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Teixeira v. Town of Coventry

United States Court of Appeals, First Circuit

February 7, 2018

MOIRA E. TEIXEIRA, Plaintiff, Appellant,
v.
TOWN OF COVENTRY, by and through its Treasurer, THEODORE PRZYBYLA, ET AL., Defendants, Appellees.

         APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND [HON. JOHN J. MCCONNELL, JR., U.S. DISTRICT JUDGE]

          Mark P. Gagliardi and Law Office of Mark P. Gagliardi on brief for appellant.

          Marc DeSisto, Kathleen A. Hilton, DeSisto Law LLC, Nicholas Gorham, and Gorham & Gorham on brief for appellees.

          Before Lynch, Circuit Judge, Souter, Associate Justice, [*] and Selya, Circuit Judge.

          SELYA, Circuit Judge.

         The McDonnell Douglas framework, see McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802-804 (1973), has proven to be a useful tool in the adjudication of pretrial motions (especially at the summary judgment stage) in discrimination and retaliation cases. See, e.g., Burns v. Johnson, 829 F.3d 1, 8 (1st Cir. 2016) (discrimination); Henry v. United Bank, 686 F.3d 50, 55 (1st Cir. 2012) (retaliation). Jury instructions, however, are a different medium, and some courts have expressed concern about the suitability of the McDonnell Douglas framework for that purpose. See, e.g., Sharkey v. Lasmo (AUL Ltd.), 214 F.3d 371, 374 (2d Cir. 2000) (expressing the view that "[i]nstructing the jury on [the] complex process [of McDonnell Douglas burden-shifting] produces no benefit and runs the unnecessary risk of confusing the jury"); Loeb v. Textron, Inc., 600 F.2d 1003, 1016 (1st Cir. 1979) (warning that reading McDonnell Douglas's "technical aspects to a jury . . . will add little to the juror's understanding of the case").

         In our view, the McDonnell Douglas framework can, in the trial court's discretion, be put to effective use in the shaping of jury instructions. The key, we think, is for the trial court to refrain from rote recitation of the complex McDonnell Douglas process and the legalistic terms in which the McDonnell Douglas framework is typically couched. Thus, a trial court that wishes to use the framework as part of its jury instructions should translate it into everyday parlance and fit it to the facts and circumstances of a particular case. Here, the court below did just that.

         Given the satisfactory nature of the district court's jury instructions as a whole, we discern no merit in the appellant's claims of error. Accordingly, we affirm the judgment below.

         I. BACKGROUND

         We briefly rehearse the facts and travel of the case. Plaintiff-appellant Moira E. Teixeira toiled as a social worker for the Town of Coventry, Rhode Island (the Town), in its Department of Human Services. Over the course of roughly three years, the appellant took three medical leaves, comprising nearly eight months in aggregate leave time. Matters came to a head on June 14, 2013: as the appellant returned from her latest leave, she was fired. The Town represented that her dismissal was based on poor job performance (including violations of department protocols, breaches of confidentiality, and repeated failures to complete work assignments).

         Displeased with the Town's actions, the appellant repaired to the federal district court and sued both the Town and her supervisor, Patricia Shurtleff. Her complaint alleged violations of federal and state law, including the Family and Medical Leave Act (FMLA), 29 U.S.C. §§ 2601-2619, and the Rhode Island Civil Rights Act (RICRA), R.I. Gen. Laws § 42-112-1. Specifically, she claimed that she had been both retaliated against for taking medical leave and discriminated against on account of disability.[1]

         Following extensive discovery and a week-long jury trial, the district court sent the case to the jury. With reference to the FMLA and RICRA counts, the court instructed the jury using an adapted version of the McDonnell Douglas framework (over the appellant's objection). After deliberating, the jury returned a take-nothing verdict in favor of the defendants.

         The appellant moved for a new trial, lodging (inter alia) two claims of instructional error in connection with the FMLA and RICRA counts: she asserted that the district court had erred in employing the McDonnell Douglas framework in its jury instruction and that the court had erred when it instructed the jury to consider whether the appellant had shown that the defendants' reasons for cashiering her were pretextual. The district ...


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