Justia Labor & Employment Law Opinion Summaries

The Massachusetts Delivery Association (MDA), a trade organization representing same-day delivery companies in Massachusetts, brought this suit on behalf of its members seeking a declaration that “Prong 2” of the Massachusetts Independent Contractor Statute is preempted by the Federal Aviation Administration Authorization Act (FAAAA) as well as an injunction barring the Attorney General from enforcing Prong 2 against its members. After the First Circuit twice remanded the case, the district court held that the FAAAA preempts Prong 2 as to the members of the MDA as a matter of logical effect. Applying the logic of the First Circuit's decision in Schwann v. FedEx Ground Package System, Inc., the First Circuit affirmed, holding that the application of Prong 2 to the members of the MDA is preempted by the FAAAA. View "Massachusetts Delivery Ass’n v. Healey" on Justia Law

After he was terminated from his employment Plaintiff sued his former employer and its parent company (collectively, Defendants) alleging violations of the Americans with Disabilities Act and its Massachusetts analog. Plaintiff also alleged a state wrongful discharge claim. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding that the district court (1) did not err in its assessment that Plaintiff could not establish a prima facie case of disability discrimination; and (2) correctly concluded that Plaintiff failed to carry his burden of establishing that his termination implicated a sufficiently important and clearly defined public policy in Massachusetts. View "Murray v. Warren Pumps, LLC" on Justia Law

Plaintiff filed a discrimination and retaliation suit against his Employer, alleging illegal harassment, discrimination and retaliation. Employer filed a motion for summary judgment, arguing that it did not employ the minimum number of employees necessary to qualify as an “employer” under either the Americans with Disabilities Act (ADA) or the Age Discrimination in Employment Act (ADEA). Plaintiff filed a memorandum in opposition to Employer’s motion for summary judgment, attaching a post-discovery sworn statement in support of his opposition. Employer requested that the district court strike the sworn statement. The district court granted Employer’s motions for summary judgment and to strike Employer’s sworn statement under the sham affidavit doctrine. The district court then sanctioned Plaintiff’s counsel for filing the sham affidavit after he received repeated warnings in earlier cases not to do so. The First Circuit affirmed, holding that the district court did not abuse its discretion in (1) striking Plaintiff’s sworn statement; (2) granting summary judgment to Employer on the basis that Plaintiff did not meet his burden of showing that Employer had enough employees to qualify as a covered employer under either the ADA or ADEA; and (3) ordering sanctions. View "Escribano-Reyes v. Prof’l HEPA Certificate Corp." on Justia Law

While working for Wal-Mart Stores East, L.P., Plaintiff claimed a disability arising from her “pregnancy status.” Plaintiff, however, claimed she could perform the essential functions of her job with a reasonable accommodation. Wal-Mart refused Plaintiff’s accommodation request and later terminated her. Plaintiff brought this action against Wal-Mart claiming violations of the Americans with Disabilities Act (ADA) and the New Hampshire Civil Rights Act. The district court granted summary judgment in favor of Wal-Mart on all claims. The First Circuit affirmed, holding (1) the trial judge correctly granted summary judgment to Wal-Mart on the ADA claim, as Plaintiff failed to create a trial worthy issue as to whether she could have performed an essential function of her job with or without reasonable accommodation; and (2) Plaintiff’s challenges to the dismissal of her state-law claims of unlawful disability discrimination and retaliation were without merit. View "Lang v. Wal-Mart Stores East, L.P." on Justia Law

In 2004, five structural steel contractors filed a complaint against a local union - Labor Union No. 7 of the International Association of Bridge, Structural, Ornamental & Reinforcing Iron Workers - alleging labor law violations under the Labor Management Relations Act (LMRA), antitrust law violations under the Sherman Act, and other violations under state law. The First Circuit reviewed the matter and found elements pertaining to the federal claims undeveloped. Therefore, the Court remanded for further proceedings. After a trial, the case once again reached the First Circuit, with both parties appealing and cross-appealing various aspects of the final judgment. The First Circuit affirmed the district court’s decisions upholding the LMRA jury verdict and award of damages for Plaintiffs D.F.M. Industries, Inc. and Ajax Construction Company, Inc. and granting summary judgment for Defendant on the antitrust claims, holding that the trial court did not err in its judgment. View "Am. Steel Erectors, Inc. v. Local Union No. 7" on Justia Law

Plaintiffs, individuals who contracted with FedEx to provide pick-up and delivery services, filed a complaint claiming that FedEx should have treated and paid them as employees rather than as independent contractors because FedEx could not satisfy all three requirements under the Massachusetts Independent Contractor Statute (Massachusetts Statute). Plaintiffs sought damages for loss of wages, improper wage deductions, and loss of benefits. The district court ultimately granted FedEx summary judgment on all counts, concluding (1) application of one of the requirements of the Massachusetts Statute is preempted by the Federal Aviation Administration Authorization Act (FAAAA), and this preempted requirement is not severable from the two remaining requirements; and (2) the remaining two requirements are preempted. The First Circuit reversed, holding (1) the express preemption provision of the FAAAA preempts the application of one of the Massachusetts Statute’s requirements to FedEx, but the preempted requirement is severable from the two remaining requirements; and (2) the district court erred by concluding, sua sponte, that application of the remaining two requirements was also preempted by the FAAAA. View "Schwann v. FedEx Ground Package Sys., Inc." on Justia Law

GlaxoSmithKline (GSK) fired Blair Hamrick after Hamrick told two Human Resources managers and several co-workers that he wanted to shoot some co-workers. Hamrick alleged that GSK had fired him in retaliation for initiating a qui tam action accusing GSK of fraud under the False Claims Act. The district court granted summary judgment to GSK. Hamrick appealed, challenging both the district court’s decision not to conduct an in camera review of the documents as to which GSK asserted attorney-client privilege and the district court’s grant of summary judgment to GSK. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in declining to conduct in camera review of the items on GSK’s privilege log; and (2) properly granted summary judgment to GSK because no reasonable jury could find that the qui tam action was GSK’s reason for terminating Hamrick. View "Hamrick v. Glaxosmithkline, PLC" on Justia Law

Plaintiff was employed by Defendants as a store manager from 2009 through 2013. Defendant filed this suit challenging his compensation arrangement under the Fair Labor Standards Act (FLSA) and the Massachusetts Minimum Fair Wage Law. Defendants employed a pay structure that combined a fixed weekly salary regardless of hours worked with commission paid weekly. The district court dismissed the complaint for failure to state a claim, concluding that, contrary to Plaintiff’s contention, the commission component of the pay arrangement did not make the pay scheme unlawful. The First Circuit affirmed, holding that a compensation structure employing a fix salary is still lawful when it includes additional, variable performance-based commissions. View "Lalli v. General Nutrition Corp." on Justia Law

Appellants in this case were family child care providers who were considered public employees for purposes of the statute authorizing employees in public service to organize for collective bargaining. A majority of the class of such providers as Appellants chose Service Employees International Union, Local 509 as their exclusive agent for bargaining collectively with the Department of Early Education and Care. No provider was required to become a Union member or to contribute money to the Union for any purpose. Appellants declined to join the Union. Appellants subsequently brought this action under 42 U.S.C. 1983 challenging the statutory scheme that authorizes the selection of an exclusive bargaining agent to “agree on terms that affect their relationships with their clients and the government.” The district court dismissed the complaint for failure to state a claim. The First Circuit affirmed based on established precedent, holding that Appellants were free from enforced association with the Union. View "D'Agostino v. Baker" on Justia Law

After Plaintiff was terminated from her employment with Puerto Rico’s Vocational Rehabilitation Administration, she filed a federal-court suit alleging that Defendants discriminated against her because of her disability, age, and politics. Plaintiff’s complaint alleged various violations of federal and local law. The district court dismissed Plaintiff’s 42 U.S.C. 1983 claim for failure to exhaust administrative remedies and then dismissed the remaining claims without explanation. The First Circuit affirmed the district court’s judgment in every respect, except that the Court reversed the dismissal of Plaintiff’s Americans with Disabilities Act (ADA) claim, holding (1) the district judge erred in concluding that Plaintiff’s section 1983 claim was barred for failure to exhaust administrative remedies, but Plaintiff’s section 1983 was time-barred; (2) because Defendants agreed that Plaintiff’s ADA claim should not have been dismissed on failure-to-exhaust grounds, the reversal is dismissed; (3) Plaintiff’s age discrimination claim was correctly dismissed for failure to exhaust; and (4) because the dismissal of the ADA claim is reversed, the judge on remand must reinstate the local-law claims as well. View "Martinez-Rivera v. Commonwealth of P.R." on Justia Law