Justia Labor & Employment Law Opinion Summaries

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

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