Ameen v. Amphenol Printed Circuits, Inc.
777 F.3d 63
| 1st Cir. | 2015Background
- Murad Ameen, a long‑time Group Leader at Amphenol, took FMLA leave in March 2012, then a separate approved personal leave in April–May 2012; he returned to his job and declined overtime shifts thereafter.
- Amphenol investigated reports that Ameen punched out for a 30‑minute unpaid lunch while continuing to work, then later left the property for about an hour, effectively receiving ~15 minutes paid time daily he did not work.
- Company records (ADI timecard and CCure door logs) showed Ameen had this practice consistently for about two years; he had a prior written warning in April 2012 for failing to follow procedure.
- Operations Director Christine Harrington reviewed the records, considered the prior warning, and decided to terminate Ameen for stealing time; she did not know about his FMLA leave or overtime refusals.
- Ameen sued under the FMLA, claiming termination was retaliation for his FMLA‑protected activity; the district court granted summary judgment for Amphenol, and the First Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Ameen raised a triable FMLA‑retaliation claim | Ameen says his FMLA leave and refusal to work overtime (as protected conduct) motivated his firing; decisionmakers or supervisors harbored retaliatory animus | Amphenol says it had a legitimate nondiscriminatory reason — consistent unauthorized paid break time and prior warning — and the decisionmaker lacked knowledge of FMLA activity | Affirmed: plaintiff failed to show pretext or animus sufficient to defeat summary judgment |
| Whether cat’s paw liability imputes supervisors’ alleged animus to the decisionmaker | Ameen contends Pratt or Conners harbored animus and their reports induced Harrington to fire him | Amphenol contends supervisors investigated, reported accurate records, and Harrington independently confirmed misconduct; no evidence supervisors were motivated by retaliation | Held: no evidence of retaliatory animus by Pratt or Conners; cat’s paw theory fails |
| Whether the employer’s proffered reason was pretextual | Ameen argues inconsistencies and differential treatment raise inference of pretext | Amphenol points to documentary timecard/door records, Ameen’s admissions, and prior warning as nonretaliatory reasons | Held: employer’s reason was legitimate; plaintiff did not produce evidence creating a genuine dispute of pretext |
| Proper standard for cat’s paw proof | Ameen urges reliance on Staub’s proximate‑cause/animus test | Amphenol notes First Circuit precedent requires showing reporting was inaccurate/ misleading or motivated by animus that induced decisionmaker | Held: Court need not resolve differences; both standards require proof of retaliatory animus, which Ameen failed to show |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (framework for burden‑shifting in discrimination/retaliation cases)
- Staub v. Proctor Hosp., 562 U.S. 411 (2011) (cat’s paw liability requires an act motivated by animus that proximately causes adverse action)
- Hodgens v. Gen. Dynamics Corp., 144 F.3d 151 (1st Cir. 1998) (FMLA prohibits using leave as a negative factor; applies McDonnell Douglas framework)
- Cariglia v. Hertz Equip. Rental Corp., 363 F.3d 77 (1st Cir. 2004) (corporate liability where decisionmaker relies on manipulated information from a biased subordinate)
- McArdle v. Town of Dracut, 732 F.3d 29 (1st Cir. 2013) (summary judgment review: facts viewed in light most favorable to nonmovant)