Stuart v. City of Framingham, Massachusetts, No. 20-1135 (1st Cir. 2021)Annotate this Case
The First Circuit affirmed the decision of the district court granting summary judgment in favor of Defendants, the City of Framingham and Brian Simoneau, in this lawsuit raising Massachusetts Whistleblower Act claims and speech retaliation claims under Garcetti v. Ceballos, 547 U.S. 410 (2006), holding that the district court did not err.
Vincent Stuart, a former Framingham police officer, brought this action alleging that the termination of his employment was in retaliation for his speech. The district court granted summary judgment for Defendants on both the First Amendment speech-retaliation and the Massachusetts Whistleblower Act claims. The First Circuit affirmed, holding that the district court did not err in concluding that there was not a triable question that Stuart's complaint was a substantial or motivating factor in his suspension and termination.