Soto-Feliciano v. Villa Cofresi Hotels, Inc.
779 F.3d 19
1st Cir.2015Background
- Soto-Feliciano was head chef at Villa Cofresí Hotel in Puerto Rico and was fired in March 2010.
- He sued under the federal Age Discrimination in Employment Act (ADEA) and Puerto Rico anti-discrimination and wrongful termination laws.
- The district court granted summary judgment for the hotel and manager in September 2013, dismissing federal claims with prejudice and state claims without prejudice.
- The district court treated the case under McDonnell Douglas framework for age discrimination with indirect evidence.
- After review, the First Circuit reversed summary judgment on the ADEA discrimination claim, finding genuine issues on pretext and motive.
- The court also revived the retaliation claim under the ADEA and vacated dismissal of pendent state-law claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prima facie case for age discrimination | Soto shows age 40+, qualified, fired, position filled. | Record disputes qualification due to misconduct; legitimate non-discriminatory reason shown. | Prima facie discrimination shown; burden shifts to defendants. |
| Pretext for age discrimination | Discriminatory comments by decisionmakers and temporal proximity support pretext. | misconduct and other evidence negate inference of age bias. | Gaps and inconsistencies create triable issue; summary judgment reversed. |
| Role of alleged misconduct in firing | Gaps in disciplinary process and timing suggest pretext for discrimination. | Proven misconduct justified suspension and termination. | Record supports competing inferences; jury could find pretext. |
| Retaliation claim viability | Protected conduct (complaints and Department of Labor visit) linked to adverse action. | Grounds for discipline independent of protected activity; timing coincidences not enough. | Genuine issues of material fact on pretext for retaliation; remand affirmed. |
Key Cases Cited
- McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (three-stage framework for circumstantial evidence in discrimination)
- Gross v. FBL Fin. Servs., Inc., 557 U.S. 167 (2009) (ADEA framework applicability acknowledged; burden-shifting discussed)
- Velez v. Thermo King de Puerto Rico, Inc., 585 F.3d 441 (1st Cir. 2009) (principles for proving pretext in ADEA cases)
- Zapata-Matos v. Reckitt & Colman, Inc., 277 F.3d 40 (1st Cir. 2002) (prima facie threshold for discrimination; low burden standard)
- St. Mary's Honor Ctr. v. Hicks, 509 U.S. 502 (1993) (presumption and burden shifting in discrimination proving)
- Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (pretext framework; evaluating evidence of discrimination)
- Hodgens v. General Dynamics Corp., 144 F.3d 151 (1st Cir. 1998) (circuit caution on weighing evidence at summary judgment in discrimination)
- Mesnick v. Gen. Elec. Co., 950 F.2d 816 (1st Cir. 1991) (pretext and motive at summary judgment; shifting burdens)
- Domínguez-Cruz v. Suttle Caribe, Inc., 202 F.3d 424 (1st Cir. 2000) (supervisor conduct can support discrimination claim)
- DeCaire v. Mukasey, 530 F.3d 1 (1st Cir. 2008) (temporal proximity can support retaliation inference)