Reyes-Caparros v. Garland, No. 20-1792 (1st Cir. 2022)
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The First Circuit affirmed the judgment of the district court rejecting the jury's advisory verdict in this case, holding that Plaintiff was not entitled to relief on his claims of error.
Plaintiff, a former intelligence specialist, sued his former employer, the United States Attorney's Office for the District of Puerto Rico pursuant to Title VII of the Civil Rights Act, alleging discriminatory retaliation and constructive discharge resulting from a hostile work environment. After a jury returned a verdict on liability for retaliation and awarding the statutory maximum in damages, the district court charged the jury to return an advisory verdict on the issue of damages for constructive discharge. The jury returned a verdict in favor of Plaintiff as to that issue, and thereafter, Plaintiff sought a judgment of front and back pay. The district court rejected the jury's advisory verdict, concluding that the verdict was not supported by the evidence, that Plaintiff was not constructively discharged, and that Plaintiff was not entitled to front or back pay. The First Circuit affirmed, holding (1) Plaintiff waived his objection to the district court's decision to submit the constructive discharge issue to an advisory jury; and (2) the district court's factual findings were not clearly erroneous.
The court issued a subsequent related opinion or order on April 8, 2022.
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