Summary
This First Circuit opinion reviews a district court's grant of summary judgment in favor of an employer on a whistleblower retaliation claim brought under Puerto Rico's Law 115. The appellate court held that the district court erred by treating temporal proximity as a strict requirement for establishing causation and by failing to adequately consider evidence of inconsistent explanations for the employee's termination. Consequently, the court vacated the summary judgment ruling and remanded the case for further proceedings, allowing a jury to determine whether the employer's stated reasons were pretextual.
Topics
Practice areas
Questions Presented
- Whether the five‑month interval between Román's protected activity and his termination precludes a finding of causation for a retaliation claim under Puerto Rico Law 115.
- Whether Cape Air's stated reasons for termination are pretextual.
- Whether the district court properly granted summary judgment on the retaliation claim.
Holdings
- Temporal proximity alone is not required; a plaintiff may establish causation through other evidence, and the five‑month gap does not bar a retaliation claim.
- The district court erred in granting summary judgment; genuine issues of material fact exist regarding pretext, so the judgment is vacated and the case remanded.
Key quotations
“We therefore do not see how he waived his challenge to the district court's pretext determination.”
“Close temporal proximity between the protected conduct and the adverse employment action may suffice at the prima facie stage to evidence causation.”
Factual background
Plaintiff Román was injured while working as a cross‑train agent for Cape Air in May 2017. He reported the incident to his supervisor and later sought workers' compensation benefits from the Puerto Rico State Insurance Fund. Cape Air failed to file the required work‑accident report promptly and later terminated Román in May 2019, five months after his report to the Fund.
Procedural history
The district court dismissed all of the plaintiff's claims, granting summary judgment on the retaliation claim under Law 115. The plaintiff appealed that decision, challenging the grant of summary judgment.
Remand instructions
The district court's summary judgment is vacated; the case is remanded for further proceedings consistent with this opinion.