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