Lawless v. Steward Health Care System, LLC, No. 17-2128 (1st Cir. 2018)Annotate this Case
In this case brought pursuant to the Massachusetts Wage Act, the First Circuit affirmed the judgment of the district court granting summary judgment in favor of Plaintiff.
Plaintiff brought an action against Defendant, which owned and operated the hospital at which Plaintiff worked, under the Massachusetts Wage Act. Plaintiff alleged that, at the time she was discharged, she was owed thousands of dollars in paid time off and extended sick leave. Defendant removed the case to the federal court on the basis of Labor Management Relations Act (LMRA), 29 U.S.C. 185(a), preemption. The district court granted summary judgment for Plaintiff, awarding her damages and reasonable attorneys’ fees and costs. The First Circuit affirmed, holding (1) federal subject-matter jurisdiction existed at the time of removal because there was then a colorable claim of complete preemption under LRMA, and even after that colorable federal question evaporated during pretrial discovery, the district court retained authority to exercise supplemental jurisdiction over the case; and (2) the district court properly found that Plaintiff was entitled to summary judgment.