Hoffman-Garcia v. Metrohealth, Inc., 918 F.3d 227

Background

Hoffman was Physical Plant Director at Hospital Metropolitano from 1995–2012; his duties included maintenance, budget oversight, hiring contractors, and attending senior meetings.
In 2012 the hospital closed the Physical Plant Department for cost-cutting and laid off Hoffman and all department staff; an outside contractor assumed maintenance services.
Giovanni Martínez (Hoffman’s deputy) was rehired months later as Safety Officer; Martínez was 36, Hoffman 62; Hoffman did not apply for the Safety Officer position.
Hoffman sued under the ADEA and Puerto Rico antidiscrimination and unjust discharge laws, claiming age discrimination in layoff/rehire and failure to hire for the Safety Officer role.
The district court granted summary judgment in part for the hospital, then at trial granted judgment as a matter of law for the hospital, holding Hoffman failed to prove a prima facie case and that the Safety Officer differed significantly from Hoffman's prior role.
On appeal the First Circuit reviewed de novo whether a rational jury could find age discrimination and affirmed the district court.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether closing the Physical Plant and laying Hoffman off constituted age discrimination by replacing him with a younger employee	Hoffman argued a younger employee (Martínez) was effectively retained to perform his job functions	Hospital argued the Physical Plant position was eliminated for legitimate business reasons and no one filled the director role	Held: No — position was eliminated; no evidence a younger person filled an equivalent role
Whether rehiring Martínez as Safety Officer (rather than hiring Hoffman) showed age discrimination	Hoffman argued rehiring a younger employee for a related role supports an inference of age bias	Hospital argued the Safety Officer role was materially different, lower authority/salary, and Hoffman never applied	Held: No — Safety Officer duties differed substantially and Hoffman did not apply
Whether Hoffman's failure to apply for Safety Officer defeats his failure-to-hire claim	Hoffman suggested employer’s conduct and statements showed discriminatory motive despite no application	Hospital asserted failure to apply is fatal to a failure-to-hire claim under settled precedents	Held: Yes — failure to apply undermines adverse-action/causal showing; fatal to prima facie case
Whether credibility determinations (e.g., Rosado’s testimony) preclude Rule 50 judgment as a matter of law	Hoffman argued credibility is for the jury and factual testimony favoring employer should not be weighed on Rule 50	Hospital argued even accepting Hoffman’s view of testimony, the evidentiary record lacked facts to establish a prima facie case	Held: No — even viewing evidence favorably to Hoffman, record lacked essential elements to send to jury

Key Cases Cited

Cardona Jimenez v. Bancomercio de Puerto Rico, 174 F.3d 36 (1st Cir. 1999) (standard for similarly situated comparison in discrimination cases)
Velez v. Janssen Ortho, LLC, 467 F.3d 802 (1st Cir. 2006) (requirement that plaintiff apply for specific job in failure-to-rehire claims)
Del Valle-Santana v. Servicios Legales de Puerto Rico, Inc., 804 F.3d 127 (1st Cir. 2015) (affirming dismissal where plaintiff failed to establish prima facie discrimination)
McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (burden-shifting framework for disparate-treatment cases)
LeBlanc v. Great Am. Ins. Co., 6 F.3d 836 (1st Cir. 1993) (partial overlap of duties insufficient to show replacement)
Pagues-Cahue v. Iberia Lineas Aereas de España, 82 F.3d 533 (1st Cir. 1996) (hiring a younger employee for an inferior position does not alone create inference of age animus)
Barkan v. Dunkin' Donuts, Inc., 627 F.3d 34 (1st Cir. 2010) (credibility assessments are generally for the jury)
Wilson v. Moreau, 492 F.3d 50 (1st Cir. 2007) (standard for reviewing sufficiency of evidence at trial)
Malone v. Lockheed Martin Corp., 610 F.3d 16 (1st Cir. 2010) (viewing evidence in light most favorable to nonmovant on appeal)
Delgado v. Pawtucket Police Dep't, 668 F.3d 42 (1st Cir. 2012) (de novo review of Rule 50 rulings)