Trindade v. Grove Services, Inc., No. 23-1288 (1st Cir. 2024)

United States Court of Appeals, First Circuit.

Paulo TRINDADE, Plaintiff, Appellee/Cross-Appellant, v. GROVE SERVICES, INC.; Victor Spivak, Defendants, Appellants/Cross-Appellees.

Nos. 23-1288, 23-1333

Decided: January 12, 2024

Before Montecalvo, Lynch, and Rikelman, Circuit Judges.

Irwin B. Schwartz, with whom BLA Schwartz PC was on brief, for appellants/cross-appellees. David B. Summer, with whom Law Office of David B. Summer, Alan D. Meyerson, and Law Office of Alan David Meyerson were on brief, for appellee/cross-appellant.

In Trindade v. Grove Services, Inc., the United States Court of Appeals for the First Circuit reviewed a dispute between Paulo Trindade, a former employee of Grove Services, Inc., and his former employer. Trindade had sued Grove Services for breach of contract and violations of the Massachusetts Wage Act, alleging he was underpaid on his sales commissions for the years 2014, 2015, and 2016.

Following a bench trial, the District Court for the District of Massachusetts ruled partially in favor of Trindade, awarding him $330,597 in damages. Both Trindade and Grove Services appealed the decision.

The First Circuit affirmed the district court’s judgment. It agreed with the district court’s finding that Trindade’s amended complaint, which included a claim for unpaid wages for 2016, related back to his original complaint. This relation-back made the 2016 claim timely under Massachusetts law, despite being added after the original filing.

The appellate court also concurred with the district court’s decisions regarding the damages awarded. It found that the lower court’s calculation, including amounts for late payment and underpayment of Trindade’s 2016 commission, was correct.

In summary, the First Circuit upheld the district court’s judgment in favor of Trindade, confirming the timeliness of his amended complaint and the appropriateness of the damages awarded.