Orabona v. Santander Bank, N.A.

141 F.4th 1
CourtCourt of Appeals for the First Circuit
DecidedJune 16, 2025
Docket24-1905
StatusPublished
Cited by1 cases

This text of 141 F.4th 1 (Orabona v. Santander Bank, N.A.) 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
Orabona v. Santander Bank, N.A., 141 F.4th 1 (1st Cir. 2025).

Opinion

United States Court of Appeals For the First Circuit

No. 24-1905

LORNA ORABONA,

Plaintiff, Appellant,

v.

SANTANDER BANK, N.A.,

Defendant, Appellee.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND

[Hon. Mary S. McElroy, U.S. District Judge]

Before

Gelpí, Lynch, and Thompson, Circuit Judges.

Jennifer L. Sylvia, with whom Moses Ryan Ltd. was on brief, for appellant.

Leslie D. Parker, with whom Brenna Anatone Force, Brendan F. Ryan, and Adler Pollock & Sheehan P.C. were on brief, for appellee.

June 16, 2025 LYNCH, Circuit Judge. Santander Bank, N.A. terminated

Lorna Orabona's employment as a high-earning mortgage development

officer for cause, notifying her that she had violated the

company's Code of Conduct client privacy policy. In consequence,

she was not eligible for severance benefits under its Employee

Retirement Income Security Act (ERISA) Severance Policy. Orabona

did not employ the administrative procedure under the ERISA

Severance Policy. Rather, she sued under state law in multiple

counts sounding in both tort and contract. She alleged that

Santander had terminated her employment to avoid paying her

severance benefits under the Policy. After discovery, the district

court entered summary judgment for Santander on the grounds that

Orabona's claims were expressly preempted by ERISA section 514(a),

29 U.S.C. § 1144(a).

We reject Orabona's arguments on appeal and hold that

her claims are preempted by ERISA, because all of her claims

"relate to" the Severance Policy as the court must refer to that

Policy to determine both liability and damages as to each claim,

see 29 U.S.C. § 1144(a), and, as to her claims seeking relief for

the denial of severance benefits, they "conflict[] with the

remedial scheme established by 29 U.S.C. § 1132(a)." See Cannon

v. Blue Cross and Blue Shield of Mass., Inc., 132 F.4th 86, 88

(1st Cir. 2025).

- 2 - I.

On review of a grant of summary judgment, we recite the

facts in the light most favorable to the nonmoving party,

"indulging all reasonable inferences in [Orabona's] favor, but

paying no heed to conclusory allegations, improbable inferences,

[or] unsupported speculation." Quintana-Dieppa v. Dep't of Army,

130 F.4th 1, 7 (1st Cir. 2025) (quoting McCarthy v. Nw. Airlines,

Inc., 56 F.3d 313, 315 (1st Cir. 1995) (internal quotation marks

omitted)). We draw the facts "from the record and discovery as to

[the Severance Policy]." Cannon, 132 F.4th at 88. The summary

judgment record includes Orabona's unverified complaint; Orabona's

supporting affidavit; the deposition of Santander's 30(b)(6)

witness Michael Pagano, head of Employment Relations; and an

affidavit by Santander's counsel, attaching the Santander US

Enterprise Severance Policy effective July 21, 2021 through

July 17, 2022 (the "Severance Policy"), Forms 5500 for the

Severance Policy for the years 2020 through 2022,1 a December 9,

2021 email from Santander HR to Orabona which included a link to

a summary of the 2020 Form 5500 for the Severance Policy, and the

Santander US Code of Conduct as of December 16, 2021. There is no

1 Form 5500 is an informational return used "to satisfy annual reporting requirements under Title I and Title IV of ERISA and under the Internal Revenue Code." U.S. Dep't of Lab., Form 5500 Series, https://perma.cc/J925-V6ZD.

- 3 - dispute as to the authenticity of Santander's Severance Policy and

Forms, Code of Conduct, and the December 9, 2021 email.2

A. The Termination of Orabona's Employment

Orabona's complaint states that the lawsuit "arises out

of the wrongful, unlawful actions by [Santander] in interfering

with and preventing [her] from continuing in her employment and

receiving her entitlement to employee benefits."

Orabona was hired by Sovereign Bank in 2008 as a Mortgage

Development Officer (MDO), and Santander became Orabona's employer

when it acquired Sovereign in 2013. She was "one of the top five

MDO performers in the country for Santander overall," and her

wages, which were based only on commission, were $525,000 in 2020

and $680,000 in 2021.

On or about January 18, 2022, Orabona told her

supervisor at Santander that she had an offer of employment from

Citizens Bank, "but she was still considering staying at Santander

and wanted to re-negotiate her salary." Her supervisor responded

that "he wanted [her to] stay and . . . would talk to his

supervisors and get back to her to work something out."

2 Though Orabona disputed the authenticity of and moved to strike Santander's December 9, 2021 email before the district court, the court denied her motion to strike, and Orabona did not appeal that denial, so we consider the email to be unrefuted evidence.

- 4 - On January 21, 2022, a Santander employee from Spain who

"was not [Orabona's] supervisor" and did not "even work[] in her

department," joined by a Santander HR employee and a Santander IT

employee, called Orabona and informed her that her employment was

terminated effective immediately, for cause, because she had

forwarded company emails from her company email address to her

private email address.3 Orabona's affidavit states that:

[The Santander employee] advised me that I was terminated for cause and all of my benefits, including my healthcare, were ceasing immediately. I was also advised that if I took any further actions, such as appealing my termination or applying for benefits, Santander would report to the Nationwide Multistate Licensing System ("NMLS") that I had committed misconduct thereby attempting to get my license revoked.

Santander's 30(b)(6) witness testified that "[u]sually the

manager . . . communicat[es] that the employee is being

terminated," and a member of the Employment Relations team, which

is entirely based in the United States, "support[s] that

communication, answer[s] any questions the employee may have, and

provide[s] an overview of what they can expect from a benefits

standpoint after their departure."

3 Orabona's affidavit states that she "did not accept the offer and/or start employment with Citizens Bank until January 24, 2022, after [her] termination from Santander," but Santander contests this, noting that "according to Orabona’s registration on the Nationwide Multistate Licensing System ("NMLS"), Orabona began employment as a Citizens employee on . . . January 18, 2022." Our disposition does not turn on this dispute.

- 5 - Orabona says she received no warning or initial

reprimand prior to the termination of her employment. She says

that she had only forwarded company emails "due to working remotely

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