Tuesday, April 1, 2014
- First Circuit: The court reversed dismissal of Title VII and state law complaint because dismissal “was based on at least three errors of law: (1) use of the prima facie case, an evidentiary standard, as a pleading requirement; (2) dismissal of plaintiff’s retaliation claim based solely on its incorrect temporal analysis of causation at the motion-to-dismiss stage; and (3) sua sponte dismissal of certain claims without any notice to the parties”
- Fourth Circuit: The court affirmed district court’s finding that employee retirement benefit plan violated the ADEA because it required that older employees pay a greater percentage of their salaries based on their ages at the time they enrolled in the plan
- Fifth Circuit: While reversing summary judgment for employer on Title VII retaliation claim, the court held that plaintiff would need to establish a prima-facie case on remand despite the fact that employer proffered a non-discriminatory reason for its decision, noting a Circuit split on the issue when it arises prior to judgment
- Eighth Circuit: In reversing dismissal of atheist inmate’s Section 1983 complaint, the court held that the complaint pled facts sufficient to state a claim that a parole stipulation requiring inmate to attend and complete a substance abuse program with religious content in order to be eligible for early parole violates the Establishment Clause of the First Amendment
- US District Court ME: In denying defendant’s motion for summary judgment on plaintiff’s ADA, FMLA, and MHRA claims, the court held that plaintiff’s alcoholism and depression were protected disabilities despite the argument that they were minor, defendant knew about them despite manager claiming he did not, plaintiff showed that non-disabled employees were treated more favorably than him even though their situations were not exactly the same as his, and a one-week span between plaintiff returning from his second disability-related leave and his termination was a sufficient causal link to establish retaliation
- US District Court ME: Magistrate Judge reversed and remanded denial of Type II SSA benefits because Administrative Law Judge impermissibly translated raw medical records into a residual functional capacity finding without an expert opinion
