Simas v. First Citizens'

Case Date: 03/02/1999
Court: United States Court of Appeals
Docket No: 98-1450

UNITED STATES COURT OF APPEALS
FOR THE FIRST CIRCUIT


No. 98-1450

VICTOR E. SIMAS,

Plaintiff, Appellant,

v.

FIRST CITIZENS' FEDERAL CREDIT UNION
AND BARBARA M. W. SILVA,

Defendants, Appellees.




APPEAL FROM THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

[Hon. Robert B. Collings, U.S. Magistrate Judge]



Before

Torruella, Chief Judge,

Aldrich and Cyr, Senior Circuit Judges,






Philip N. Beauregard, with whom Law Offices of Beauregard & Burkewas on brief for appellant.
Michael P. Duffy, with whom Harvey Weiner and Peabody & Arnold LLPwere on brief for appellees.




March 2, 1999



CYR, Senior Circuit Judge. Victor E. Simas appeals the
district court judgment which dismissed his complaint charging
First Citizens' Federal Credit Union ("Citizens") and its president
and CEO, Barbara M.W. Silva, with violating the "whistleblower"
provisions of the Federal Credit Union Act, 12 U.S.C.  1790b(a)
(FCUA or "the Act"), by retaliating against him for having informed
the National Credit Union Administration ("NCUA") that Citizens,
notwithstanding its longstanding policy, had made a suspect
commercial loan to a member of its board of directors. We vacate
the district court judgment and remand for further proceedings.
I
BACKGROUND
The district court opinion thoroughly explicates the
factual background underlying the present claim. See Simas v.
First Citizens' Fed. Credit Union, 996 F. Supp. 76 (D. Mass. 1998).
Accordingly, we restrict our opening recitation to the essentials.
At all relevant times, Simas was a vice-president under
Silva's supervision, with primary responsibility for all delinquent
loan collections. In September 1993, Simas learned that Silva's
friend, Louis Xifiras, was about to default on an undersecured
commercial loan with an outstanding balance approximating $831,000.
Simas considered the circumstances surrounding the 1990 loan to
Xifiras suspicious. For one thing, Silva herself had arranged the
loan, the largest in Citizens' history, even though Xifiras was
serving on the Citizens board of directors at the time and intended
to use the proceeds to acquire commercial real estate. Citizens
had a longstanding policy against making commercial loans.
Moreover, several Board members expressed concern that the
$1,030,000 real estate appraisal, prepared by an appraiser selected
by Xifiras, was inflated. Furthermore, Xifiras and Lisa Grace,
Silva's daughter and Citizens' senior vice-president for mortgage
loans, were rumored to be involved in an extramarital affair.
Finally, Ms. Grace personally presented the Xifiras loan
application for Board approval.
Simas alerted Silva to his concerns, then asked Citizens'
internal auditor to conduct an investigation. The auditor
declined. When Simas persisted, the auditor complained to Silva.
Simas thereafter informed the auditor that if she chose not to
investigate internally, he might be forced to report his concerns
to the NCUA or the press.
In October 1993, Silva sent Simas a memorandum advising
that his repeated "irrational" and "aggressive" verbal harangues
about the Xifiras loan were causing the internal auditor "emotional
distress." She characterized Simas' announced intention to contact
the NCUA or the press as "threats to the credit union," and his
concerns about the Xifiras loan as totally unwarranted. She
suggested that Simas was making trouble because he was unhappy with
his own working conditions and she explicitly warned that he would
be terminated immediately if the "verbal harassments [or]
unwarranted charges or threats" occurred again. Shortly
thereafter, Silva removed Simas from all responsibility for the
Xifiras loan. Following this "final warning" from Silva, Simas was
informed by Citizens' senior vice-president that he believed Silva
should have fired Simas for "stirring [up]" the Xifiras matter.
After Xifiras defaulted on the Citizens loan and declared
bankruptcy, the commercial real estate securing the loan was
appraised at $538,000. As required by law, Silva reported the loss
to the NCUA. Fearing for his job in the event he chose to pursue
the Xifiras matter internally, Simas promptly reported his concerns
to the FBI and NCUA.
Thereafter, Simas "experienced an abrupt and substantial
change in the way that he was treated by [Citizens]." Coworkers
shunned him, socially and professionally. Citizens disapproved his
car loan application for the first time ever. Although Citizens
ultimately approved his education loan application, it did so over
Silva's active opposition. Simas was stripped of many work-related
privileges consistently accorded him in the past; including (1)
attending board of directors meetings, (2) supervising employees in
the credit department, (3) approving credit-card applications, (4)
personal access to the file vault, and (5) serving as Citizens'
acting president in Silva's absence. Silva also refused to
consider Simas' request for promotion to a vacant vice-presidency,
removed him as network administrator, denied him permission to
attend a business-related seminar, and refused his request for a
cellular phone. These adverse employment actions were
unprecedented.
In January 1994, the NCUA conducted its annual audit of
Citizens, devoting an "unusual" amount of time to consultations
with Simas. Its audit report noted "the presence of adverse
conditions and trends [which] [i]f left unresolved . . . will
jeopardize the financial condition and/or operations of
[Citizens]." The NCUA found that the Xifiras loan had been made
"without the support of a comprehensive written Member Business
Loan program" and that it was improperly preferential in its terms
and conditions to a compensated member of the board of directors.
The NCUA cited Citizens for allowing Xifiras to engage his own
appraiser, directed Citizens to cease making business loans to its
members, and ordered that it notify its surety bond carrier of all
regulatory violations. Citizens' board of directors accepted the
NCUA report. Thereafter, the NCUA requested that several Citizens'
directors resign, including Silva.
In March 1994, Citizens' new internal auditor recommended
that Simas start looking for another job. After locating a lesser
paying job at another bank, on May 2 Simas submitted his
resignation to Citizens, effective May 13. Silva, however, made
the resignation effective immediately, and directed that Simas be
escorted from the credit union premises in full view of his
coworkers, several of whom questioned him about the reason for the
unprecedented treatment. In reporting Simas' accelerated
"resignation" to the NCUA, Silva characterized Simas as "a
disgruntled employee" with access to confidential information.
Later, she defined the term "disgruntled employee" as including one
who might come into work and shoot his fellow workers.
In due course Simas brought suit against Citizens and
Silva in federal district court, alleging violations of the FCUA
"whistleblower" provisions, see 12 U.S.C.  1790b(a), together with
several pendent state-law claims, including wrongful termination,
defamation, and tortious interference with an advantageous
relationship. Following discovery, both defendants moved for
summary judgment on all claims.
The district court granted summary judgment on the FCUA
claim, concluding that Simas had not generated a trialworthy
dispute as to whether the treatment accorded him after September
1993 was sufficiently adverse to constitute either a "constructive
discharge" or "discriminat[ion] . . . with respect to compensation,
terms, conditions, or privileges of employment," within the meaning
of section 1790b(a). Finally, the pendent state-law claims were
dismissed for lack of supplemental jurisdiction. See 28 U.S.C. 
1367(c)(3).
II
DISCUSSION
A. The Statutory Framework
One of several federal "whistleblower" statutes, the FCUA
provides in pertinent part:
No insured credit union may discharge or
otherwise discriminate against any employee
with respect to compensation, terms,
conditions, or privileges of employment
because the employee (or any person acting
pursuant to the request of the employee)
provided information to the [National Credit
Union] Board or the Attorney General regarding
any possible violation of any law or
regulation by the credit union or any
director, officer, or employee of the credit
union.

12 U.S.C.  1790b(a)(1). Should a federal credit union violate
section 1790b, the aggrieved employee may bring suit for
compensatory damages and "other appropriate actions to remedy any
past discrimination." Id.  1790b(c).
In according safeguards against retaliation to credit
union employees who report potential irregularities, Congress
intended to "enhance the regulatory enforcement powers of the
depository institution regulatory agencies to protect against
fraud, waste and insider abuse." H.R. Rep. No. 101-54(I), at 308
(1989), reprinted in 1989 U.S.C.C.A.N. 86, 103-04. Since the case
law interpreting section 1790b itself is extremely sparse, however,
the courts have looked to case law construing comparably-phrased
anti-retaliation provisions in other federal employment-
discrimination statutes, such as Title VII, 42 U.S.C.  2000e etseq., the Americans with Disabilities Act (ADA), id.  12101 etseq., and the Age Discrimination in Employment Act (ADEA), 29
U.S.C.  621 et seq., as well as other federal whistleblower
statutes, such as the False Claims Act (FCA), 31 U.S.C.  3730(h),
the Safety Transportation Assistance Act (STAA), 49 U.S.C. 
31105(a)(1)(A), and FIRREA  1831j(a)(1) (providing  1790b-type
coverage to employees of all "insured depository institutions"
"with respect to . . . the terms, conditions, or privileges of
employment"). We follow their lead. See Larou v. Ridlon, 98 F.3d
659, 663 n.6 (1st Cir. 1996).
B. Burdens of Proof
Many of these federal anti-retaliation statutes require
the claimant to make a three-part prima facie showing that: (1)
the claimant engaged in the protected activity (e.g., filed a
complaint or reported information to the government); (2) the
defendants subjected the claimant to some materially adverse
employment action, and (3) a causal connection existed between the
protected activity and the adverse action. Cf. BSP Trans, Inc. v.
United States Dep't of Labor, 160 F.3d 38, 46 (1st Cir. 1998) (STAA
whistleblower provision); Hernandez-Torres v. Intercontinental
Trading, Inc., 158 F.3d 43, 47 (1st Cir. 1998) (Title VII
retaliation); Hodgens v. General Dynamics Corp., 144 F.3d 151, 161
(1st Cir. 1998) (Family and Medical Leave Act). Even under these
analogous statutes, however, "[t]he [claimant's] initial burden to
establish a prima facie case of discrimination is 'not onerous' .
. . [and] '[a]ll that is needed is the production of admissible
evidence which, if uncontradicted, would justify a legal conclusion
of discrimination.'" Brennan v. GTE Gov't Sys. Corp., 150 F.3d 21,
26 (1st Cir. 1998) (emphasis added; citation omitted); see alsoTexas Dep't of Community Affairs v. Burdine, 450 U.S. 248, 253-54
(1981).
Under yet other anti-retaliation statutes, moreover, the
claimant's prima facie burden on the third or "causation" element
is further eased, so as to require only a showing that the
protected activity was a "contributing factor" in the adverse
action, not necessarily its substantial or motivating cause. SeeFrobose v. American Sav. and Loan Ass'n of Danville, 152 F.3d 602,
612 (7th Cir. 1998) (FIRREA  1831j(a)(1)). Indeed, Citizens and
Silva acceded to the latter prima facie standard below, see Simas,
996 F. Supp. at 86, and we accept their concession in addressing
the merits on appeal. See, e.g., Clean Harbors Envtl. Servs., Inc.v. Herman, 146 F.3d 12, 22 (1st Cir. 1998) ("Both parties have
accepted this [allocation of the BOP] as the standard and we do not
reexamine it.").
Once the claimant makes a prima facie showing, a
presumption of retaliation arises and the burden shifts to the
defendants. With respect to the former category of anti-
retaliation statutes, see supra Section II.B, 1, only the burden
of production passes to defendants, i.e., requiring them merely to
articulate