Gomez-Gonzalez v. Rural Opportunities, Inc.
626 F.3d 654
1st Cir.2010Background
- ROI is a private regional not-for-profit with Puerto Rico operations; Gómez-González, the Puerto Rico director, faced relocation of authority and a disciplinary probation after a Rochester audit.
- Gómez-González alleged gender, age, and disability discrimination, and claimed ERISA benefits denial; she also asserted state-law wrongful termination.
- ROI terminated Gómez-González following discovery of an island-based bank account opened by ROI Puerto Rico’s affiliate, which allegedly breached ROI policies.
- Gómez-González claimed the bank-account action was pretextual for discrimination and that ROI failed to accommodate her back condition (ADA).
- ROI moved for summary judgment on all federal claims; the district court granted summary judgment and dismissed pendent state claims without prejudice.
- The First Circuit affirmed, holding that ROI’s proffered reason was not pretextual, accommodation was not shown as reasonable, and ERISA claims failed as ROI was not a fiduciary in denial of benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Discriminatory termination pretext | Gómez-González argues pretext due to shifting reasons. | ROI asserts a consistent, policy-violating breach (ROPRI account) as the termination basis. | No genuine pretext; termination based on policy breach and fiduciary concerns. |
| ADA failure to accommodate | Gómez-González contends ROI failed to provide reasonable accommodation after back/eyeing recovery. | Proposed accommodation was unreasonable; ROI offered alternatives. | Summary judgment for ROI affirmed; accommodation not proven reasonable. |
| ERISA benefits denial | ROI denied disability benefits; Gómez-González seeks plan-benefit relief. | ROI only processed claims; Guardian administers benefits; ROI not a fiduciary. | ROI not liable as a non-fiduciary; dismissal affirmed. |
| Pretext evidence consistency | Differences between termination letter and deposition show pretext. | Letters and testimony align; no contradiction. | No material inconsistency found; supports summary judgment. |
| State-law claims preclusion/dismissal | Plaintiff sought state claims; argues for jurisdiction. | District court dismissed pendent state claims without prejudice. | Affirmed dismissal without prejudice of state-law claims. |
Key Cases Cited
- Rodríguez-Torres v. Caribbean Form Mfr., Inc., 399 F.3d 52 (1st Cir. 2005) (prima facie discrimination framework for Title VII)
- Vélez v. Thermo King de P. R., Inc., 585 F.3d 441 (1st Cir. 2009) (ADEA prima facie framework for age discrimination)
- Lockridge v. Univ. of Me. Sys., 597 F.3d 464 (1st Cir. 2010) (burden-shifting framework; pretext standard)
- García v. Bristol-Myers Squibb Co., 535 F.3d 23 (1st Cir. 2008) (summary judgment in discrimination context; focus on evidence as a whole)
- Higgins v. New Balance Athletic Shoe, Inc., 194 F.3d 252 (1st Cir. 1999) (prima facie/ accommodation framework; burden on plaintiff)
- Terry v. Bayer Corp., 145 F.3d 28 (1st Cir. 1998) (ERISA fiduciary status; processing claims alone not enough)
- Law v. Ernst & Young, 956 F.2d 364 (1st Cir. 1992) (fiduciary status for ERISA claims)
- Beddall v. State St. Bank & Trust Co., 137 F.3d 12 (1st Cir. 1998) (minimally discretionary role; not fiduciary)