Justia Labor & Employment Law Opinion Summaries

The plaintiff brought claims against her former employer alleging violations of federal and state wage and hour laws. After removal to the United States District Court for the District of Rhode Island, some claims were resolved at summary judgment, leaving the federal wage claims for trial. Before trial, the parties participated in a court-ordered mediation before a magistrate judge, during which they reached an oral settlement agreement whose terms were recited on the record. The agreement included payment to the plaintiff, confidentiality, non-defamation, and no-rehire clauses, as well as dismissal of the action with prejudice. Both parties, including the plaintiff and her counsel, confirmed their assent to the agreement.Following the mediation, the defendant prepared written settlement documents and a stipulation of dismissal. However, the plaintiff refused to sign, asserting she felt pressured and that certain terms were ambiguous or not sufficiently definite. The district court reviewed these objections after the defendant moved to enforce the settlement. The court found the agreement enforceable, denied the plaintiff’s request for an evidentiary hearing on alleged undue influence due to lack of factual support, and ordered her to execute the documents. After the plaintiff failed to comply, the court ultimately dismissed the case with prejudice under Federal Rule of Civil Procedure 41(b).On appeal, the United States Court of Appeals for the First Circuit held that the district court did not err in enforcing the oral settlement agreement or in denying the plaintiff’s motion for reconsideration and request for an evidentiary hearing. The appellate court found no genuine dispute of material fact as to the existence or terms of the settlement and affirmed the district court’s judgment, awarding costs and attorney fees to the defendant. View "Maccarone v. Siemens Industry, Inc." on Justia Law

Two former employees of a global toy and game company sought religious exemptions from the company’s COVID-19 vaccination policy. Both had worked remotely during the pandemic and requested to continue working remotely due to their sincerely held Christian beliefs, which included objections to vaccines developed or tested using tissue from aborted fetuses and a belief that receiving the vaccine would violate their religious principles. After submitting their accommodation requests, both employees experienced workplace actions they alleged were retaliatory and discriminatory. These included formal investigations and written warnings for alleged prior mask policy violations, exclusion from promotion opportunities, reassignment of roles, dissemination of personal medical information, and changes to established workplace practices. Both resigned, asserting that these actions compelled their departures.The plaintiffs initiated legal action in Rhode Island state court, raising claims under Title VII of the Civil Rights Act, the Rhode Island Civil Rights Act, and the Rhode Island Fair Employment Practices Act. The case was removed to the United States District Court for the District of Rhode Island, which granted the employer’s motion to dismiss. The district court determined that the plaintiffs’ objections to vaccination were not based on religion, characterizing their beliefs as moral rather than religious, and held that the complaint failed to allege sufficiently adverse employment actions or a causal connection between the plaintiffs’ accommodation requests and any adverse action.The United States Court of Appeals for the First Circuit reviewed the case. It held that the plaintiffs plausibly alleged that their refusal to take the COVID-19 vaccine was based on bona fide religious beliefs, as recognized in recent circuit precedent. The court concluded that the amended complaint sufficiently pleaded plausible claims of retaliation and religious discrimination under federal and state law. Accordingly, the First Circuit vacated the district court’s dismissal and remanded the case for further proceedings. View "DeAngelis v. Hasbro, Inc." on Justia Law

A former Boston police officer alleged that the Boston Police Department (BPD) retaliated against her after she reported a fellow officer for rape in 2009. Following her report, both she and the accused officer were placed on leave, and subsequent criminal and internal investigations found her allegations unsubstantiated. She later made additional complaints of misconduct by BPD officials, which were also found unsubstantiated. In response, BPD’s Internal Affairs Department sustained numerous disciplinary charges against her, and she resigned with these charges pending. After her resignation, she applied for various jobs, authorizing prospective employers to request her employment and disciplinary records from BPD. Additionally, BPD included her name and reason for departure in a list provided to the Washington Post in response to a public records request.The Massachusetts Superior Court dismissed her three successive lawsuits against BPD, primarily for procedural reasons, with the last dismissal in 2017 operating as an adjudication on the merits. In federal court, claims based on alleged retaliatory acts before February 2, 2017, were precluded due to the prior state court judgment. The U.S. District Court for the District of Massachusetts allowed her Title VII retaliation claims to proceed only as to BPD’s actions after that date, specifically regarding the release of her records to prospective employers and the Washington Post.The United States Court of Appeals for the First Circuit affirmed the district court’s grant of summary judgment for BPD. The court held that no reasonable jury could find that retaliation was the but-for cause of BPD’s release of employment information, since Doe had authorized those disclosures and there was no evidence of deviation from standard procedure or retaliatory motive. The court also held that BPD’s response to the public records request was legally required and contained accurate information. View "Doe v. City of Boston" on Justia Law

A group of former employees at a luxury hotel in Lenox, Massachusetts brought a series of lawsuits against the hotel and its operators, alleging violations of the Fair Labor Standards Act (FLSA) and Massachusetts wage laws. The claims primarily involved misclassification as overtime-exempt, failure to pay minimum wage, mismanagement of tip pools, and other wage-related violations. One plaintiff, after successfully certifying a class of similarly situated employees, joined with others to negotiate a global settlement with the hotel’s owners.Prior to this appeal, the United States District Court for the District of Massachusetts, acting through a magistrate judge, oversaw the coordinated settlement negotiations for four related cases—three individual actions and one class action. After the parties agreed to a global settlement via email, defense counsel confirmed the deal and the court was notified. The individual cases were subsequently dismissed with prejudice. When obstacles arose regarding finalization, including Wheatleigh’s concerns over attorney fees and purported conflicts of interest for class counsel, plaintiffs moved to enforce the settlement. The district court granted the motion, enforced the settlement, and later granted preliminary and then final approval of the class-action settlement, including approval of attorney fees, expenses, and a service award.The United States Court of Appeals for the First Circuit reviewed Wheatleigh’s appeal, which challenged the district court’s rulings on standing, enforcement and approval of the settlement, class certification, and attorney fees. The First Circuit held that the district court did not err in finding Article III standing for the named plaintiff, enforcing the global settlement, approving the class-action settlement despite alleged conflicts of counsel, maintaining class certification, and awarding attorney fees. The First Circuit affirmed the judgment of the district court. View "Mongue v. The Wheatleigh Corporation" on Justia Law

A group of eleven current and former employees of the Woods Hole, Martha’s Vineyard and Nantucket Steamship Authority challenged the Authority’s COVID-19 vaccine mandate, which required all employees to be fully vaccinated unless they qualified for a medical or religious exemption. The policy allowed for exemptions if an employee provided sufficient medical documentation or demonstrated a sincerely held religious belief, provided that reasonable accommodations could be made without undue burden to the Authority. Thirteen employees applied for religious exemptions, but only the request of one fully remote employee was granted. One employee received a temporary medical exemption but was ultimately terminated after refusing vaccination once that exemption expired. Four appellants later became vaccinated and remained employed; the remaining seven were fired for noncompliance.After the Authority enacted its policy, the plaintiffs filed suit, alleging violations of their rights under the Massachusetts Declaration of Rights, the First and Fourteenth Amendments, and Massachusetts anti-discrimination law. The state court initially granted a temporary restraining order, but after removal to the United States District Court for the District of Massachusetts, the district court denied their preliminary injunction request. On a prior appeal, the United States Court of Appeals for the First Circuit affirmed the denial as to most claims but remanded for further consideration of the First Amendment claim, instructing the district court to address the relevance of the granted medical exemption and to determine the appropriate level of scrutiny.On remand, the district court again denied a preliminary injunction, finding the policy to be generally applicable and thus subject to rational basis review, which it held the policy satisfied. The United States Court of Appeals for the First Circuit affirmed, holding that the policy’s medical and religious exemptions were not comparable for Free Exercise purposes, the policy was generally applicable, and the Authority’s interests justified the mandate under rational basis review. View "Brox v. Woods Hole, Martha's Vineyard & Nantucket Steamship Authority" on Justia Law

The plaintiff was an employee of the Puerto Rico Aqueduct and Sewer Authority and a former member of the relevant labor union. In 2016, he attempted to resign from the union and objected to the continued deduction of union dues from his wages, arguing that compelled dues for non-bargaining activities violated his First Amendment rights. The employer and union, acting under Puerto Rican law and the terms of a collective bargaining agreement, denied his requests, continued to deduct dues, and the plaintiff filed suit seeking declaratory, injunctive, and monetary relief.The United States District Court for the District of Puerto Rico presided over the initial proceedings. After the Supreme Court’s decision in Janus v. American Federation of State, County, and Municipal Employees overruled Abood v. Detroit Board of Education and invalidated mandatory union payments by nonmembers in the public sector, the employer and union ceased deducting dues from the plaintiff. The union then sought to deposit the amount withheld after his resignation, plus interest and nominal damages, with the court. The District Court ultimately granted the union’s request to deposit funds and dismissed the plaintiff’s claims as moot, reasoning that he had received all requested relief. The plaintiff’s subsequent motion to alter or amend the judgment was denied, with the court stating he was entitled to the deposited funds.The United States Court of Appeals for the First Circuit reviewed the appeal. The First Circuit found that the plaintiff was entitled to the funds deposited by the union, rejecting the argument that there was no judgment awarding him monetary relief. However, the court determined that the issue of whether the plaintiff could seek prevailing party attorneys’ fees—potentially affecting mootness—had not been fully addressed below. The First Circuit remanded the case to the District Court for further proceedings on that issue, while retaining jurisdiction over the appeal. View "Cruz v. UIA" on Justia Law

Giovanni Irizarry Sierra worked as an Attorney Advisor for the Social Security Administration (SSA) in Puerto Rico and was terminated in March 2019 for unsatisfactory performance. He subsequently filed a complaint with the SSA’s Office of Civil Rights and Equal Opportunity (OCREO), alleging that his termination was the result of discrimination and retaliation. The OCREO reorganized his allegations, dismissing one as untimely and bifurcating the remainder into pre-termination and termination discrimination claims. The termination claim was treated as a “mixed case” because it involved both discrimination and an adverse personnel action.After receiving a report of investigation, Irizarry requested a hearing before an Equal Employment Opportunity Commission (EEOC) Administrative Judge (AJ). The AJ dismissed the termination claim for lack of jurisdiction, explaining that mixed cases must proceed through the Merit Systems Protection Board (MSPB), not the EEOC. Irizarry then appealed his termination claim to the MSPB, which sustained his removal and notified him that he had thirty days from the final decision to seek judicial review in federal district court. Irizarry did not file within that period. Later, the OCREO erroneously issued a Final Agency Decision (FAD) on the termination claim, which was subsequently rescinded.Irizarry filed suit in the United States District Court for the District of Puerto Rico, relying on the rescinded FAD. The SSA moved to dismiss, arguing the complaint was untimely and the FAD was issued in error. The district court granted the motion, finding the claims time-barred and rejecting Irizarry’s arguments for equitable tolling and estoppel.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s dismissal. The court held that Irizarry’s claim was untimely because he failed to file within thirty days of the MSPB’s final decision, and equitable relief was not warranted. View "Irizarry Sierra v. Bisignano" on Justia Law

An employee of an airline company in Puerto Rico suffered a work-related injury when an airplane door struck his head. After the incident, he sought medical treatment and eventually reported to Puerto Rico’s State Insurance Fund (the Fund) for workers’ compensation. The employer did not initially provide the necessary incident report for the Fund, nor did it file a Work Accident Report with the Fund until nearly two years later. The employee was placed on leave under the Family and Medical Leave Act (FMLA) and continued to receive treatment, including surgery and physical therapy. While still under medical care and unable to return to work, he was terminated by the employer, who cited his failure to keep them informed of his status.The employee filed suit in the United States District Court for the District of Puerto Rico, alleging several claims under federal and Puerto Rico law, including a retaliation claim under Puerto Rico’s Whistle-Blower Act (Law 115). The district court dismissed some claims at the motion to dismiss stage and granted summary judgment on the remaining claims, including the Law 115 retaliation claim. The district court found that the five-month gap between the employee’s report to the Fund and his termination was too long to establish causation, and also concluded that the employer’s stated reasons for termination were not pretextual.On appeal, the United States Court of Appeals for the First Circuit reviewed the summary judgment ruling de novo. The court held that the district court erred by treating close temporal proximity as a necessary condition for causation and by failing to consider the employer’s shifting explanations for the termination as evidence of pretext. The First Circuit vacated the district court’s summary judgment on the Law 115 claim and remanded for further proceedings, holding that genuine issues of material fact remained regarding causation and pretext. View "Mercado v. Hyannis Air Service, Inc." on Justia Law

A long-serving postal employee applied for two higher-level postmaster positions in New Hampshire. At the time of her applications, she was 58 years old and had significant experience. For the first position, she was interviewed by her supervisor but was not selected; instead, a 36-year-old man was chosen, with the supervisor citing his greater relevant experience. Several months later, she applied for a second position, was again interviewed by the same supervisor, and was again passed over in favor of a man, this time 53 years old. During the second interview, the supervisor remarked that the office had never had a female postmaster and questioned whether the applicant had the energy for the job. The applicant believed she was denied both promotions due to her age and sex, and she pursued administrative remedies before filing suit.The United States District Court for the District of New Hampshire granted summary judgment to the employer, the United States Postal Service, on all claims. The court found that the employer had provided legitimate, nondiscriminatory reasons for its decisions and that no reasonable jury could find those reasons to be pretextual. The court applied the McDonnell Douglas burden-shifting framework to both the age and sex discrimination claims.On appeal, the United States Court of Appeals for the First Circuit reviewed the summary judgment decision de novo. The court affirmed the district court’s grant of summary judgment on the age discrimination claims, holding that the plaintiff had waived any argument for a more lenient causation standard and that, under the McDonnell Douglas framework, no reasonable jury could find pretext. The court also affirmed summary judgment on the sex discrimination claim related to the first promotion. However, the court reversed summary judgment on the sex discrimination claim regarding the second promotion, finding that the supervisor’s comments during the interview created a genuine dispute of material fact as to pretext and discriminatory motive. The case was remanded for further proceedings on that claim. View "Warner v. Steiner" on Justia Law

The appellant, a former Senior Vice President of Corporate Development at a pharmaceutical company, had a longstanding history of back and hip problems, leading him to stop working in 2014. He received long-term disability benefits under an insurance plan administered by USAble Life for several years. In 2019, USAble terminated his benefits, citing evidence of significant improvements in his physical condition, including weight loss, increased exercise, travel, and other activities inconsistent with total disability. The termination was based on updated medical records, surveillance, and reviews by independent physicians, despite continued support for disability from some of the appellant’s treating doctors.After the termination, the appellant pursued multiple rounds of internal appeals with USAble, submitting additional medical and vocational evidence. USAble obtained further independent medical reviews, which consistently concluded that the appellant was no longer disabled under the plan’s definition. The appellant then filed suit in the United States District Court for the District of Massachusetts, which granted summary judgment in favor of USAble, finding that the insurer’s decision was reasonable and supported by substantial evidence.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s summary judgment ruling de novo but applied a deferential “arbitrary and capricious” standard to USAble’s benefits determination, as required under ERISA. The First Circuit held that USAble’s decision to terminate benefits was reasoned and supported by substantial evidence, that USAble properly applied the plan’s definition of disability, and that it adequately explained its disagreement with the appellant’s treating physicians. The court also found that any structural conflict of interest was sufficiently mitigated. Accordingly, the First Circuit affirmed the district court’s judgment in favor of USAble. View "Bernitz v. USAble Life" on Justia Law