Carreras-Morales v. Silgan Containers Manufacturing Puerto Rico LLC
3:19-cv-01828
D.P.R.Feb 4, 2022Background
- Carreras applied for a Silgan plant-manager job; Silgan used TPI (which cooperated with Okaya) to recruit and consider local candidates.
- TPI president Joann Cox emailed that Silgan "won't hire any candidate who is 58+" and advised focusing on candidates under ~55–58; Okaya later asked Carreras for his age and DOB; Carreras replied he was 60.
- Carreras took Silgan’s two-stage pre‑employment test: he passed stage one but received a non‑passing "review" on stage two; Silgan recommended not moving him forward and ultimately promoted an internal, younger candidate who passed the tests.
- Carreras sued Silgan, Okaya, and TPI under the ADEA and Puerto Rico Law 100; Silgan and Okaya filed third‑party indemnity/contribution/negligence claims against TPI and against each other; TPI filed similar third‑party claims back.
- Carreras and TPI settled: TPI paid Carreras, Carreras released TPI from liability and agreed to hold TPI harmless; they filed a stipulation seeking dismissal of Carreras’s claims against TPI and dismissal of Silgan’s and Okaya’s third‑party complaints.
- The court (1) accepted dismissal of Carreras’s claims against TPI, (2) held the settlement mooted indemnity/contribution claims but not Silgan’s/Okaya’s negligence claims against TPI, (3) granted summary judgment to Silgan and Okaya on ADEA and Law 100 claims, and (4) declined supplemental jurisdiction over the remaining negligence claims and dismissed them without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Effect of plaintiff/TPI settlement on third‑party claims | Settlement released TPI from all liability, so third‑party claims should be dismissed | Defendants argue they were not parties to the settlement and therefore their claims survive | Settlement valid to release TPI from Carreras’s claims and from indemnity/contribution claims by others, but it does not release defendants’ negligence claims against TPI; indemnity/contribution claims are moot and dismissed |
| Rule 41 dismissal of TPI from Carreras’s amended complaint | Voluntary dismissal with prejudice pursuant to stipulation and settlement | No opposition from TPI; defendants object that dismissal cannot extinguish their claims | Court granted dismissal of Carreras’s claims against TPI with prejudice under Rule 41(a)(2); defendants’ objections do not prevent plaintiff’s dismissal of his own claims |
| ADEA/Law 100: whether evidence showed direct discrimination or a prima facie case (failure‑to‑hire) | Cox’s emails, LaClair’s "longevity" remark, and Okaya’s request for age are direct evidence; overall show age was but‑for cause | Defendants contend remarks are hearsay or stray/nondecisionmaker comments; Carreras failed the pre‑employment test and there is no evidence Silgan knew his age | Court: Cox’s emails partly hearsay/nondecisionmaker; LaClair’s "longevity" remark ambiguous; Okaya’s remarks not attributable to Silgan. Carreras failed the test and admitted no evidence Silgan knew his age. Summary judgment for defendants on ADEA and Law 100 claims |
| Whether to retain supplemental jurisdiction over defendants’ negligence claims | Plaintiff/TPI argue settlement and related rulings resolve federal claims; leave state claims to be decided here | Defendants prefer adjudication here; court should consider comity and efficiency | Court declined supplemental jurisdiction over remaining negligence claims given different legal issues and mootness of related third‑party claims; negligence claims dismissed without prejudice |
Key Cases Cited
- Sagardía de Jesús v. Hosp. Auxilio Mutuo, 177 D.P.R. 484 (P.R. 2009) (plaintiff may release a joint tortfeasor and that release reduces plaintiff’s recovery accordingly)
- Szendrey v. Hospicare, Inc., 158 D.P.R. 648 (P.R. 2003) (same principle on subtracting released co‑defendant liability from recovery)
- Rio Mar Assocs., LP v. UHS of P.R., Inc., 522 F.3d 159 (1st Cir.) (parties cannot by private agreement extinguish third parties’ legal rights)
- Zampierollo‑Rheinfeldt v. Ingersoll‑Rand de P.R., Inc., 999 F.3d 37 (1st Cir.) (standard for direct evidence and McDonnell Douglas framework at summary judgment)
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden‑shifting framework for discrimination claims)
- Cason v. P.R. Elec. Power Auth., 770 F.3d 971 (1st Cir.) (standard for assessing prejudice in Rule 41 voluntary dismissals)
- Already, LLC v. Nike, Inc., 568 U.S. 85 (2013) (cases must present a live controversy at all stages; mootness doctrine)