Henderson v. Massachusetts Bay Transportation Authority, No. 19-1720 (1st Cir. 2020)
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The First Circuit affirmed the district court's grant of summary judgment on Plaintiff's racial discrimination and retaliation claims against the Massachusetts Bay Transportation Authority (MBTA), holding that both challenges were meritless.
Plaintiff brought claims of racial discrimination, unlawful retaliation, and negligent infliction of emotional distress against the MBTA. The district court granted summary judgment to the MBTA on all claims. The First Circuit affirmed, holding (1) Plaintiff did not produce sufficient evidence to get to a jury on his claim that he was denied a promotion based on his race; and (2) Plaintiff did not establish a prima facie case of retaliation.
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