Justia Labor & Employment Law Opinion SummariesArticles Posted in US Court of Appeals for the First Circuit
Rios-Campbell v. U.S. Department of Commerce
The First Circuit vacated the judgment of the district court granting Defendants' motion for summary judgment after treating the motion as a motion to dismiss pursuant too Fed. R. Civ. P. 12(b)(6), holding that the district court applied the wrong legal standard in adjudicating Defendants' summary judgment motion. Plaintiff brought this action alleging that his employer had discriminated against him on the basis of his national origin and subjected him to retaliation. Defendants moved for summary judgment. The district court considered the motion as a motion to dismiss for failure to state a plausible claim and granted the motion. The First Circuit reversed, holding that the district court's attempt to transform Defendants' fully developed motion for summary judgment into a motion to dismiss was an abuse of discretion. View "Rios-Campbell v. U.S. Department of Commerce" on Justia Law
Posted in: Civil Procedure, Civil Rights, Labor & Employment Law, US Court of Appeals for the First Circuit
Merlini v. Canada
The First Circuit reversed the order of the district court dismissing Plaintiff's complaint against Canada for lack of jurisdiction after concluding that Canada was immune from the suit under the Foreign Sovereign Immunities Act (FSIA), 28 U.S.C. 1602 et seq., holding that the FSIA did not prohibit Plaintiff's suit. Plaintiff, who was injured in the course of her employment at the Canadian consulate in Boston, Massachusetts, sued Canada for damages in the United States District Court for the District of Massachusetts pursuant to the Massachusetts Workers' Compensation Act, Mass. Gen. Laws chapter 152. The district court dismissed the complaint for lack of jurisdiction. The First Circuit reversed, holding that Plaintiff's claim was not barred by FSIA. View "Merlini v. Canada" on Justia Law
Luceus v. State
The First Circuit affirmed the district court's grant of summary judgment to Defendants, the Rhode Island Department of Labor and Training and the State, on Plaintiff's complaint alleging discrimination in violation of Title VII of the Civil Rights Act, 42 U.S.C. 2000e-2, holding that summary judgment was properly granted. In his complaint, Plaintiff claimed that the Department's promotion practices had a disparate impact on minority employees and that the Department declined to promote her because she is black. The district court granted summary judgment in favor of Defendants. The First Circuit affirmed, holding (1) because Plaintiff could not show a disparate impact in the absence of statistical and statistically significant evidence, the district court correctly granted summary judgment to Defendants on Plaintiff's claim of disparate impact; and (2) Plaintiff failed to present enough evidence for a reasonable jury to conclude that Defendants' stated reason for failing to promote her was pretextual. View "Luceus v. State" on Justia Law
Pena v. Honeywell International, Inc.
The First Circuit affirmed the district court's grant of summary judgment in favor of Employer on this action brought by Employee under the Americans with Disabilities Act (ADA), 42 U.S.C. 1210 et seq., and under various Rhode Island laws, holding that the district court properly granted summary judgment on all of Employee's claims. After Employer terminated Employee's employment on the basis of job abandonment Plaintiff filed this suit claiming that Employer terminated her on the basis of her disabilities, failed to provide her with reasonable accommodations, and retaliated against her. The district court granted Employer's motion for summary judgment, concluding that Employee had not met the requirements of Cleveland v. Policy Management Systems Corp., 526 U.S. 795 (1999). The First Circuit affirmed, holding that the district court properly granted Employer summary judgment as to all of Plaintiff's claims. View "Pena v. Honeywell International, Inc." on Justia Law
Ramos-Santiago v. WHM Carib LLC
The First Circuit affirmed the district court's partial entry of summary judgment in favor of Defendants on Plaintiff's age discrimination claim and his family's derivative tort claims and the denial of Plaintiff's motion for summary judgment, holding that the district court's summary judgment rulings were proper. Plaintiff and five of his family member brought this action under Puerto Rico law against Plaintiff's former employer and its insurance carrier alleging unjust dismissal and age discrimination in employment, his family asserting derivative tort claims arising from the alleged age discrimination. The district court granted summary judgment for Defendants on all but the unjust dismissal claim and denied Plaintiff's cross-motion for summary judgment. The First Circuit affirmed, holding that, under the facts of this case, summary judgment was properly granted. View "Ramos-Santiago v. WHM Carib LLC" on Justia Law
Hoffman-Garcia v. Metrohealth, Inc.
The First Circuit affirmed the judgment of the district court granting judgment as a matter of law to Defendant-employer on Plaintiff’s age discrimination claims and Puerto Rico law claims and granting in part Defendant’s summary judgment motion, holding that there was no error in the proceedings below. After Plaintiff was laid off as part of Defendant’s effort to cut costs, Plaintiff sued the hospital under the Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621-634 and Puerto Rico antidiscrimination and tort law. The district court granted summary judgment in part for Defendant, finding that Defendant had facially legitimate, non-discriminatory grounds to terminate Plaintiff’s position. A jury trial ensued, but at the close of evidence the district court granted Defendant’s motion for judgment as a matter of law. The First Circuit affirmed, holding that there were fatal and uncontradicted defects in Defendant’s prima facie theory of liability as established by the evidence at trial. View "Hoffman-Garcia v. Metrohealth, Inc." on Justia Law
Villeneuve v. Avon Products, Inc.
The First Circuit affirmed the orders of the district court judge’s rulings dismissing Plaintiff’s sexual orientation discrimination claim and granting summary judgment for Defendant on Plaintiff’s unjust discharge and age discrimination claims and awarded Defendant its costs on this appeal, holding that the judge committed no reversible error. In this diversity case governed by Puerto Rico law, the district court judge dismissed Plaintiff’s claims against her former employer on Defendant’s motions to dismiss and for summary judgment. The First Circuit affirmed, holding (1) the judge properly dismissed Plaintiff’s sexual orientation discrimination claim because Plaintiff did not plausibly plead that her firing constituted sexual orientation discrimination; and (2) the judge properly granted summary judgment for Defendant on Plaintiff’s unjust discharge and age discrimination claims. View "Villeneuve v. Avon Products, Inc." on Justia Law
Bekele v. Lyft, Inc.
The First Circuit affirmed the decision of the district court granting Defendant’s motion to dismiss this putative class action in favor of arbitration of Plaintiff’s claim in his individual capacity after concluding that the parties had a valid and enforceable agreement to arbitrate, holding that the arbitration clause was enforceable because it was conscionable under Massachusetts law. Plaintiff drove for Lyft, Inc., the defendant. Plaintiff tapped “I accept” on his iPhone when presented with Lyft’s terms of service agreement, which contained a provision requiring that disputes between the parties be resolved by arbitration. In this putative class action Plaintiff alleged that Lyft misclassified its Massachusetts drivers as independent contractors under the Massachusetts Wage Act. Left removed the case to federal court and moved to dismiss in favor of individual arbitration. The district court granted the motion. The First Circuit affirmed, holding (1) Plaintiff waived his contract-formation argument; and (2) the arbitration clause was not substantively unconscionable and was thus enforceable. View "Bekele v. Lyft, Inc." on Justia Law
Posted in: Arbitration & Mediation, Contracts, Labor & Employment Law, US Court of Appeals for the First Circuit
Garcia v. Director, Office of Workers’ Compensation Programs, United States Department of Labor
The First Circuit denied Petitioner’s petition for review of the decision of the U.S. Department of Labor Benefits Review Board (Board) affirming an administrative law judge’s (ALJ) denial of attorney’s fees and costs to Appellant, holding that Appellant's request for benefits did not result in a “successful prosecution” under the Longshore and Harbor Workers’ Compensation Act (LHWCA), 33 U.S.C. 901 et seq., so as to warrant an award of attorney’s fees. At a hearing before the ALJ it was undisputed that Appellant was entitled to medical benefits due to his back injury, including for surgery in Puerto Rico. The ALJ stated that Appellant could have the surgery done in New York but would have been responsible for the additional expenses he incurred. Appellant then submitted a request for attorney’s fees on the theory that his claim had been a victory because he obtained his “right to choose” to have the surgery in New York. The ALJ denied the request, determining that Appellant did not gain any additional benefit beyond what he would have received had he not initiated the claim. The Board affirmed. The First Circuit affirmed, holding that Appellant’s request for attorney’s fees and costs was properly denied because he did not secure any additional compensation by filing his claim. View "Garcia v. Director, Office of Workers’ Compensation Programs, United States Department of Labor" on Justia Law
Posted in: Government & Administrative Law, Labor & Employment Law, US Court of Appeals for the First Circuit
Heagney v. Wong
The First Circuit affirmed in part and reversed in part the decision of the district court entering judgment for Plaintiff on Mass. Gen. Laws ch. 151B and defamation claims against the City of Fitchburg and its mayor and the award of punitive damages, holding that the award of punitive damages was improper and that the district court erred in entering judgment for Plaintiff on the defamation claim. Plaintiff brought this action against the City and its mayor after the mayor decided not to nominate Plaintiff for the position of the City police chief. Plaintiff alleged that the City violated his rights under Chapter 151B by deciding not to hire him because of his failure to disclose a criminal case against him of which he was later acquitted and that the mayor defamed him through statements she made to the media. A jury found for Plaintiff on both claims and awarded punitive damages. The First Circuit held (1) the district court erred in denying Plaintiff’s motion for judgment as a matter of law and for a new trial on Plaintiff’s defamation claim because the statement at issue was not false; (2) the evidence was sufficient with respect to the Chapter 151B claim; and (3) there was insufficient evidence to support the punitive damages award. View "Heagney v. Wong" on Justia Law