Justia Labor & Employment Law Opinion Summaries

The First Circuit reversed the order of the district court denying Defendant's motion for summary judgment as to Plaintiff's whistleblower retaliation claim brought under section 1514A of the Sarbanes-Oxley Act, holding that Plaintiff could not satisfy his burden of bringing a claim for whistleblower retaliation under section 18 U.S.C. 1514A.Plaintiff, a former employee of Defendant, sued Defendant for whistleblower retaliation under section 1514A, but his particular whistleblower claim was based on an alleged violation of 15 U.S.C. 78m(b)(2), (5). Defendant moved for summary judgment following the completion of discovery, arguing that Plaintiff's action did not fall within any of the definitions of protected activity under section 1514A. The district court denied the motion as to the whistleblower retaliation claim. The First Circuit reversed and remanded with instructions to enter summary judgment in favor of Defendant, holding that Plaintiff's conduct was not "protected activity" under section 1514A. View "Baker v. Smith & Wesson, Inc." on Justia Law

The First Circuit reversed the judgment of the district court denying arbitration requested by two unions - the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union and the United Steelworkers Local 12203 (collectively, Union) - on behalf of former two employees of the Boston Gas Company (Company) as to their claims for pension benefits, holding that this matter called for arbitration.The Union represented the two members in filing grievances regarding their underpaid pensions. The Union submitted the grievances to the Joint Pension Committee, which was unable to resolve the dispute. The Union subsequently sought arbitration over the grievances, but the Company refused to arbitrate. The First Circuit reversed, holding that it was up to an arbitrator, not a court, to determine the matters at issue in this case. View "United Steelworkers v. National Grid" on Justia Law

The First Circuit affirmed the district court's judgment dismissing Plaintiffs' lawsuit asserting race-based discrimination and retaliation in violation of Title VII of the Civil Rights Act, holding that the district court did not err in dismissing the suit for failure to state a claim.Plaintiffs represented a putative class of employees employed by Whole Foods and Amazon who were disciplined for wearing face masks with the message "Black Lives Matter." In their lawsuit, Plaintiffs alleged that the manner in which their employers enforced a previously unenforced dress code policy constituted race-based discrimination and retaliation in violation of Title VII of the Civil Rights Act of 1964. The district court dismissed all claims. The First Circuit affirmed, holding that Plaintiffs did not adequately plead claims for racial discrimination and retaliation under Title VII. View "Frith v. Whole Foods Market, Inc." on Justia Law

The First Circuit affirmed the entry of final judgment entered in favor of Defendant on Plaintiff's wage and employment misclassification claims, holding that the Massachusetts Wage Act, Mass. Gen. Laws ch. 149, 148 (MWA), did not apply to the undisputed facts in this case.Plaintiff, a Florida-based financial planner with a Massachusetts-based financial services company and office, sued his former broker-dealer in a Massachusetts federal district court alleging that Defendant had misclassified him as an independent contractor instead of an employee in violation of Massachusetts law. The district court concluded that Defendants were entitled to judgment as a matter of law and granted Defendants' motion in its entirety. The First Circuit affirmed, holding that the district court correctly concluded that the MWA did not apply to Plaintiff's employment relationship with Defendant. View "Viscito v. National Planning Corp." on Justia Law

The First Circuit affirmed the decision of the district court denying motion for a preliminary injunction sought by Appellants, then-employees of Mass General Brigham, Inc. (MGB), to stop their employer's application of its mandatory COVID-19 vaccination policy to them, holding that the district court did not err.In November 2021, Appellants bought this action. The district court denied a preliminary injunction. Appellants then noticed an appeal and also sought emergency injunctive relief from the First Circuit. The First Circuit held that they had not met the requirements for an injunction pending appeal. Now that the merits of Appellants' appeal were before the Court, the First Circuit affirmed the denial of a preliminary injunction, holding that the district court correctly denied relief. View "Together Employees v. Mass General Brigham Inc." on Justia Law

The First Circuit reversed the judgment of the district court entering summary judgment against a group of jockeys who demanded higher wages and refused to rice and vacated the orders permanently enjoining the work stoppage and imposing $1,190,685 in damages, holding that the district court erred in granting Plaintiffs an injunction and summary judgment.Plaintiffs, an association of horse owners and the owner of a racetrack, brought this action against the jockeys and their spouses who refused to race, alleging that Defendants engaged in a group boycott in violation of federal antitrust law. The district court granted an injunction, concluding (1) the jockeys were independent contractors and had acted in concert to restrain trade, and (2) the jockeys could not benefit from the labor-dispute exemption because of their independent contractor status. The First Circuit reversed, holding (1) the labor-dispute exemption applied in this case; and (2) therefore, the district court erred in granting Plaintiffs and injunction and summary judgment. View "Confederacion Hipica de Puerto Rico v. Confederacion de Jinetes Puertorriqueños, Inc." on Justia Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Defendant, his former employer, and dismissing Plaintiff's complaint alleging that Defendant terminated his employment because of his age and because he received a liver transplant, holding that the district court did not err.Plaintiff filed a complaint alleging disability discrimination under the Americans With Disabilities Act (ADA) and age discrimination under the Age Discrimination in Employment Act (ADEA). The district court granted summary judgment for Defendant and dismissed the complaint. The First Circuit affirmed, holding that the evidence on the record did not support either Plaintiff's ADA claim or his ADEA claim. View "Lahens v. AT&T Mobility Puerto Rico, Inc." on Justia Law

The First Circuit affirmed in part and reversed in part the district court's grant of summary judgment in favor of Defendant on Plaintiff's federal and Massachusetts state law employment discrimination claims, holding that that court erred in granting summary judgment as to several of Plaintiff's claims.Plaintiff, a former employee of Defendant, an online home furnishings company with a principal place of business in Massachusetts, sued Defendant bringing claims under both Title VII of the Civil Rights Act, 42 U.S.C. 2000e et seq., and Mass. Gen. Laws ch. 151B, 4.1, 4.4, and 4.4A. The district court granted summary judgment for Defendant on all claims. The First Circuit reversed in part, holding that the district court (1) correctly granted summary judgment to Defendant on Plaintiff's state and federal claims for failing to remedy sexual harassment; and (2) erred in granting summary judgment to Defendant on Plaintiff's remaining claims. View "Forsythe v. Wayfair, LLC" on Justia Law

The First Circuit affirmed the judgment of the district court granting summary judgment ruling in favor of Defendant, a marketing company, holding that district court correctly concluded that Plaintiffs, who worked as "brand representatives" for Defendant, qualified as outside salespeople under governing law.Plaintiffs sued Defendant on behalf of themselves and other brand representatives, seeking to recover unpaid overtime wages under the Fair Labor Standards Act (FLSA) and analogous state wage laws, alleging that they failed to receiver overtime wages for working over forty hours per week. The district court granted summary judgment in favor of Defendant, concluding that Plaintiffs fell within the FLSA's outside sales exemption and thus were not entitled to overtime compensation. The First Circuit affirmed, holding that Plaintiffs fell within the outside sales exemption, 29 U.S.C. 213(a)(1). View "Modeski v. Summit Retail Solutions, Inc." on Justia Law

The First Circuit affirmed the judgment of the district court rejecting the jury's advisory verdict in this case, holding that Plaintiff was not entitled to relief on his claims of error.Plaintiff, a former intelligence specialist, sued his former employer, the United States Attorney's Office for the District of Puerto Rico pursuant to Title VII of the Civil Rights Act, alleging discriminatory retaliation and constructive discharge resulting from a hostile work environment. After a jury returned a verdict on liability for retaliation and awarding the statutory maximum in damages, the district court charged the jury to return an advisory verdict on the issue of damages for constructive discharge. The jury returned a verdict in favor of Plaintiff as to that issue, and thereafter, Plaintiff sought a judgment of front and back pay. The district court rejected the jury's advisory verdict, concluding that the verdict was not supported by the evidence, that Plaintiff was not constructively discharged, and that Plaintiff was not entitled to front or back pay. The First Circuit affirmed, holding (1) Plaintiff waived his objection to the district court's decision to submit the constructive discharge issue to an advisory jury; and (2) the district court's factual findings were not clearly erroneous. View "Reyes-Caparros v. Garland" on Justia Law