Justia Labor & Employment Law Opinion Summaries

Relator, an employee of the University of Massachusetts Medical School (UMMS), sued UMMS alleging violations of the False Claims Act (FCA) and its Massachusetts counterpart. The district court dismissed Relator’s FCA claims against UMMS, concluding that UMMS is a state agency and, thus, exempt from the FCA. The district court denied Relator’s subsequent motion for leave to file a third amended complaint, concluding that the proffered complaint would be futile. The First Circuit affirmed, holding (1) UMMS is an arm of the state, not a “person” subject to suit under the FCA, and therefore, UMMS is exempt from suit by private parties under the FCA; and (2) Relator’s attempt to appeal the district court’s denial of leave to amend for want of appellate jurisdiction is dismissed for want of appellate jurisdiction. View "Willette v. Univ. of Mass." on Justia Law

Plaintiff filed this action alleging that she was stripped of various job duties and eventually terminated from her job at the Puerto Rico Highway and Transportation Authority due to her affiliation with the Popular Democratic Party. The district court granted summary judgment in favor of Defendants on Plaintiff’s First Amendment political discrimination claims, concluding that there was insufficient evidence that the stripping of Plaintiff’s job functions constituted adverse employment actions, and absent any political discrimination, Plaintiff would have in any event been terminated for nondiscriminatory reasons. The First Circuit reversed, holding (1) Plaintiff made out a prima facie case of political discrimination; and (2) a genuine dispute existed as to whether Defendants would have fired Plaintiff regardless of her political affiliation. Remanded. View "Reyes-Orta v. P. R. Highway and Transp. Auth." on Justia Law

Article 3 of Puerto Rico’s Law No. 80 requires companies that operate in Puerto Rico to pay a “mesada” - or a statutory severance - to employees who are terminated without “just cause.” Specifically, if the employer terminates a more senior employee without just cause and retains a less senior employee within the same job category, the employer must pay the terminated employee a mesada. Plaintiffs here were seven former employees of American Airlines, Inc. who worked in American’s sole Puerto Rico office. Plaintiffs were the least senior employees in the Puerto Rico office when American let them go. Plaintiffs could be entitled to a mesada only if their seniority was computed in relation to America’s offices worldwide. The district court ruled in favor of American on the basis that the Puerto Rico Supreme Court has construed Article 3 to count only those transfers that occur in Puerto Rico and to count none that are made to or from an office outside of it. The First Circuit certified the proper interpretation of Article 3 to the Puerto Rico Supreme Court, concluding that the precedent relied upon by the district court was less definitive on the issue than the district court deemed it to be. View "Carrasquillo-Ortiz v. American Airlines, Inc." on Justia Law

Appellant, a social worker, worked for Appellee for several months. Appellant was fired for allegedly “creating disharmony in the workplace.” Appellant filed suit, alleging that Appellee illegally retaliated against her in violation of Maine’s Whistleblower Protection Act. Appellant’s theory was that Appellee terminated her for reporting what she considered to be violations of state employment law to her supervisor and, thereafter, to Maine’s Department of Health and Human Services. The district court granted Appellee’s motion for summary judgment, concluding that, thanks to the “job duties exception” carved out in Winslow v. Aroostook County, Appellant had not engaged in protected whistleblowing activity. The First Circuit vacated the district court’s grant of summary judgment after addressing a jurisdictional issue, holding that the district court misapplied the First Circuit’s holding in Winslow, and the court’s erroneous shortcutting of the Winslow analysis required a remand for the district court to re-analyze Appellant’s claims. View "Harrison v. Granite Bay Care, Inc." on Justia Law

Plaintiff’s late father was formerly employed as a mechanic by the City of Boston. Plaintiff brought this lawsuit on behalf of her father’s estate, alleging that the City and her father’s supervisors discriminated against her father on the basis of race and retaliated against him by terminating his employment. Plaintiff’s federal claims appeared to arise under 42 U.S.C. 1981 and 1983. The district court dismissed Plaintiff’s complaint, concluding that Plaintiff had not pled facts sufficient to support her section 1983 claim and had failed to timely exhaust the administrative prerequisites necessary to bring suit on her section 1981 claim. The First Circuit (1) affirmed the dismissal of the section 1983 claim, holding that this claim was properly dismissed pursuant to Fed. R. Civ. P. 12(b)(6); but (2) reversed the dismissal of the section 1981 claim, holding that the district court erred by imposing an administrative exhaustion requirement where none exists. View "Buntin v. City of Boston" on Justia Law

Defendant, a company that provides skycap services to airlines, was defending against a class action lawsuit when Plaintiff, one of the skycaps that Defendant had employed, brought an individual suit against Defendant, alleging unlawful termination. Specifically, Plaintiff alleged that Defendant fired him for his role in helping to organize the class action. A jury rendered a verdict in favor of Plaintiff, and the district court awarded damages and attorney’s fees and costs. Both parties appealed. The First Circuit (1) affirmed the verdict in favor of Plaintiff and the awarded of damages and attorney’s fees; (2) affirmed the district court’s decisions not to treble the emotional-distress damages award that the district court had ordered on remittitur and not to grant prejudgment interest on the emotional-distress damages; but (3) vacated the district court’s elimination of front-pay damages. Remanded. View "Travers v. Flight Services & Systems, Inc." on Justia Law

Plaintiffs, two former managers of Dunkin’ Donuts stores in Massachusetts, filed this action claiming that they were improperly denied overtime pay under the Fair Labor Standards Act (FLSA). The defendant employers moved for summary judgment. The magistrate judge recommended that the motion be denied, finding a genuine issue of material fact as to whether Plaintiffs were “bona fide executive[s]” excluded from the FLSA’s overtime pay requirement. The district rejected the recommendation of the magistrate judge and granted summary judgment for Defendants. The First Circuit reversed, holding that a reasonable fact-finder could conclude that Defendants failed to meet their burden of showing that Plaintiffs fell within the “bona fide executive” exception to the FLSA’s overtime pay requirement. View "Marzuq v. Cadete Enters., Inc." on Justia Law

Plaintiff was formerly employed by the Civilian Health Promotion Services Program at Hanscom Air Force Base in Bedford, Massachusetts. After the government contractor that employed Plaintiff terminated her employment, Plaintiff filed this lawsuit against the government contractor that employed her, her supervisor, and several government agencies and officials that Plaintiff believed were involved in her termination. Plaintiff asserted a claim under Bivens v. Six Unknown Named Agents of Federal Bureau of Narcotics for violation of her First Amendment rights and a claim of gender discrimination under Title VII. Plaintiff’s Bivens claims was dismissed, and summary judgment was granted against Plaintiff on her Title VII claim. The First Circuit affirmed, holding (1) Plaintiff’s Bivens claim failed to plausibly demonstrate her right to recover against any of the defendants it named, and therefore, its dismissal was proper; and (2) the entry of summary judgment against Plaintiff on her Title VII claim was proper. View "Casey v. Dep’t of Defense" on Justia Law

Plaintiff filed suit against officials at the University of Massachusetts at Dartmouth after the university had commenced termination proceedings against him, alleging, inter alia, claims under 42 U.S.C. 1983 for violations of his First and Fourteenth Amendment rights. Plaintiff then filed a second amended complaint along with an amended motion for preliminary injunction requesting that the termination proceedings be halted and Plaintiff be reinstated to his position. Defendants moved to dismiss the amended complaint. The district court granted in part and denied in part the motion to dismiss and sua sponte combined the motion for preliminary injunction with a trial on the merits. The university subsequently terminated Plaintiff. During the pendency of Plaintiff’s interlocutory appeal of the district court’s order combining the preliminary injunction hearing with the trial, the district court proceeded with the case. The First Circuit dismissed the appeal, holding that the Court had no jurisdiction over the underlying decision to consolidate the motion for preliminary injunction with trial. Therefore, the Court also lacked jurisdiction over the district court’s denials of Plaintiff’s motions to reconsider its order. View "Nwaubani v. Grossman" on Justia Law

In 2008, Employee was fired from his employment with Employer on the grounds that Employee failed to “meet job performance standards.” Employee subsequently sued Employer, claiming that Employer did not have cause to fire him. The district court dismissed the complaint for failure to state a claim. Defendant appealed the dismissal of his claim under section 301 of the Labor Management Relations Act (LMRA) for breach of a Collective Bargaining Agreement. The district court concluded that the only way Employee could bring his LMRA claim against Employer was by bringing a hybrid claim, one that alleged breach of contract by the Hospital as well as breach of the duty of fair representation by Employee’s union. The court concluded that because Employee did not bring a hybrid claim he was barred from bringing his LMRA claim. The court also concluded that even if Employee’s complaint could be construed as bringing a hybrid claim, the complaint was filed outside the six-month statute of limitations for hybrid claims. The First Circuit reversed, holding that Employee was not required to bring a hybrid claim, and therefore, the six-year statute of limitations for breach of contract claims applied. View "DeGrandis v. Children's Hospital Boston" on Justia Law