Carrabes v. Expeditors International of Washington, Inc., 1:24-cv-12142

Michael Carrabes, a Massachusetts employee, sued Expeditors International, his former employer, for alleged sex discrimination relating to his demotion and firing following a purported "covert termination program" aimed at avoiding layoffs.
Carrabes alleged Expeditors promoted a "no layoff policy" but secretly engineered terminations under pretext of poor performance during a post-pandemic business downturn.
Plaintiff moved to amend his complaint, seeking to add five new claims (including RICO and promissory estoppel) and two individual defendants: his supervisor and his brother (a company VP).
The amended complaint relied on allegations about Expeditors’ Code of Conduct and public promises, as well as specific negative performance reviews and subsequent personnel actions.
The court reviewed whether the proposed new claims would be futile under the Rule 12(b)(6) standard and whether joinder of new defendants was proper under Rule 20(a)(2).
The court ultimately allowed the amendment as to one claim (interference with advantageous relations) but denied as to others, including RICO and promissory estoppel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Promissory Estoppel	Expeditors made clear promises (no layoffs, fair treatment, Code compliance) that induced reliance.	No enforceable or specific promise made; at-will employment, and no handbook contract.	Dismissed — Promises too vague; no reasonable reliance.
RICO (18 U.S.C. § 1962(c)/(d))	Defendant’s wire communications and internal scheme to replace employees were predicate acts of wire fraud for RICO claim.	No predicate acts; emails not fraudulent or deceptive; no scheme to defraud as defined under RICO.	Dismissed — Insufficient particularity, no actionable wire fraud alleged.
Interference with Contractual Relations	Supervisors interfered with his contract through malice and actions in violation of the Code.	No valid contract existed, only at-will employment; Code/Handbook not enforceable.	Dismissed — Handbook/Code was not an employment contract.
Interference with Advantageous Relations	Supervisors acted out of malice to disrupt plaintiff’s advantageous relationship with the company.	No sufficient showing of actual malice; actions were employment-related.	Allowed — Sufficiently pled malice and improper motive; amendment permitted.

Hinchey v. NYNEX Corp., 144 F.3d 134 (1st Cir. 1998) (personnel manuals and vague employer promises typically do not create enforceable employment contracts)
O'Brien v. New England Tel. & Tel. Co., 664 N.E.2d 843 (Mass. 1996) (establishing factors for whether an employee handbook can alter at-will status)
Jackson v. Action for Boston Community Development, Inc., 525 N.E.2d 411 (Mass. 1988) (identifying nonbinding nature of personnel manuals absent specific circumstances)
Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479 (U.S. 1985) (four elements required to state a RICO claim)
Zimmerman v. Direct Fed. Credit Union, 262 F.3d 70 (1st Cir. 2001) (supervisors may be personally liable for interference with employment if acting with actual malice)
G.S. Enters., Inc. v. Falmouth Marine, Inc., 571 N.E.2d 1363 (Mass. 1991) (setting forth elements for tortious interference with contractual relations)