Abril-Rivera v. Johnson, No. 14-1316 (1st Cir. 2015)
Annotate this CasePlaintiffs were employees of Puerto Rico National Processing Service Center (PR-NPSC), which is now closed, run by the Federal Emergency Management Agency (FEMA). Plaintiffs filed this lawsuit alleging that FEMA’s actions in implementing a rotational staffing plan at the PR-NPSC, which reduced the number of work days for each employee, and in eventually closing the facility discriminated against them on the basis of national origin and retaliation in violation of Title VII. The district court granted summary judgment to Defendants. The First Circuit affirmed, holding (1) Plaintiffs’ disparate impact claims failed because (i) Plaintiffs expressly disavowed any claim of intentional discrimination, and under relevant caselaw, claims of different treatment based on location absent a claim of intentional discrimination do not establish liability under 42 U.S.C. 2000e-2(h), and (ii) the challenged actions were job-related and consistent with business necessity, and Plaintiffs failed to show that there were alternatives available to FEMA that would have had less disparate impact and served FEMA’s legitimate needs; and (2) both retaliation claims failed because Plaintiffs did not show that the allegedly adverse employment actions were causally related to any protected conduct.
The court issued a subsequent related opinion or order on November 17, 2015.
The court issued a subsequent related opinion or order on November 17, 2015.
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