Lahens v. AT&T Mobility Puerto Rico, Inc, 28 F.4th 325

Felix Lahens was hired in 2013 at age 57 as a Sales Training Manager for DIRECTV (later AT&T) and supervised Sales Training Specialists.
In August 2015 he took medical leave for a liver transplant (surgery Jan. 29, 2016); he returned April 4, 2016, to the same title, pay, and benefits and later requested limited time off for medical appointments (requested July 26, 2016; told no accommodation required).
After a January 9, 2017 meeting with supervisees, an internal complaint led to a written warning (March 10, 2017) for unprofessional conduct; Lahens then filed internal complaints alleging age/disability discrimination and retaliation.
Following the AT&T–DIRECTV integration and an outside efficiency review, AT&T implemented a reduction-in-force (RIF) eliminating the Sales Training Manager position; Lahens received surplus notice July 31, 2017 and his employment ended Dec. 30, 2017.
Lahens filed administrative charges (Mar. 27, 2018) and sued (Oct. 2018) under the ADEA and ADA and parallel Puerto Rico statutes; the district court granted summary judgment for AT&T, dismissing federal claims with prejudice and some local claims, and this appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness of pre-2017 events	Lahens sought to rely on pre-May 31, 2017 conduct to show discrimination/retaliation	AT&T and district court: events before May 31, 2017 are time-barred; only post-May 31, 2017 acts are actionable	Plaintiff conceded pre-May 31 claims waived; appellate court enforced the time bar
ADEA — discriminatory termination	Lahens: RIF was pretextual and motivated by age (points to HR note and alleged exclusion/promotion of younger employees)	AT&T: elimination based on legitimate, non-discriminatory business integration and London Consulting recommendations; RIF applied evenhandedly	Held for AT&T: plaintiff failed to show pretext or that decisionmaker disbelieved stated business reasons
ADA — disability discrimination/failed accommodation	Lahens: termination and alleged exclusion were related to his transplant; denial of accommodation	AT&T: requested accommodation unnecessary; he could perform essential duties and had schedule flexibility; termination due to RIF	Held for AT&T: ADA claim fails for same reasons as ADEA — no pretext shown; most pre-termination ADA facts were time-barred
Puerto Rico statutory/tort claims (Laws 44, 100, 115, 80; Art. 1802)	Lahens: parallel local-law claims should survive if federal claims do	AT&T: local claims rise or fall with federal analogues; Article 1802 duplicative	Held: Laws 44, 100, 115, 80 fail for same reasons as federal claims; Article 1802 dismissal affirmed as waived on appeal

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (U.S. 1973) (establishes the burden-shifting framework for disparate-treatment claims)
Mesnick v. Gen. Elec. Co., 950 F.2d 816 (1st Cir. 1991) (pretext inquiry focuses on the decisionmaker's perception and belief in the stated reason)
Suarez v. Pueblo Int'l, Inc., 229 F.3d 49 (1st Cir. 2000) (ADEA standard and McDonnell Douglas application)
Zampierollo-Rheinfeldt v. Ingersoll-Rand de P.R., Inc., 999 F.3d 37 (1st Cir. 2021) (prima facie showing in RIF context)
Bonefont-Igaravidez v. Int'l Shipping Corp., 659 F.3d 120 (1st Cir. 2011) (pretext shown by weaknesses or inconsistencies in employer's reasons)
Furnco Constr. Corp. v. Waters, 438 U.S. 567 (U.S. 1978) (courts should not act as super-personnel departments reviewing business decisions)
Bennett v. Saint-Gobain Corp., 507 F.3d 23 (1st Cir. 2007) (focus on motivations and perceptions of the actual decisionmaker in pretext analysis)
Brader v. Biogen Inc., 983 F.3d 39 (1st Cir. 2020) (termination of others in RIF and evenhanded application weighs against finding pretext)
Ruiz v. Posadas de San Juan Assocs., 124 F.3d 243 (1st Cir. 1997) (pretext requires evidence sufficiently strong to permit a reasonable finding employer's reason was manifestly unsupported)