Geoffroy v. Town of Winchendon, No. 19-1573 (1st Cir. 2020)
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The First Circuit affirmed the judgment of the district court granting summary judgment for Defendants on Plaintiff's age discrimination and Older Workers Benefit Protection Act (OWBPA) claims, holding that Plaintiff's OWBPA-compliant waiver and release were knowing and voluntary under federal common law.
Plaintiff, a former Winchendon police officer, decided to resign with a pension after the Defendants determined that he had made several threats against his former girlfriend. Plaintiff resigned instead of facing termination and the possibility of losing his pension and being criminally charged. Plaintiff signed a separation agreement agreeing to waive and release any claims he had against Defendants up and through signing the agreement. Plaintiff later brought a complaint alleging age discrimination, retaliation, and defamation, alleging that the waiver and release in his separation agreement violated the OWBPA and were thus invalid. The district court granted summary judgment on the age discrimination and OWBPA claims for Defendants, and a jury found for Defendants on the retaliation and defamation claims. The Supreme Court affirmed the district court's grant of summary judgment, holding (1) the waiver and release did not violate the OWBPA and were knowing and voluntary; and (2) Defendant's argument that the district court abused its discretion in withdrawing an exhibit at trial was meritless.
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