the Army's facts were deemed admitted. The court concluded that Quintana did not establish a prima facie case of discrimination or retaliation and, even if she had, she failed to show that the Army's reasons for her reassignment were pretextual.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court affirmed the district court's judgment, agreeing that Quintana did not meet her burden of showing that the Army's stated reasons for her reassignment were a pretext for discrimination or retaliation. The court noted that the Army's investigations provided legitimate, nondiscriminatory reasons for the reassignment, and Quintana's arguments, including claims of hearsay and fabrication, were unsupported by the record. The court also found that the temporal proximity between her EEOC complaint and reassignment was insufficient to establish a causal link for retaliation. View "Quintana-Dieppa v. Department of the Army" on Justia Law

Rosemary Morgan-Lee, a former employee of Therapy Resources Management, LLC (TRM), alleged that she was discharged in violation of the whistleblower protections under the False Claims Act (FCA) and the Rhode Island Whistleblowers' Protection Act (RIWPA). Morgan-Lee claimed that her termination was due to her efforts to report fraudulent activities by TRM. The district court found that while she had engaged in some protected activity and TRM had general corporate knowledge of this, she failed to prove that her protected conduct was the but-for cause of her termination.The case was initially tried before a jury in 2017, resulting in a mistrial. The district court then conducted a four-day bench trial, during which it heard testimony from ten witnesses. The court ultimately ruled against Morgan-Lee, finding that her termination was due to unapproved absences and her refusal to provide specifics about the alleged fraudulent activities, rather than any retaliatory animus from TRM.The United States Court of Appeals for the First Circuit reviewed the case. Morgan-Lee argued that the district court committed legal errors and that its factual findings were clearly erroneous. However, the appellate court found that many of her arguments were waived, unpreserved, or without merit. The court affirmed the district court's decision, holding that the district court properly applied the law and that its findings, including the lack of but-for causation, were well-supported by the record. The appellate court also rejected Morgan-Lee's arguments regarding the application of the McDonnell Douglas burden-shifting framework and the causation standard, affirming the district court's use of the but-for causation standard as consistent with precedent. View "United States ex rel. Morgan-Lee v. Therapy Resources Management, LLC" on Justia Law

A high school student, Adrianna Wadsworth, filed a lawsuit against her principal, Andrew Cavanaugh, a school social worker, Chuck Nguyen, and the school district, MSAD 40/RSU 40, alleging constitutional violations and a Title IX claim. Wadsworth claimed that Cavanaugh sexually harassed her, Nguyen failed to protect her, and the school district was indifferent to the harassment.The United States District Court for the District of Maine dismissed some of Wadsworth's claims and granted summary judgment in favor of the defendants on others. The court dismissed the supervisor-liability claim against Nguyen, finding no control over Cavanaugh. It also granted summary judgment to Cavanaugh on the substantive due process claim, concluding that non-physical harassment did not violate Wadsworth's right to bodily integrity. The court found that Wadsworth's equal protection claim against Cavanaugh was valid but granted him qualified immunity. Nguyen was granted summary judgment on the state-created-danger claim, as his conduct did not shock the conscience. The court also granted summary judgment to MSAD on the § 1983 municipal liability claim, finding no deliberate indifference, and on the Title IX claim, concluding that the assistant principals did not have actual knowledge of the harassment.The United States Court of Appeals for the First Circuit reviewed the case. It affirmed the district court's decision on the substantive due process claim against Cavanaugh but reversed the summary judgment on the equal protection claim, finding that a reasonable jury could conclude that Cavanaugh's conduct was severe and pervasive enough to constitute sexual harassment. The court also affirmed the dismissal of the supervisor-liability claim against Nguyen and the summary judgment on the state-created-danger claim. However, it reversed the summary judgment on the Title IX claim against MSAD, concluding that a reasonable jury could find that the assistant principals had actual knowledge of the harassment. The case was remanded for further proceedings consistent with the opinion. View "Wadsworth v. MSAD 40/RSU 40" on Justia Law

A registered nurse, Alexandra Melino, sued her former employer, Boston Medical Center (BMC), alleging violations of Title VII of the Civil Rights Act and Massachusetts General Laws by denying her request for a religious exemption from BMC's COVID-19 vaccination mandate. Melino's primary duties involved direct patient care in critical units. During the pandemic, BMC converted several units to COVID-19 units and faced significant staffing challenges due to the virus. BMC implemented a vaccination policy based on CDC recommendations to mitigate the risk of COVID-19 transmission among staff and patients.The United States District Court for the District of Massachusetts granted summary judgment to BMC, holding that Melino's requested exemption would impose undue hardship on the hospital. The court found that Melino could not work remotely, could not work in-person unvaccinated without risking patient safety, and that any feasible accommodation would impose substantial costs on BMC. Melino's motion to strike portions of an affidavit submitted by BMC was also denied due to her failure to comply with local procedural rules.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court affirmed the district court's decision, agreeing that BMC had demonstrated undue hardship by showing that allowing Melino to work unvaccinated would increase the risk of COVID-19 transmission. The court noted that Melino did not provide any medical evidence to contradict BMC's reliance on CDC recommendations. Additionally, Melino's argument that BMC should have considered alternative accommodations was waived as it was not raised in the lower court. The court upheld the district court's rulings, affirming the grant of summary judgment in favor of BMC. View "Melino v. Boston Medical Center" on Justia Law

George Rodrique, II, a photographer for WCVB-TV, sued his employer, Hearst Stations, Inc. ("Hearst"), after it denied his request for a religious exemption from the company's COVID-19 vaccination requirement and subsequently terminated him for refusing to receive the vaccine. Rodrique claimed that Hearst's actions violated Title VII of the Civil Rights Act of 1964, which prohibits religious discrimination in employment.The United States District Court for the District of Massachusetts granted Hearst's motion for summary judgment, concluding that Rodrique's objections to the vaccine were not religious in nature. The court did not address whether accommodating Rodrique's request would have imposed an undue hardship on Hearst.Rodrique appealed to the United States Court of Appeals for the First Circuit, arguing that his objections were indeed religious and that granting the exemption would not have caused undue hardship. He contended that Hearst provided insufficient evidence that the COVID-19 vaccine reduces virus transmission.The First Circuit assumed, without deciding, that Rodrique's objections were religious. However, it affirmed the district court's summary judgment on different grounds, holding that Hearst reasonably relied on objective medical evidence, including public health guidance, to conclude that the vaccine reduces the likelihood of transmitting COVID-19. The court found that Hearst's reliance on such evidence was reasonable and that accommodating Rodrique's request would have imposed an undue hardship on the company. Thus, the First Circuit affirmed the district court's order granting summary judgment to Hearst. View "Rodrique v. Hearst Communications, Inc." on Justia Law

Jesse Sutherland was employed as an oil service technician at Peterson's Oil Service, Inc. ("Peterson's"). Two months into his job, he injured his right knee, leading to a torn meniscus and damaged patella. Sutherland requested reduced work hours due to his injury and eventually took a 12-week leave for knee surgery. Upon attempting to return to work, he was informed of his termination, effective the date he was supposed to return, citing a lack of work during the COVID-19 pandemic. Sutherland sued Peterson's for disability discrimination and related claims.The United States District Court for the District of Massachusetts granted summary judgment in favor of Peterson's, leading Sutherland to appeal. The district court concluded that Sutherland did not provide sufficient evidence to establish a prima facie case of disability discrimination, particularly questioning whether his knee injury qualified as a disability under the ADA.The United States Court of Appeals for the First Circuit reviewed the case and found that the district court erred in its analysis. The appellate court concluded that Sutherland provided sufficient evidence to show that his knee injury was a disability under the ADA, as it substantially limited his major life activities. The court also found that Sutherland's requests for reduced work hours were reasonable and that Peterson's failed to engage in the interactive process required by law. The appellate court vacated the district court's summary judgment on Sutherland's disability-related claims and remanded the case for further proceedings. However, the court affirmed the district court's decision regarding Sutherland's wrongful termination claim based on alleged violation of Massachusetts public policy, as Sutherland did not provide sufficient evidence of a well-defined public policy supporting his views on biofuel. View "Sutherland v. Peterson's Oil Service, Inc." on Justia Law

Regina M. Thornton was employed by Ipsen Biopharmaceuticals, Inc. as Associate Director - Patient Safety. In September 2021, Ipsen required employees to receive COVID-19 vaccinations. Thornton requested a religious exemption, which Ipsen denied. After she did not comply with the vaccination requirement, Ipsen terminated her employment. Thornton sued Ipsen in the Superior Court of Massachusetts, alleging violations of Title VII, Massachusetts law (Chapter 151B), the Fourteenth Amendment, and the Massachusetts Declaration of Rights (MDR). Ipsen removed the case to the United States District Court for the District of Massachusetts and moved to dismiss all counts. The Magistrate Judge granted Ipsen's motion, dismissing Thornton's complaint. Thornton appealed.The United States District Court for the District of Massachusetts dismissed Thornton's complaint, finding that she failed to state a plausible claim of religious discrimination under Title VII or Chapter 151B. The court concluded that Thornton did not adequately state her religious beliefs or how they related to vaccines. The court also found that Thornton's federal constitutional claims failed because Ipsen was not a state actor, and her MDR claims failed because the MDR does not provide a private right of action.The United States Court of Appeals for the First Circuit reviewed the case. The court reversed the Magistrate Judge's dismissal of Thornton's religious discrimination claims under Title VII and Chapter 151B, finding that she had plausibly alleged that her religious beliefs conflicted with the vaccination requirement. However, the court affirmed the dismissal of her federal constitutional claims, as the Fourteenth Amendment does not apply to private actors like Ipsen. The court also affirmed the dismissal of her MDR claims, noting that Thornton had waived any argument that her claim should be reimagined under the Massachusetts Civil Rights Act. View "Thornton v. Ipsen Biopharmaceuticals, Inc." on Justia Law

The First Circuit declined enforcement of the National Labor Relations Board’s (NLRB) order requiring 1199 SEIU United Healthcare Workers East (the Union) and Good Samaritan Medical Center to reinstate Camille Legley with back pay and rescind a workplace civility policy, holding that there was not substantial evidence on the record as a whole that Legley was discharged because of his protected conduct.Legley, a probationary employee hired by Good Samaritan, questioned a union delegate’s alleged remark during an orientation training that he had to join the Union in order to work at Good Samaritan. Good Samaritan terminated Legley’s employment the following day, claiming that Legley’s conduct had violated its civility policy. The NLRB found that the Union caused Good Samaritan to discharge Legally because of his protected conduct. In denying enforcement of the NLRB’s order the First Circuit held that the NLRB’s decision ignored a portion of the record and could not survive review under the substantial evidence standard. View "Good Samaritan Medical Center v. National Labor Relations Board" on Justia Law

The First Circuit affirmed the district court’s rejection of Appellant’s claims that she, among other things, suffered discrimination in violation of the Americans with Disabilities Act (ADA) and its Massachusetts state-law corollary when Defendants failed to accommodate her request for transfer to another position in the Plymouth Police Department after she suffered an on-the-job injury. The district court concluded that Appellant failed to raise a genuine issues of material fact regarding her discrimination claims. The First Circuit affirmed, holding (1) the district court correctly entered summary judgment on Appellant’s handicap discrimination claims and gender discrimination claim; and (2) even if the court were able to glean an ADA retaliation claim from Appellant’s complaint, Appellant waived it during summary judgment proceedings. View "Audette v. Town of Plymouth, Mass." on Justia Law

A plaintiff may not bring claims for damages under 42 U.S.C. 1981 against state actors, including defendants sued in their official capacities as government officials.The First Circuit affirmed the district court’s dismissal of Plaintiff's section 1981 claims against employees of the City of Boston. Plaintiff, who represented the estate of her late father, challenged her father’s termination from his employment with the Department of Public Works. The district court dismissed the section 1981 claims, concluding that section 1981 provides no implied private right of action for damages against state actors. The First Circuit affirmed, holding that Jett v. Dallas Independent School District compelled the result reached by the district court. View "Buntin v. City of Boston" on Justia Law