Justia Labor & Employment Law Opinion Summaries

Plaintiffs, two high-profile medical researchers that held faculty appointments at Harvard Medical School and were intimately involved with a research laboratory at Brigham and Women’s Hospital, were investigated for alleged research misconduct. Responding to allegations that Plaintiffs used manipulated research data in articles reporting on studies supported by government funds, Harvard and Brigham triggered a unique federal statutory and regulatory scheme. Without awaiting the outcome of the administrative proceedings, Plaintiffs filed suit in federal court against the institutional defendants, alleging, inter alia, tortious interference with business relations, invasion of privacy, and unfair and deceptive business practices. The district court dismissed the action, concluding that the suit was premature because Plaintiffs had not exhausted their administrative remedies. The First Circuit affirmed as modified, holding (1) the district court correctly applied the doctrine of administrative exhaustion; but (2) on remand, the district court is directed to convert its order of dismissal to an order staying the case pending the timely resolution of administrative proceedings. View "Anversa v. Partners Healthcare Sys., Inc." on Justia Law

Plaintiffs, a putative class of unionized “visiting” nurses, sued their employer - Baystate Visiting Nurse association & Hospice, Inc. and Baystate Health, Inc. (collectively, “Baystate”) - in state court for unpaid wages and overtime pay. Plaintiffs conceded that they were subject to the terms of a collective bargaining agreement (CBA) between the union and Baystate. Baystate removed this action to federal court, citing the doctrine of complete preemption, under which claims requiring interpretation of a CBA are reclassified as federal claims. The district court denied Plaintiffs’ motion to remand, concluding that complete preemption applied. The district court then granted Defendants’ motion for judgment on the pleadings and dismissed Plaintiffs’ claims. The First Circuit affirmed, holding (1) resolving one of the claims would require a court to interpret the CBA, and therefore, the claim was completely preempted, and the entire action was removable to federal court; and (2) the CBA required Plaintiffs to raise their wage claims through the grievance procedure, and therefore, the district court properly entered judgment on the pleadings. View "Rueli v. Baystate Health, Inc." on Justia Law

Plaintiff, a former graduate student intern at the John A. Volpe National Transportation System Center, sought access to the Volpe Centers propriety data through a Cooperative Research and Development Agreement (CRADA) to continue her thesis, but the CRADA was never executed. Plaintiff brought an employment discrimination suit against the Secretary of Transportation, alleging that, by failing to execute the CRADA, the Secretary discriminated against her on the basis of her sex, race, or national origin. The district court granted summary judgment against Plaintiff on the CRADA claim. The First Circuit affirmed, holding that summary judgment was proper. View "Tyree v. Lahood" on Justia Law

Robert Harris sought to recover in federal bankruptcy court a real estate broker’s commission that he alleged he was owed by Rosa Scarcelli and Oak Knoll Associates, LP (together, Oak Knoll). The bankruptcy court granted Oak Knoll’s motion for summary judgment, concluding, as a matter of law, that Harris was not owed a commission. The First Circuit affirmed, holding that the bankruptcy court correctly granted summary judgment in favor of Oak Knoll, as (1) Harris’s proof of claim for his unpaid commission was unenforceable against Oak Knoll; and (2) Harris failed to identify a right that would entitle him to equitable relief. View "Harris v. Scarcelli" on Justia Law

After her employment was terminated, Employee filed sexual harassment, gender discrimination, and retaliation claims under federal and Puerto Rico law against her former employer (Employer) and its co-owners and administrator. The district court granted summary judgment in favor of Employer on Employee’s federal claims and dismissed Employee’s remaining claims. The district court later awarded attorneys’ fees to the defendants. The First Circuit affirmed, holding that the district court (1) did not abuse its discretion in holding Employee to the local rules’ ordinary page limits; (2) acted within its discretion in awarding attorneys’ fees to the prevailing defendants; and (3) did not err in rejecting Employee’s motions to set aside the summary judgment order and the fees award. View "Fontanillas-Lopez v. Morel Bauza Cartagena & Dapena" on Justia Law

At issue in this case was whether one of the Commonwealth of Puerto Rico’s special-purpose public corporations, the Puerto Rico Ports Authority (PRPA), is an arm of the Commonwealth that enjoys sovereign immunity under the Eleventh Amendment. Daniel Grajales and his family alleged that PRPA subjected Daniel to political discrimination and unlawfully terminated his employment for reasons related to political discrimination and retaliation. After many procedural “twists and turns,” the district court granted PRPA’s motion to dismiss, concluding that PRPA was an arm of the Commonwealth and thus immune from suit under Eleventh Amendment immunity principles. The First Circuit reversed, holding that PRPA was not entitled to claim the Commonwealth’s immunity as an arm of the Commonwealth. Remanded. View "Grajales v. P.R. Ports Auth." on Justia Law

Plaintiff, a Puerto Rico Police Department law enforcement officer, filed a complaint alleging that Defendants, his superior officers, violated the Establishment Clause by holding a group prayer while on duty and punishing Plaintiff for his non-conformance. Defendants moved to dismiss the complaint on the grounds that the complaint failed to allege plausibly a constitutional violation, and invoking qualified immunity. The district court denied the motion on both grounds. Appellants filed this interlocutory appeal to challenge the court’s denial of qualified immunity. The First Circuit affirmed, holding that the district court did not err in rejecting Defendants’ qualified immunity defense. View "Marrero-Mendez v. Calixto-Rodriguez" on Justia Law

This appeal stemmed from an employment dispute between Angel Edgardo Rodriguez-Miranda (Rodriguez) and Malik Benin (Benin), two former colleagues. At issue in this, the the latest round of litigation, was a judgment entered against Benin’s company, Coquico, Inc., in favor of Rodriguez for $348,821. Benin apparently sought to avoid paying the judgment by transferring Coquico’s assets to his mother, Acquanetta Benin (Acquanetta) and to 18 Degrees North, LLC. The district court used Fed. R. Civ. P. 25(c) to hold Coquico, Benin, Acquanetta, and 18 Degrees North (collectively, Appellants) all liable for the judgment. The court also found Benin in civil contempt and imposed a monetary sanction. The First Circuit affirmed, holding (1) the district court did not plainly err in joining Benin, Acquanetta, and 18 Degrees North under Rule 25(c) as alter egos of Coquico and holding them liable for the judgment originally entered against Coquico only; and (2) the district court did not err in fining Appellants in civil contempt and imposing a $5,000 sanction on Benin. View "Rodriguez-Miranda v. Benin" on Justia Law

Plaintiff, a former employee of the Transportation Security Administration, filed suit against David Johnson, the Supervisory Air Marshal in Charge at the Boston Field Office of the Federal Air Marshals Service where Plaintiff worked, and the Department of Homeland Security (DHS), alleging sex discrimination and sex harassment in violation of Title VII of the Civil Rights Act of 1964. The district court dismissed Johnson from the suit and subsequently granted summary judgment in favor of DHS. The Supreme Court reversed the entry of summary judgment, holding (1) the district court erred by requiring Plaintiff to present direct evidence to establish sex discrimination under the mixed-motives theory; (2) the district court erred by requiring Plaintiff to show that Johnson’s conduct was both severe and pervasive to establish sex harassment; and (3) there was sufficient circumstantial evidence from which a reasonable jury could find in Plaintiff’s favor on both of her claims. Remanded. View "Burns v. Johnson" on Justia Law

Plaintiff brought suit against his former employer, Springfield Terminal Railway Company (Defendant), under the whistleblower provisions of the Federal Railroad Safety Act after he was fired. After a trial, the jury awarded Plaintiff $150,000 in compensatory damages and $250,000 in punitive damages. Defendant appealed, arguing that the district court gave an incorrect jury instruction as to the standard for awarding punitive damages. The First Circuit affirmed, holding (1) Defendant’s notice of appeal was timely, and the Court’s jurisdiction over this appeal was proper; and (2) there was no error in the district court’s punitive damages instruction. View "Worcester v. Springfield Terminal Ry. Co." on Justia Law