Mercado v. Hyannis Air Service, Inc.

CourtCourt of Appeals for the First Circuit
DecidedSeptember 22, 2025
Docket23-1744
StatusPublished

This text of Mercado v. Hyannis Air Service, Inc. (Mercado v. Hyannis Air Service, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mercado v. Hyannis Air Service, Inc., (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit No. 23-1744

ERASTO ROMÁN MERCADO,

Plaintiff, Appellant,

v.

HYANNIS AIR SERVICE, INC., d/b/a Cape Air/Nantucket Airlines,

Defendant, Appellee,

TEXTRON AVIATION INC.; CAPE AIR CORP.; NANTUCKET AIRLINES, A,B,C INSURANCE COMPANIES,

Defendants.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

[Hon. Camille L. Vélez-Rivé, U.S. District Judge]

Before

Gelpí, Lipez, and Rikelman, Circuit Judges.

Eugenio W.A. Géigel-Simounet, with whom GS Law Offices P.C. was on brief, for appellant.

Tatiana Leal González, with whom Juan Felipe Santos, Ana B. Rosado-Frontanés, and Jackson Lewis LLC, were on brief, for appellee.

September 22, 2025 GELPÍ, Circuit Judge. About five months after he began

receiving treatment for a work-related injury, Plaintiff-Appellant

Erasto Román Mercado ("Román") received a letter from his employer,

Defendant-Appellee Hyannis Air Service Inc. ("Cape Air"),

informing him that he was terminated from his job as a cross train

agent.1 Román sued Cape Air in the U.S. District Court for the

District of Puerto Rico, alleging various state and federal claims.

The district court disposed of all of them -- some at the motion

to dismiss and others at the summary judgment stage.

In this appeal, Román challenges only the district

court's summary judgment ruling as to his retaliation claim under

Puerto Rico's Whistle-Blower Act, P.R. Laws Ann. Tit. 29 § 194

("Law 115"). We are hence called upon to determine whether a jury

should be the one who determines if Cape Air's reasons for Román's

termination were pretextual, and, ultimately, whether Cape Air

retaliated against him under Law 115. While the district court

believed that the issue should be resolved at the summary judgment

stage -- and so ruled -- we, however, see it differently. We thus

vacate the district court's entry of summary judgment as to Román's

Law 115 claim and remand for further proceedings.

1 A cross train agent at Cape Air performs a multifaceted role that involves customer service, operations, and ramp duties.

- 2 - I. BACKGROUND

A. Facts

Cape Air is an airline company headquartered in Hyannis,

Massachusetts. Among other locations across the continental

United States, Cape Air provides services in the Caribbean,

including Vieques, San Juan, and Mayagüez, Puerto Rico. In 2005,

Román began working for Cape Air as a cross train agent in the

Mayagüez station. He was one of three agents who were responsible

for, among other things, operations, checking in passengers,

working the counters, and working the ramp. Over a decade after

beginning his tenure with Cape Air, however, Román's employment

with the company took an unexpected turn.

On April 16, 2017, when, during a shift, Román opened

the top portion of the passengers' cabin door of the airplane to

let a customer disembark, the door's support suddenly unhinged,

hitting Román's forehead with significant force. Pilot Alberto

Espinosa, who was present when the incident occurred, filed a

"Flight Crew Analyst Incident Report" ("Form 3590"), which stated:

Maintenance NEED to do their job! The airplane's cabin door was worked on two days prior to the incident. After close inspection, I noticed that they forgot to install the locking safety clips on both the top and bottom strut sockets. It was just a matter of time before one popped off and let the door fall on someone, even a passenger.

Soon after the incident, Román alerted his

then-supervisor of what had transpired. Román nonetheless

- 3 - continued working until the end of his shift and then drove himself

to a nearby hospital where, after being evaluated, he was diagnosed

with unspecified superficial injury to the skull. Sometime later,

Román asked Cape Air for the incident report to seek medical

treatment with Puerto Rico's workers' compensation system: the

State Insurance Fund ("the Fund"). Cape Air, however, neither

gave him the report nor informed him that the same was necessary

to seek treatment from the Fund.2 Instead, Cape Air told him to

use his personal insurance. As a result, Román did not immediately

seek help at the Fund.3

Six months after the incident, on October 21, 2017,

Román went to the emergency room at a nearby hospital, where he

underwent an examination.4 Then over a year later, on November 29,

2018 -- after experiencing neck pain and numbness in his hands for

several months -- Román sought medical treatment. The

chiropractor ordered him to undergo a cervical magnetic resonance

2 While Cape Air did not file a Work Accident Report with the Fund immediately after the incident, it eventually did so in March 2019, upon discovering that it had never been filed with the Fund. Cape Air amended the report on May 23, 2019, to correct the case number. Cape Air admitted that the report should have been filed in 2017, right after Román's accident -- that is, almost two years earlier. 3 Román's supervisors never instructed him to avoid reporting

to the Fund, nor did they impose disciplinary actions or suggest that seeking medical treatment from the Fund would alter the terms of his employment. 4 After the examination, Román was referred to a neurological

evaluation.

- 4 - imaging ("MRI"), which showed that Román had C6-C7 stenosis, a

condition associated with pain and numbness. Román also visited

a physician on November 30, 2018, who referred Román to the Fund.

On that same date, Román reported to the Fund and began receiving

treatment.

Because Román could not continue working at the time,

Cape Air placed him on leave on December 5, 2018, under the Family

and Medical Leave Act ("FMLA"). The leave was set to expire on

February 27, 2019. From December 2018 to February 2019, Fund

personnel examined Román five times and placed him on rest until

February 13, 2019. About a week before his rest period ended,

however, Román had neck surgery. As a result, Fund personnel

examined him again on February 13, March 17, and April 29, 2019,

ultimately placing him on rest until June 12, 2019, with a

return-to-work date of June 13, 2019.

Meanwhile, at the time Román was receiving treatment at

the Fund, he informed Supervisor José Calo ("Calo") on April 29,

2019, that he would begin physical therapy in June 2019. The next

day, Calo emailed Elizabeth Kennelly ("Kennelly"), Cape Air's

Director of Benefits, stating his intention to have lunch with

Román at the end of the week. Calo intended to inform Román during

the lunch meeting that his employment with Cape Air would be

terminated. But the lunch meeting did not materialize. So, on

June 10, 2019, Kennelly sent Román a termination letter

- 5 - retroactively effective as of May 21, 2019: "You have failed to

keep us informed of your status. We made several attempts to

contact you via telephone, email and text and we have had no

response from you. This letter is to inform you that effective

5/21/2019, your employment with Cape Air is terminated."

At the time Kennelly sent the termination letter, she

knew that Román was receiving treatment with the Fund and that he

was to be on rest until June 12, 2019. It is undisputed that from

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