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Wednesday, May 20, 2026

Employment – Retaliation – Nexus - Massachusetts Lawyers Weekly

Where a defendant employer was awarded summary judgment on claims of unlawful retaliation, that judgment should be affirmed because the plaintiff has not produced evidence from which a reasonable jury could conclude that he was terminated for asserting his right to seek accommodation of a disability under Massachusetts law or for exercising his rights under the Family and Medical Leave Act.

“Sandy Harris, Jr., appeals the district court’s grant of summary judgment in favor of his former employer, National Grid USA Service Company, Inc. (‘National Grid’), on his claims of unlawful retaliation under Massachusetts and federal law. The district court found Harris had failed to show the causal nexus required to sustain his claims. We agree that the clear chronology of events precludes any finding that Harris’s protected activity caused his termination. Our reasoning follows. …

“While Harris’s complaint sought to advance several claims, he challenges on appeal only the district court’s grant of summary judgment for National Grid on his retaliation claims, which we review de novo. … He does not press any claim that National Grid improperly failed to accommodate any disability. Instead, he contends that he was fired because he asserted his right to seek accommodation of a disability under Massachusetts law and/or relief under the FMLA. …

“Harris’s retaliation claims require him to prove a causal connection between conduct protected by those laws and his termination. … The record...



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