DeGrandis v. Children's Hospital Boston, No. 15-1657 (1st Cir. 2015)
Annotate this CaseIn 2008, Employee was fired from his employment with Employer on the grounds that Employee failed to “meet job performance standards.” Employee subsequently sued Employer, claiming that Employer did not have cause to fire him. The district court dismissed the complaint for failure to state a claim. Defendant appealed the dismissal of his claim under section 301 of the Labor Management Relations Act (LMRA) for breach of a Collective Bargaining Agreement. The district court concluded that the only way Employee could bring his LMRA claim against Employer was by bringing a hybrid claim, one that alleged breach of contract by the Hospital as well as breach of the duty of fair representation by Employee’s union. The court concluded that because Employee did not bring a hybrid claim he was barred from bringing his LMRA claim. The court also concluded that even if Employee’s complaint could be construed as bringing a hybrid claim, the complaint was filed outside the six-month statute of limitations for hybrid claims. The First Circuit reversed, holding that Employee was not required to bring a hybrid claim, and therefore, the six-year statute of limitations for breach of contract claims applied.
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