Latest 3 Cases: Chum v. Coyne-Fague (Civil Rights), Santana-Vargas v. Banco Santander Puerto Rico (Civil Rights), Martinez v. Sun Life Assurance ...

The Law Will Not Save Us

JOSEPH MARGULIES

Cornell law professor Joseph Margulies reminds us that the rule of law exists in the United States primarily to conceal politics; that is, one cannot rely on having “the law” on one’s side if politics are opposed. Margulies illustrates this point by replacing “the lawyers reviewed the law and decided” with “the high priests studied the entrails and decided”—a substitution that ultimately yields the same results.

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Chum v. Coyne-Fague

Docket: 18-2028

Opinion Date: January 27, 2020

Judge: Kermit Victor Lipez

Areas of Law: Civil Rights, Constitutional Law, Criminal Law

The First Circuit affirmed the district court decision denying Appellant's petition for habeas corpus relief, holding that the state court's evaluation of Appellant's constitutional claim was not contrary to, nor involved an unreasonable application of, federal law. Appellant was convicted in Rhode Island state court on felony assault and firearms charges. The Rhode Island Supreme Court affirmed. Appellant then applied for postconviction relief based on the ineffective assistance of counsel. The trial justice denied relief, and the Supreme Court affirmed. Appellant later filed a petition for a writ of habeas corpus in federal court, claiming ineffective assistance of counsel in violation of the Sixth Amendment. The district court concluded that Appellant's counsel's performance was constitutionally deficient but that the state Supreme Court's conclusion that Appellant had failed to satisfy the prejudice prong was not an unreasonable application of clearly established federal law. The First Circuit affirmed, holding (1) the Rhode Island Supreme Court's use of the incurable prejudice standard did not lead to a decision "contrary to" federal law; and (2) the Supreme Court's application of Strickland was not unreasonable.

Santana-Vargas v. Banco Santander Puerto Rico

Docket: 18-1990

Opinion Date: January 27, 2020

Judge: William Joseph Kayatta, Jr.

Areas of Law: Civil Rights, Labor & Employment Law

The First Circuit affirmed the decision of the district court granting summary judgment to Defendants on Plaintiff's Age Discrimination in Employment Act (ADEA), 29 U.S.C. 621, and relinquishing supplemental jurisdiction over his claims under Puerto Rico law, holding that a reasonable jury could not find pretext discrimination and that the district court did not abuse its discretion in declining to exercise continued supplemental jurisdiction. In his complaint, Plaintiff alleged that he was fired on account of his age. The district court concluded that Plaintiff failed to put forth evidence that he was complying with the legitimate job performance expectations for his position and therefore failed to make a prima facie showing of discrimination. The First Circuit affirmed, holding (1) assuming that Plaintiff established a prima facie case, Plaintiff failed to show that his poor performance reviews were pretextual; and (2) while retention was an option, the district court did not exceed the boundary of its discretion in declining to exercise continued supplemental jurisdiction.

Martinez v. Sun Life Assurance Co. of Canada

Docket: 18-2127

Opinion Date: January 27, 2020

Judge: Kermit Victor Lipez

Areas of Law: ERISA, Insurance Law, Labor & Employment Law

The First Circuit affirmed the judgment of the district court in favor of Sun Life Assurance Company of Canada finding that Sun Life properly permitted an offset of Appellant's benefits under tis employer-sponsored long-term disability insurance policy (the Plan) by the amount of Appellant's service-connection disability compensation (Veterans' Benefits), holding that the district court did not err. Specifically, the First Circuit held (1) Appellant's Veterans' Benefits fell squarely within the definition of "Compulsory Benefit Act or Law"; (2) that the district court did not err by concluding as a matter of law that Veterans' Benefits unambiguously qualify as a form of "Other Income Benefit" covered by the Plan's offset provision; and (3) the district court did not err by rejecting as a matter of law Appellant's assertion that Sun Life's offset determination was motivated, at least in part, by Appellant's military service in violation of the Uniformed Services Employment and Reemployment Rights Act.