Abril-Rivera v. Johnson, No. 14-1316 (1st Cir. 2015)
Annotate this CasePlaintiffs were employees of Puerto Rico National Processing Service Center (PR-NPSC), 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 and in eventually closing the facility discriminated against them on the basis of national origin and constituted unlawful 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 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.
This opinion or order relates to an opinion or order originally issued on July 30, 2015.
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