Justia Labor & Employment Law Opinion Summaries

Efrain Oliveras-Villafañe, Mirta Rosario-Montalvo, and their conjugal partnership (collectively, "Appellants") filed a lawsuit against Baxter Healthcare SA and related entities ("Appellees"), alleging unlawful discrimination. Oliveras worked for Baxter from 1990 until 2019, holding various positions, including Engineering Director. In 2018, he was transferred to a lower position, which he claimed was part of a discriminatory effort to remove senior Puerto Rican personnel. In 2019, his position was eliminated, and he chose termination over accepting two part-time roles. He filed a discrimination charge with the EEOC in May 2019.The United States District Court for the District of Puerto Rico granted summary judgment in favor of the Appellees. The court found that the Appellants failed to comply with Local Rule 56(c) and disregarded non-compliant facts. It dismissed the Title VII claims, ruling that the EEOC charge did not encompass the February 2018 transfer and was untimely. The court also found that the Appellants did not establish a prima facie case of discrimination regarding the March 2019 termination. The remaining claims were dismissed based on the Appellants' concessions.The United States Court of Appeals for the First Circuit affirmed the district court's judgment. The appellate court noted that the Appellants failed to challenge the district court's finding that the EEOC charge did not encompass the February 2018 transfer, leaving an independent ground for affirmance. The court emphasized that arguments must be clearly articulated and supported, and the Appellants' failure to address the exhaustion issue was fatal to their appeal. Thus, the district court's decision was upheld. View "Oliveras-Villafane v. Baxter Healthcare SA" on Justia Law

The U.S. Department of Education announced a reduction in force (RIF) on March 13, 2025, affecting about half of its employees. Subsequently, twenty-one states and several labor organizations and school districts filed lawsuits against the Secretary of Education, the Department, and the President, claiming that the RIF violated the U.S. Constitution and the Administrative Procedure Act (APA). They also sought an injunction against the transfer of certain functions out of the Department, announced by the President on March 21, 2025.The U.S. District Court for the District of Massachusetts consolidated the cases and granted the plaintiffs' motions for a preliminary injunction. The court found that the plaintiffs were likely to succeed on the merits of their claims, determining that the RIF and the transfer of functions were likely ultra vires and violated the APA. The court concluded that the actions were arbitrary and capricious, lacking a reasoned explanation and failing to consider the substantial harms to stakeholders.The United States Court of Appeals for the First Circuit reviewed the case. The court denied the appellants' motion for a stay pending appeal. The court found that the appellants did not make a strong showing that they were likely to succeed on the merits, particularly regarding the APA claims. The court also determined that the plaintiffs would suffer substantial injury without the injunction, as the RIF made it effectively impossible for the Department to carry out its statutory functions. The court concluded that the public interest favored maintaining the injunction to ensure the Department could fulfill its legal obligations. View "New York v. McMahon" on Justia Law

David Keane's employment with Expeditors Hong Kong Limited (Expeditors HK) was terminated on December 11, 2023. Keane subsequently filed a lawsuit against Expeditors HK and Expeditors International of Washington, Inc. (Expeditors US) in the District of Massachusetts, alleging federal and state law claims related to his termination. Expeditors HK is a wholly owned subsidiary of Expeditors US. The defendants moved to dismiss the claims for lack of personal jurisdiction, forum non conveniens, and improper venue for the federal law claim.The United States District Court for the District of Massachusetts granted the defendants' motion to dismiss. The court dismissed the claims against Expeditors HK and the non-contract claims against Expeditors US for lack of personal jurisdiction. The contract claims against Expeditors US were dismissed under the doctrine of forum non conveniens. The court found that Keane failed to provide sufficient evidence to support his assertion that Expeditors HK was an alter ego of Expeditors US.The United States Court of Appeals for the First Circuit reviewed the case and affirmed the district court's dismissals. The appellate court held that the Massachusetts federal district court lacked personal jurisdiction over Expeditors HK. Regarding the claims against Expeditors US, the court found that Keane could not prevail without proving wrongful termination by Expeditors HK, and he failed to allege sufficient facts or legal theories to impute Expeditors HK's actions to Expeditors US. The court concluded that Keane's complaint did not provide adequate grounds to disregard the corporate formalities between Expeditors US and Expeditors HK. View "Keane v. Expeditors International of Washington, Inc." on Justia Law

Northeastern University operates a campus police department (NUPD) responsible for the safety and security of its Boston campus. The NUPD includes Sergeants and Sergeant Detectives who oversee Patrol Officers, Community Service Officers, and Detectives. The American Coalition of Public Safety (ACOPS) sought to represent a bargaining unit including these Sergeants and Sergeant Detectives. Northeastern argued that these employees were supervisors under the National Labor Relations Act (NLRA) and thus excluded from the bargaining unit.The Regional Director for Region 1 of the National Labor Relations Board (NLRB) held a hearing and concluded that Northeastern failed to prove that Sergeants and Sergeant Detectives were supervisors. The Director found that while Sergeants had some role in assigning duties, they did not exercise independent judgment in doing so. The NLRB denied Northeastern's request for review and certified the union. Northeastern refused to bargain, leading to an unfair labor practice charge. The NLRB granted summary judgment against Northeastern, ordering it to bargain with ACOPS.The United States Court of Appeals for the First Circuit reviewed the case. The court found that the NLRB's conclusion that Sergeants and Sergeant Detectives were not supervisors was not supported by substantial evidence and deviated from precedent without adequate explanation. The court held that Sergeants and Sergeant Detectives do exercise independent judgment in assigning duties and managing the Incident Containment Team (ICT) and details. Consequently, the court denied the NLRB's cross-petition for enforcement, vacated the unfair labor practice finding against Northeastern, and remanded the case for further proceedings consistent with its opinion. View "Northeastern University v. National Labor Relations Board" on Justia Law

Eric Moore, an employee of Industrial Demolition LLC, injured his hip while working at the Brayton Point Power Station demolition site in December 2019. Despite his injury, Moore was able to continue working with reasonable accommodations. He returned to work with a doctor's note outlining his limitations and requested accommodations from Industrial Demolition. Although initially allowed to work with restrictions, Moore's supervisor became hostile towards him, leading to Moore's termination after an argument over his job-related limitations and requests for accommodation.A federal jury in the District Court for the District of Massachusetts found that Industrial Demolition failed to accommodate Moore's injury and retaliated against him for requesting or using a reasonable accommodation. The jury awarded Moore $10,035 in damages. Both Moore and Industrial Demolition were dissatisfied with the result and sought to reverse or amend the judgment or to grant a new trial.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's verdict, finding that the jury's determination that Moore was retaliated against for requesting or using a reasonable accommodation was supported by sufficient evidence. The court also upheld the district court's decision to allow the jury to consider the NLRB settlement payment in calculating damages, rejecting Moore's argument that the settlement should be excluded as collateral source income. Additionally, the court affirmed the district court's denial of Moore's motion for a new trial on the issue of punitive damages, concluding that the evidence did not support a finding of outrageous or egregious conduct by Industrial Demolition warranting punitive damages. View "Moore v. Industrial Demolition LLC" on Justia Law

The case involves Leika Joanna García-Gesualdo, who filed an employment discrimination lawsuit against Honeywell Aerospace of Puerto Rico, Inc., and Honeywell International, Inc. García-Gesualdo alleged that Honeywell discriminated against her in violation of Title VII of the Civil Rights Act of 1964 and the Americans with Disabilities Act (ADA). The EEOC investigated her claims but decided not to proceed further, issuing a right-to-sue letter on March 29, 2022. García-Gesualdo filed her lawsuit on July 7, 2022, 100 days after the EEOC's decision.The United States District Court for the District of Puerto Rico dismissed García-Gesualdo's claims as time-barred, agreeing with Honeywell that the complaint was filed more than ninety days after the EEOC issued the right-to-sue letter. The court noted that García-Gesualdo's attorney received emails from the EEOC on March 29 and April 6, indicating that a new document was available on the EEOC's portal. The district court concluded that the ninety-day period began on either March 29 or April 6, making the July 7 filing untimely.The United States Court of Appeals for the First Circuit reviewed the case and reversed the district court's dismissal. The appellate court held that neither the March 29 email nor the April 6 email provided sufficient notice of García-Gesualdo's right to sue. The court emphasized that the emails did not unambiguously indicate that the EEOC had terminated its processes or that the ninety-day period to file a lawsuit had begun. Therefore, the appellate court concluded that the facts establishing untimeliness were not clear on the face of the pleadings, and the case was remanded for further proceedings. View "Garcia-Gesualdo v. Honeywell Aerospace of Puerto Rico, Inc." on Justia Law

Scott Cannon, individually and as the personal representative of the estate of Blaise Cannon, filed a wrongful death and punitive damages claim against Blue Cross and Blue Shield of Massachusetts (BCBS). Cannon alleged that BCBS's denial of coverage for a specific inhaler led to asthma-related complications that contributed to Blaise's death. Blaise was a beneficiary of his partner's BCBS health insurance policy, which was governed by the Employee Retirement Income Security Act of 1974 (ERISA).The United States District Court for the District of Massachusetts granted summary judgment to BCBS on the grounds of ERISA preemption. The court found that Cannon's wrongful death claim was preempted by ERISA because it related to an employee benefit plan and arose from the denial of benefits under that plan. The court also held that the claim conflicted with the remedial scheme established by ERISA, which provides specific civil enforcement mechanisms.The United States Court of Appeals for the First Circuit reviewed the case de novo and affirmed the district court's decision. The appellate court held that Cannon's claim was statutorily preempted under ERISA because it had a connection with the ERISA-regulated health insurance plan. The court also found that the claim was preempted under ERISA's civil enforcement provisions, as it sought remedies for the denial of benefits under the plan. The court rejected Cannon's argument that the Supreme Court's decision in Rutledge v. Pharmaceutical Care Management Association altered the preemption analysis, reaffirming that ERISA preempts state laws that relate to employee benefit plans. The court concluded that Cannon's wrongful death claim was derivative of Blaise's potential claim for benefits, which would have been preempted by ERISA. View "Cannon v. Blue Cross and Blue Shield of Massachusetts, Inc." on Justia Law

Dr. Susan O'Horo, an interventional radiologist and Director of Quality and Safety at Boston Medical Center Corporation (BMC), alleged that she faced discriminatory and retaliatory actions at her workplace. She claimed that her efforts to report safety concerns, particularly regarding a colleague, Dr. Mikhail Higgins, were met with hostility and that she was ultimately forced to resign due to the intolerable work environment.In the United States District Court for the District of Massachusetts, Dr. O'Horo filed claims under Title VII of the Civil Rights Act of 1964, Massachusetts General Laws Chapter 151B, and the Massachusetts Health Care Whistleblower Act (MHCWA). The defendants, including BMC, Boston University Medical Center Radiologists, Inc. (BUMCR), and Dr. Jorge Soto, moved for summary judgment. The magistrate judge recommended granting the motion, and the district court adopted this recommendation, dismissing all of Dr. O'Horo's claims.The United States Court of Appeals for the First Circuit reviewed the case. The court affirmed the district court's decision, holding that Dr. O'Horo failed to establish a prima facie case of gender discrimination or retaliation. The court found that the alleged adverse actions, such as the reassignment of her duties and the scheduling of reviews, did not constitute materially adverse employment actions. Additionally, the court concluded that the hostile work environment claim was insufficient as the workplace was not objectively hostile or abusive. The aiding and abetting claim under Chapter 151B was dismissed as it was derivative of the failed discrimination claims. Lastly, the court held that Dr. O'Horo did not establish a prima facie case under the MHCWA, as she failed to show that the actions taken against her were retaliatory. View "O'Horo v. Boston Medical Center Corporation" on Justia Law

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