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Rodriguez-Machado v. Shinseki
700 F.3d 48
| 1st Cir. | 2012
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Background

  • Rodríguez-Machado appeals a district court grant of summary judgment in an ADEA discrimination, retaliation, and hostile work environment case.
  • The appeal is dismissed for major noncompliance with appellate rules, per panel’s decision.
  • Plaintiff failed to provide specific record cites, failed to articulate a legal theory with caselaw, and offered little reasoning in briefing.
  • Defendant is Eric K. Shinseki, Secretary of the Department of Veterans Affairs; the district court decision was in Puerto Rico.
  • The panel cites Reyes-García and In re Simply Media as controlling authority for severe procedural breaches justifying dismissal with prejudice.
  • The court notes that occasional rule violations are not fatal, but major breaches that impede review warrant dismissal.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the appeal should be dismissed for noncompliance with appellate rules Rodríguez-Machado argues against dismissal, contending factual disputes require review. Shinseki contends major rule breaches justify dismissal with prejudice. Yes; the appeal was dismissed with prejudice for major rule violations.

Key Cases Cited

  • Reyes-García v. Rodríguez & Del Valle, Inc., 82 F.3d 11 (1st Cir. 1996) (major procedural breaches can justify dismissal of an appeal)
  • In re Simply Media, Inc., 566 F.3d 234 (1st Cir. 2009) (per curiam; standard for dismissing appeals for noncompliance)
  • United States v. Dunkel, 927 F.2d 955 (7th Cir. 1991) (judges are not obligated to hunt for record support; parties must provide it)
  • Tayag v. Lahey Clinic Hosp., Inc., 632 F.3d 788 (1st Cir. 2011) (reliance on proper briefing and record citation in complex issues)
  • Velázquez-Ortiz v. Vilsak, 657 F.3d 64 (1st Cir. 2011) (complex discrimination claims require thorough briefing)
  • Colón-Fontánez v. Mun. of San Juan, 660 F.3d 17 (1st Cir. 2011) (guidance on hostile environment analysis in employment cases)
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Case Details

Case Name: Rodriguez-Machado v. Shinseki
Court Name: Court of Appeals for the First Circuit
Date Published: Nov 21, 2012
Citation: 700 F.3d 48
Docket Number: 12-1430
Court Abbreviation: 1st Cir.