Justia Labor & Employment Law Opinion SummariesArticles Posted in 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
Gilbert v. City of Chicopee
The First Circuit affirmed the judgment of the district court dismissing Plaintiff’s claims under 42 U.S.C. 1983 and various state laws, holding that the district court properly dismissed Plaintiff’s claims under Fed. R. Civ. P. 12(b)(6). Plaintiff, a captain in the Chicopee Police Department, brought this action against the City, its police chief and mayor, a fellow police officer, and other defendants, alleging that his First Amendment rights were violated after Defendants improperly targeted him for “speaking out and participating in a government investigation.” The district court dismissed Plaintiff’s claimed under Rule 12(b)(6). The First Circuit affirmed, holding that the district court (1) properly dismissed Plaintiff’s First Amendment claim because al of Plaintiff’s speech was made within the scope of his official duties rather than as a citizen; and (2) did not err in dismissing the state law claims. View "Gilbert v. City of Chicopee" on Justia Law
Miceli v. JetBlue Airways Corp.
The First Circuit affirmed the decision of the district court granting summary judgment in favor of Employer on Plaintiff’s claims alleging handicap discrimination and retaliation under Massachusetts state law, holding that there was no probative evidence of discrimination or retaliation. While Employer maintained that Plaintiff was fired because she violated company policy on unexcused absences, Plaintiff argued in her claim that she was fired because of her disability and that Employer retaliated against her for filing a complaint with the Massachusetts Commission against Discrimination. The district court granted summary judgment in favor of Employer. The First Circuit affirmed, holding that neither of Plaintiff’s claims could survive summary judgment. View "Miceli v. JetBlue Airways Corp." on Justia Law
Roy v. Correct Care Solutions, LLC
The First Circuit reversed in part and affirmed in part the district court’s grant of summary judgment to all Defendants on Plaintiff’s claims of discrimination, unlawful retaliation, and violations of the Equal Protection Clause and the First Amendment, holding that summary judgment was properly granted as to Rodney Bouffard and Troy Ross but improperly granted as to Correct Care Solutions, LLC (CCS) and Maine Department of Corrections (MDOC). Plaintiff was employed by CCS at a MDOC prison. After MDOC revoked Plaintiff’s prison security clearance and CCS terminated Plaintiff’s employment, Plaintiff sued CCS, MDOC, and Bouffard, the warden, and Ross, the deputy warden, bringing claims under the Maine Human Rights Act (MHRA) and 42 U.S.C. 1983. The district court granted summary judgment for Defendants on all claims. The First Circuit held (1) a reasonable jury could find that Plaintiff’s work environment was hostile; (2) summary judgment was properly granted in favor of the warden and deputy warden based on qualified immunity; (3) an employer can be liable for a hostile work environment created by non-employees as long as the employer knew of the harassment and failed to take reasonable steps to address it; and (4) summary judgment was improper was to MDOC and CCS. View "Roy v. Correct Care Solutions, LLC" on Justia Law
Torres v. Bella Vista Hospital, Inc.
The First Circuit affirmed the judgment of the district court rejecting Plaintiffs’ motion to set aside an earlier federal district court decision granting summary judgment in favor of Defendants on Plaintiffs’ claims seeking to recover lost benefits from their former employer, holding that the district court properly found that the judgment was not procured by “fraud on the court.” Plaintiffs claimed in their motion that various defendants made deliberate material misstatements in their answers and various sworn statements. The district court determined that the allegations did not warrant vacating the judgment. The First Circuit affirmed, holding that, even assuming the truth of Plaintiffs’ allegations, the allegations were not sufficient to constitute “fraud upon the court.” View "Torres v. Bella Vista Hospital, Inc." on Justia Law
Rivera-Colon v. AT&T Mobility Puerto Rico, Inc.
The First Circuit affirmed the order of the district court finding that an arbitration agreement between the parties in this case was enforceable, granting AT&T Mobility Puerto Rico, Inc.’s (AT&T) motion to compel arbitration and dismissing Nereida Rivera-Colon’s (Rivera) suit, holding that Rivera manifested her intent to accept the agreement to arbitrate legal grievances as per Puerto Rico law. Rivera filed suit against AT&T, her former employer, alleging age discrimination and wrongful termination. AT&T entered a special appearance and moved to stay the proceedings and compel arbitration. In response, Rivera argued that there was no valid arbitration agreement. The district court held that the arbitration agreement was enforceable and granted the motion to compel arbitration. The First Circuit affirmed, holding that, under Puerto Rico law, Rivera was bound by the arbitration agreement because she failed to opt out of the agreement. View "Rivera-Colon v. AT&T Mobility Puerto Rico, Inc." on Justia Law
Guilfoile v. Shields
The First Circuit affirmed in part and vacated and remanded in part the district court’s dismissal of Appellant’s complaint claiming that he was fired from his job in retaliation for accusing his employer of violating the Anti-Kickback Statute (AKS) and making false representations in customer contracts, holding that Appellant plausibly pleaded that he engaged in protected conduct within the meaning of a False Claims Act (FCA) retaliation claim. The district court dismissed the complaint after finding that Appellant did not allege sufficient facts to show he was engaged in protected conduct within the meaning of the retaliation provision of the FCA. The First Circuit affirmed as to the contractual language claim but vacated and remanded as to the AKS claim, holding that Appellant plausibly pleaded that the concerns he raised about certain payments could have led to an FCA action. View "Guilfoile v. Shields" on Justia Law
Anderson v. Brennan
The First Circuit affirmed the judgment of the district court concluding that Plaintiff was not discriminated against but that Defendant’s decision to terminate her employment, rather than impose lesser discipline, was in retaliation for protected conduct, holding that the district court’s rulings were not erroneous or an abuse of discretion. In her complaint, Plaintiff, a former employee of the U.S. Postal Service, argued that her termination was unlawfully discriminatory due to her race and national origin and, independently, was in retaliation for her having filed earlier complaints. Defendant appealed the ruling that Defendant’s termination was in retaliation for protected conduct, and Plaintiff appealed the remedy awarded - back pay but not reinstatement or front pay. The First Circuit affirmed, holding that there was no error in the district court’s judgments. View "Anderson v. Brennan" on Justia Law
Thomas v. Town of Salisbury
The First Circuit affirmed the decision of the district court granting summary judgment in favor of Defendants on Plaintiff’s claim that Defendants conspired against him and violated the Massachusetts Civil Rights Act (MCRA), Mass. Gen. Laws ch. 12, 11H, 11I by depriving him of his protected property right of continued employment with the Salisbury Police Department (SPD), holding that summary judgment was properly granted. In 2010, Cornelius Harrington, the Salisbury town manager, hired Robert St. Pierre to investigate allegations of misconduct by the then-police chief. During the investigation, St. Pierre uncovered evidence of alleged wrongdoing by Plaintiff, an officer at the SPD. After a follow-up investigation, Harrington terminated Plaintiff from his employment. An arbitrator later reversed that decision. Plaintiff retired soon after and filed this lawsuit against Harrington and St. Pierre. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding that summary judgment was proper where Plaintiff offered little evidence beyond bald speculation for the existence of a conspiracy and failed to show that his constitutional rights ere interfered with by “threats, intimidation, or coercion,” as required by the MCRA. View "Thomas v. Town of Salisbury" on Justia Law
Mancini v. City of Providence
The First Circuit affirmed the decision of the district court granting summary judgment to the City of Providence, Rhode Island (the City) as to Plaintiff’s complaint for discrimination under the Americans with Disabilities Act (ADA), 42 U.S.C. 12101-12213, and related state anti-discrimination laws, holding that the district court properly entered summary judgment on Plaintiff’s claims. Following an injury that he sustained while on duty, Plaintiff, a veteran police officer in the City, sued the City for discrimination. The district court granted summary judgment in favor of the City on all claims, concluding that Plaintiff had failed to establish that he was disabled within the meaning of the ADA and failed to show a cognizable disability as to his state-law claims. Although its reasoning differed from that of the district court, the First Circuit affirmed, holding that summary judgment was properly entered on Plaintiff’s claims. View "Mancini v. City of Providence" on Justia Law