Justia Civil Rights Opinion Summaries

Plaintiff, an attorney, filed a lawsuit against the Narragansett Indian Tribe alleging breach of contract. Plaintiff alleged that the Tribe contractually waived the sovereign immunity that would otherwise have prevented him from bringing this suit outside the tribal courts. The district court denied the Tribe’s motion to dismiss the case on sovereign immunity grounds. The Tribe did not appeal the denial of the motion to dismiss. Instead, the Tribe filed an untimely Fed. R. Civ. P. 59(e) motion for reconsideration. The district court denied the Rule 59(e) motion. The Tribe subsequently filed a notice purporting to appeal from both the denial of the motion to dismiss and the denial of the untimely Rule 59(e) motion. A prior duty panel of the First Circuit dismissed as untimely any appeal from the denial of the motion to dismiss. The First Circuit subsequently denied interlocutory review of the order denying its motion to reconsider, holding that it lacked jurisdiction to entertain such an appeal because the denial of the Tribe’s untimely 59(e) motion did not qualify as a collateral order that the Court may review prior to the end of the litigation in the district court. View "Luckerman v. Narragansett Indian Tribe" on Justia Law

Plaintiff, a physician, filed an employment discrimination action against the California Emergency Physicians Medical Group (CEP) in state court. CEP removed the suit to federal court. Prior to trial, the parties agreed in writing to settle the case. The settlement agreement included a provision that Plaintiff waive his rights to employment with CEP or at any facility that CEP may own or with which it may contract in the future. Plaintiff refused to execute the written agreement and attempted to have it set aside. The district court ultimately ordered that the settlement be enforced and dismissed the case, concluding that Cal. Bus. & Prof. Code 16600, which provides that a contract is void if it restrains anyone from engaging in a lawful profession, did not apply because the no-employment provision in the settlement agreement did not constitute a covenant not to compete. A panel of the Ninth Circuit reversed, holding (1) the parties’ dispute regarding whether the no-employment provision voided the settlement agreement was ripe for review under the traditional ripeness standard; and (2) the district court abused its discretion by categorically excluding the settlement agreement from the ambit of 16600 solely on the ground that it did not constitute a covenant not to compete. Remanded. View "Golden v. Cal. Emergency Physicians Med. Group" on Justia Law

In 2011, the Town of Middletown issued an invitation for bids on a drainage improvement project. Two contractors submitted bids, including HK&S Construction Holding Corp., which provided the lowest bid. Woodard & Curran, Inc. recommended against awarding HK&S the project and in favor of negotiating a contract with the second bidder. The town counsel concluded that HK&S’s bid was non-responsive and awarded the contract to the second bidder. Plaintiff filed a complaint against the Town and Woodard & Curran alleging, among other claims, that the Town violated state and local law when it denied the contract award for the project. The superior court granted summary judgment for Defendants. The Supreme Court affirmed, holding (1) there was no error in disposing of HK&S’s claims against the Town in summary judgment where HK&S failed to submit a responsive bid; and (2) HK&S’s claim of negligence against Woodard & Curran also failed. View "HK&S Constr. Holding Corp. v. Dible" on Justia Law

Plaintiff was a life insurance agent with the New Life Insurance Company for more than forty years. In 2009, Plaintiff was informed that his agent contract would be terminated. In 2012 and 2014, Plaintiff filed two separate suits against New York Life, alleging, in addition to several common-law claims, age discrimination under both Massachusetts law and the federal Age Discrimination in Employment Act. The U.S. District Court of the District of Massachusetts consolidated the two cases. The district court then granted summary judgment for New York Life on all claims. The First Circuit affirmed, holding (1) Plaintiff’s state law age discrimination claims were time barred; (2) no reasonable jury could conclude that New York Life engaged in age discrimination under federal law in terminating his agent contract; and (3) no reasonable jury could conclude that the termination breached Plaintiff’s contract with New York Life or violated any of Plaintiff’s common law rights. View "Santangelo v. New York Life Ins. Co." on Justia Law

The Professional Massage Training Center (PMTC) filed suit against the Accreditation Alliance of Career Schools and Colleges (ACCSC) after ACCSC denied PMTC’s application for re-accreditation. The district court entered judgment in favor of PMTC, finding that ACCSC had violated the school’s due process rights. The court awarded the school more than $400,000 in damages and ordered ACCSC to fully reinstate its accreditation. The Supreme Court reversed in part and affirmed in part, holding (1) the district court erred in conducting a de novo approach to the accreditation process; (2) judged by the correct standard of review, the accreditation decision was well supported and not arbitrary or capricious; and (3) the district court correctly dismissed PMTC’s state law claims for breach of contract, negligence, and tortious interference. Remanded. View "Prof’l Massage Training v. Accreditation Alliance of Career Schs." on Justia Law

In 1999, Allstate reorganized its business and terminated the at-will employment contracts of about 6,200 sales agents, offering them conversion to independent contractor status; $5,000 and an economic interest in their accounts, to be sold to buyers approved by Allstate; severance pay equal to one year’s salary; or severance pay of 13 weeks’ pay. Employees who chose independent contractor status received a bonus of at least $5,000, were not required to repay any office-expense advances, and acquired transferable interests in their business two years after converting. All employees who chose not to convert and left the company were bound by noncompetition covenants in their original contracts. As a condition of becoming independent contractors, agents were required to sign a release waiving existing legal claims against Allstate. The Equal Employment Opportunity Commission sued, claiming that the company violated federal anti-retaliation laws. The district court reversed. The Third Circuit affirmed, noting the settled rule that employers can exchange consideration for releases of claims and that EEOC established neither protected activity nor an adverse action. View "Equal Emp't Opportunity Comm'n v. Allstate Ins. Co" on Justia Law

Rosana Claudio-de Leon (Claudio) and the University of the East of the Ana G. Mendez University System (SUAGM) entered into an employment contract that contained a forum selection clause precluding adjudication in federal court. Claudio, Luis F. Carrasquillo-Rivera, and the conjugal partnership Carrasquillo-Claudio (collectively, Appellants) filed suit against SUAGM in the district court, alleging, among other claims, pregnancy and gender discrimination. The district court dismissed Appellants’ Title VII pregnancy and gender discrimination claim and supplemental state law claims due to the forum selection clause. The First Circuit affirmed as modified, holding (1) the forum selection clause was applicable and enforceable; but (2) the district court should have dismissed the case without prejudice to permit Appellants to refile in the appropriate forum. Remanded.View "Claudio de-Leon v. Ayala" on Justia Law

This case stemmed from the district court’s approval of the Utah Department of Financial Institutions’ (UDFI) seizure of America West Bank Members, L.C. (Bank) and the appointment of the Federal Deposit Insurance Corporation as receiver of the Bank. The Bank filed a complaint against the State, UDFI, and the director of UDFI (collectively, the State), alleging breach of contract, breach of the covenant of good faith and fair dealing, constitutional takings, and due process violations. The district court dismissed the Bank’s claims for lack of sufficient factual allegations under Utah R. Civ. P. 12(b)(6). The Supreme Court affirmed, holding (1) the district court did not err when it dismissed the Bank’s claims; and (2) the district court did not hold the Bank to a heightened pleading standard.View "America West Bank Members, L.C. v. State" on Justia Law

Plaintiff appealed the district court's grant of summary judgment in favor of his former employers, BoA, on his claim of age discrimination under the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. 621 et seq., and breach of contract. Under the McDonald Douglas Corp v. Green framework, assuming arguendo that plaintiff met his burden of demonstrating a prima facie case of age discrimination, the court agreed with the district court that BoA has satisfied its burden to articulate a legitimate, nondiscriminatory reason for plaintiff's termination. BoA has explained that plaintiff's employment was terminated as part of a company-wide reduction in force; two months prior to his termination, plaintiff received a negative mid-year performance review; and as of September 2010, plaintiff was ranked 136th across all BoA sales personnel for the year and his performance was the worse of all employees in his group. In regards to the breach of contract claim, the district court correctly determined that plaintiff was an at-will employee and that although annual bonuses were discretionary, there is no record evidence, or even an allegation, indicating that plaintiff was promised a mid-year bonus. Accordingly, the court affirmed the judgment of the district court. View "Delaney v. Bank of America Corp." on Justia Law

Jeffrey Healey and Edward Given, residents of the Massachusetts Treatment Center, were each civilly committed as a sexually dangerous person. Plaintiffs brought separate suits, which were later consolidated, challenging the conditions of their confinement and the adequacy of their sexual offender treatment. Plaintiffs sought equitable relief against the Massachusetts Department of Corrections and other state officials (collectively, the DOC). Both plaintiffs alleged violations of the Constitution and state statutory provisions, and Healey alleged that the DOC was not in compliance with the terms of a management plan (Plan) for the Center developed by the DOC during the course of prior litigation. The district court granted Plaintiffs declaratory and injunctive relief on some claims and entered judgment in favor of the DOC on the remaining claims. The First Circuit (1) reversed the declaratory judgment in favor of Healey on his contempt claim as well as injunctive relief compelling the Commonwealth’s compliance with the Plan’s provisions; and (2) affirmed the district court’s judgment in favor of Defendants in all respects with the exception of the judgment for Plaintiffs regarding the constitutionality of the pharmacological evaluation and treatment provided by Defendants, as that portion of the judgment was not challenged on appeal. View "Healey v. Dennehy" on Justia Law