On Friday, January 20, the First Circuit reversed the lower court's denial to hear an employment classification suit. At issue was an action brought against the state by the Massachusetts Delivery Association ("MDA"). The First Circuit ruled that although MDA is currently facing litigation in state court, this fact does not bar MDA from bringing a separate action against the state in federal court.
MDA members are facing lawsuits in state court brought by independent contractors who allege they were misclassified. After MDA filed a separate suit in federal court, the lower court refused to take up the action, stating MDA was an alter ego of the defendants appearing in state court. Therefore, pursuant to the Younger doctrine, MDA was precluded from bringing an action.
In its opinion, the First Circuit's three-judge panel ruled that the lower court misapplied the Younger doctrine. The Younger doctrine bars federal courts from hearing cases brought by parties who are simultaneously facing claims in state court. According to the First Circuit opinion, the Younger doctrine was intended to prevent interference among court proceedings, however, given that the federal suit would not interfere with the state proceeding, the First Circuit provided that the doctrine did not apply. The First Circuit also stated given the uncertainty as to whether MDA is a party to the state proceeding, it would be unfair to preclude a separate federal action.