Justia Labor & Employment Law Opinion Summaries

A physician assistant worked for a medical practice in New Hampshire for over a decade. During her employment, she had a series of contentious interactions with one of the practice’s orthopedic surgeons, who was also a partner and vice-president of the organization. The surgeon accused her of being disrespectful and ultimately insisted that he could not remain at the practice if she continued to work there. This ultimatum led the practice’s partners to vote unanimously to terminate her employment. However, the practice allowed her to continue working during a transition period while the parties negotiated a severance agreement and a possible independent contractor arrangement.After the employee raised concerns that her termination was driven by sex discrimination, the practice ended negotiations and immediately terminated her employment. She subsequently filed suit in the United States District Court for the District of New Hampshire against both the medical practice and the surgeon, alleging sex discrimination and retaliation under federal and state law. The district court granted summary judgment in favor of both defendants, concluding that there was insufficient evidence to support her claims.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s grant of summary judgment on the sex discrimination claim, finding there was no genuine issue of material fact that her termination was motivated by gender bias rather than personal conflict. However, the court reversed summary judgment on the retaliation claim against the practice. The court held there was sufficient evidence for a reasonable jury to find that the practice accelerated her termination and withdrew an independent contractor opportunity in retaliation for her complaint of sex discrimination. The case was remanded for further proceedings on the retaliation claim. View "Russo v. New Hampshire Neurospine Institute, P.A." on Justia Law

Several employees of Veolia Water Contract Operations USA, Inc. sued their employer, seeking prevailing wages under the Massachusetts Prevailing Wage Act (PWA) for certain repair and replacement work they performed pursuant to a contract between Veolia and the Springfield Water and Sewer Commission. That contract was authorized by a 1997 Massachusetts Special Act, which provided that work falling within "the construction and design of improvements" remained governed by the PWA. The disputed work occurred during the contract’s second stage, which involved ongoing operation, maintenance, repair, and replacement of wastewater facilities.After both sides moved for summary judgment, the United States District Court for the District of Massachusetts ruled for Veolia. The court concluded that the employees’ work did not fall under "construction and design of improvements" as used in the Special Act and, relying on the Supreme Judicial Court of Massachusetts’s (SJC) decision in Metcalf v. BSC Group, Inc., determined that the structure of the procurement scheme made the PWA inapplicable to the service contract as a whole. The employees appealed.The United States Court of Appeals for the First Circuit, reviewing the case, certified two questions regarding Massachusetts law to the SJC. The SJC clarified that "construction and design of improvements" in the Special Act is broader than the PWA’s definition of “construction” but does not include ordinary repairs or maintenance. The SJC also held that the Special Act was not incompatible with the PWA and that Metcalf was not controlling. Based on the SJC’s answers, the First Circuit held that the district court’s summary judgment for Veolia could not stand, reversed the order, vacated the judgment, and remanded the case for further proceedings to determine which, if any, of the employees’ tasks fell within the statutory phrase. View "Nicholls v. Veolia Water Contract Operations USA, Inc." on Justia Law

The case concerns the estate administrators of a former employee, Juliana Rodriguez Morel, who alleged she was discriminated and retaliated against by her employer, Mammoth Tech, Inc., during her pregnancy. After initially filing an administrative complaint with the New Hampshire Commission for Human Rights and the EEOC in 2019, Rodriguez Morel obtained a right-to-sue letter from the EEOC. She then filed a lawsuit in the United States District Court for the District of New Hampshire. That court entered a default judgment against Mammoth in 2023, awarding damages and fees.Subsequently, in 2025, the estate administrators initiated a separate action in the same district court against Travelers Casualty and Surety Company of America, Mammoth’s insurer. They sought a declaratory judgment that Travelers was required to pay the losses Mammoth incurred as a result of the default judgment, arguing that the insurer’s policy provided coverage for the claims in question. Travelers moved for judgment on the pleadings, contending that the policy did not provide coverage because Mammoth had received notice of the claims prior to the policy period, thus excluding coverage under the policy’s terms. The District Court agreed with Travelers and granted judgment on the pleadings.The United States Court of Appeals for the First Circuit reviewed the case de novo. The court held that the insurance policy’s “Related Claims” provision applied, which meant that all related claims were considered made at the time the first such claim was made. Because the first notice of the employment discrimination claims was before the policy period, the policy did not cover the judgment. The First Circuit affirmed the District Court’s decision, holding that the administrators failed to show any conflict or ambiguity in the policy that would override the Related Claims provision. View "Urena v. Travelers Casualty and Surety Co. of America" on Justia Law

A professor at Dartmouth College’s Thayer School of Engineering, who is Muslim and of Arab-Egyptian descent, applied for tenure after six years of employment, consistent with his offer letter. He alleged that he was discouraged from advising a Muslim student group, removed from a research project, and denied access to campus data, which he believed impeded his work. His tenure application was reviewed by faculty who cited concerns about inflated accomplishments, high self-citation rates, less competitive grant funding, and poor teaching evaluations. The faculty voted overwhelmingly to deny tenure. An internal review committee found procedural errors in how the consequences of tenure denial were explained, allowing him to reapply, but found no discrimination. Separately, a student accused the professor of research misconduct for not crediting him as an author on a collaborative paper. An investigation committee ultimately found no research misconduct but concluded the professor’s conduct was unethical and recommended he not be allowed to collaborate with Dartmouth in the future.The United States District Court for the District of New Hampshire granted summary judgment to Dartmouth on all claims of discrimination and retaliation, finding no genuine issue of material fact. The professor appealed, challenging both the discrimination and retaliation rulings, as well as a discovery order.The United States Court of Appeals for the First Circuit reviewed the case de novo. It held that the plaintiff failed to provide sufficient evidence of pretext or discriminatory animus under both Title VII and New Hampshire’s employment discrimination statute. The court determined that differences in qualifications and procedural issues did not support an inference of discrimination or retaliation. The summary judgment was affirmed, and the challenge to the discovery order was deemed moot due to the affirmed judgment. View "Farid v. Trustees of Dartmouth College" on Justia Law

John Buccieri, who is deaf and communicates primarily through American Sign Language, applied for a Chair Car Driver position with Brewster Ambulance Service, Inc., a medical transportation provider in Massachusetts. The job required frequent communications with dispatch, patients, and facility staff, as well as monitoring patients for emergencies. Buccieri requested to use Video Relay Services (VRS) and a phone holder as accommodations to facilitate communication with dispatch. Brewster considered his application and allowed him a ride-along in a Chair Car, but concerns arose about his ability to communicate and respond to emergencies, especially with patients and staff. Brewster ultimately declined to hire Buccieri, citing safety and operational concerns, and explored but rejected alternative positions for him.Buccieri sued Brewster in the United States District Court for the District of Massachusetts under the Americans with Disabilities Act (ADA), alleging failure to hire and failure to engage in the interactive process required by the ADA. The case proceeded to a jury trial, which found for Brewster on the failure-to-hire claim, concluding that accommodating Buccieri would have imposed an undue hardship or posed a direct threat. However, the jury found for Buccieri on the interactive process claim, indicating Brewster had not sufficiently engaged in dialogue to identify reasonable accommodations.Following the verdict, Brewster filed a Rule 50(b) motion for judgment as a matter of law. The district court granted the motion, setting aside the jury's finding on the interactive process claim, and entered judgment for Brewster on all counts. The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court’s order. The court held that, based on the evidence, no reasonable jury could conclude that a reasonable accommodation existed that would have allowed Buccieri to perform the essential communications functions of the driver positions without undue hardship to Brewster. View "Buccieri v. Brewster Ambulance Service, Inc." on Justia Law

The plaintiff worked for over twenty years in various administrative roles for the Drug Enforcement Agency (DEA) in Puerto Rico, eventually becoming Secretary to the Assistant Special Agent in Charge. In 2016, after suffering a foot injury, she requested workplace accommodations, some of which were denied. She filed an Equal Employment Opportunity (EEO) complaint alleging discrimination based on disability and national origin. Subsequently, other DEA agents filed an EEO complaint against her, and she filed a retaliation complaint with the Department of Justice’s Office of the Inspector General. A series of workplace conflicts followed, including a verbal altercation, revocation of outside work permission, and eventual suspension. After further absence and issues with communication with supervisors, she was reassigned to another office. An internal investigation led to her termination for insubordination and alleged lack of candor.She appealed her termination to the Merit Systems Protection Board (MSPB), arguing it was retaliatory and unsupported by evidence. The MSPB found no lack of candor, but upheld the insubordination charge and her termination. She then sought judicial review in the United States District Court for the District of Puerto Rico, which denied her discovery motions and granted summary judgment to the government, finding no prima facie case of retaliation and holding that the MSPB’s decision was supported by substantial evidence.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court’s rulings. The court held that the denial of the plaintiff’s Rule 56(d) motion for additional discovery was not an abuse of discretion, as she did not show good cause for her delay. On the merits, the court concluded that the MSPB’s finding of insubordination was supported by substantial evidence and that the plaintiff failed to show the employer’s stated reasons for termination were pretext for retaliation under Title VII. View "Hernandez v. Blanche" on Justia Law

A tenured professor at a university was terminated in 2022 following a classroom incident where students objected to terminology used in an assigned reading and a subsequent discussion of LGBTQ+ rights in Latin America. The professor alleged that her Department Chair encouraged students to submit complaints against her, and that there was a coordinated effort to undermine her reputation. After complaints were submitted, the university held a student meeting about the professor’s conduct, restricted some of her duties, and ultimately terminated her employment "for cause," citing continued misconduct and failure to fulfill faculty responsibilities. The professor appealed her termination to the Faculty Hearing Board, which upheld the decision by a narrow margin, citing procedural issues but attributing them to outdated dismissal procedures rather than prejudice. The Board found her teaching was not culturally responsive and noted longstanding concerns about her interaction with students. The minority opinion of the Board disagreed, finding the process unfair. The university’s Board of Trustees unanimously affirmed the termination.The professor then filed a verified complaint in Rhode Island Superior Court against the university, its Board of Trustees, and several colleagues. She alleged violations of federal and state anti-discrimination laws, as well as state tort and contract claims related to her termination. The university removed the case to the United States District Court for the District of Rhode Island and moved to dismiss. The district court dismissed the federal and state anti-discrimination claims for failure to state a claim, finding insufficient factual allegations connecting protected characteristics to the termination. The court declined to exercise supplemental jurisdiction over the state claims and remanded them to state court.On appeal, the United States Court of Appeals for the First Circuit affirmed the district court’s judgment. The First Circuit held that the professor failed to plead sufficient facts to make her discrimination, hostile work environment, and retaliation claims plausible, and found no error in the district court’s consideration of certain documents. View "Crawford v. Salve Regina University" on Justia Law

The case involves a dispute between two unions representing Department of Veterans Affairs (VA) employees and the VA itself, along with the VA Secretary. The core issue centers on the VA’s termination of a collective bargaining agreement (CBA) that was signed in August 2023 and set to last three years. The termination followed a March 2025 executive order by President Trump that excluded the VA from coverage under the Federal Service Labor-Management Relations Statute (FSLMRS), citing national security. The VA Secretary then terminated the CBA, prompting the unions to file suit, alleging violations of the Administrative Procedure Act (APA) and the First Amendment.Prior to this case, unions not party here challenged the executive order in the U.S. District Court for the Northern District of California, which issued a preliminary injunction. That injunction was later stayed and ultimately vacated on appeal by the Ninth Circuit. In the present case, the U.S. District Court for the District of Rhode Island granted a preliminary injunction requiring the VA to reinstate the CBA and later issued an enforcement order when the VA attempted to re-terminate the agreement. The district court found that the termination was likely retaliatory and arbitrary and capricious.On appeal, the United States Court of Appeals for the First Circuit reviewed requests to stay both the preliminary injunction and the enforcement order. The First Circuit denied the VA’s request to stay the preliminary injunction, finding the VA had not made a strong showing of likely success on appeal. However, the court granted a partial stay of the enforcement order, holding that the district court likely lacked jurisdiction to order specific compliance with every term of the CBA under threat of contempt. The court otherwise denied the VA’s requests. View "American Federation of Gov't Employees Local 2305 v. United States Department of Veterans Affairs" on Justia Law

After Puerto Rico was struck by Hurricane Maria, a nonprofit organization based in Oklahoma, known as "The Facilitators: Iron Horse, Inc." (TFCI), received federal funds from the Federal Emergency Management Agency (FEMA) to provide post-disaster services. The plaintiffs in this case were hired by TFCI to perform this work. When TFCI’s federal funding was exhausted, it sought additional funds from FEMA, but that request was denied. Despite this, the plaintiffs continued working without full pay for several weeks before being terminated by TFCI.The plaintiffs filed suit in the United States District Court for the District of Puerto Rico seeking backpay from FEMA and TFCI, claiming they were entitled to wages as employees under the Fair Labor Standards Act (FLSA). FEMA removed the case to federal court. The plaintiffs amended their complaint multiple times to clarify their FLSA claims and add additional plaintiffs. Both sides moved for summary judgment. The district court granted summary judgment for FEMA, finding the plaintiffs were not FEMA employees under the FLSA, and entered summary judgment for TFCI as well. The court declined to exercise supplemental jurisdiction over the Commonwealth-law claims.On appeal, the United States Court of Appeals for the First Circuit reviewed the district court’s decision de novo. The court found that the uncontroverted facts established that TFCI, not FEMA, had the authority to hire, fire, supervise work, set pay, and maintain employment records for the plaintiffs. Arguments by the plaintiffs that FEMA exercised sufficient control were unsupported by the record. The First Circuit held that FEMA was not the plaintiffs’ employer under the FLSA and affirmed the district court’s grant of summary judgment in favor of FEMA. View "Perez v. FEMA" on Justia Law

Four employees of the University of Puerto Rico sought to stop the deduction of union dues from their paychecks after the Supreme Court’s decision in Janus v. American Federation of State, County, & Municipal Employees, Council 31, which held that public sector employees could not be compelled to pay union dues without consent. Despite their requests, the University and the union continued to deduct dues for nearly three years. The employees then brought suit against the University’s president and the union, alleging violations of their First Amendment rights and seeking declaratory and injunctive relief, as well as damages.The United States District Court for the District of Puerto Rico largely granted summary judgment to the University president and the union, finding no constitutional violation. However, the court ordered the union to reimburse the employees for dues deducted after their resignations but denied interest and did not grant declaratory or injunctive relief. The court also declined to exercise supplemental jurisdiction over the employees’ Puerto Rico law claims.On appeal, the United States Court of Appeals for the First Circuit was asked only to direct the district court to issue declaratory judgments stating that the past and potential future deductions were unconstitutional. The First Circuit dismissed the appeal as moot. It held that a declaration regarding past conduct would be merely advisory because the deductions had already ceased and a judgment ordering reimbursement was in place. The court also found the request for prospective relief moot, as the University and union had admitted their error, stopped the deductions, and adopted new policies to comply with Janus. The court concluded there was no substantial controversy remaining and that the voluntary cessation doctrine did not apply under these facts. The appeal was therefore dismissed as moot. View "Ramos-Ramos v. Jordan-Conde" on Justia Law