Genzyme Defeats Planning Analyst’s Appeal in Race Bias Lawsuit

A Black former Genzyme Therapeutic Products LP senior site planning analyst failed to revive his lawsuit alleging race discrimination caused his performance rating to be unfairly lowered.

The US Court of Appeals for the First Circuit stopped short of addressing whether and when a negative job review can be an adverse employment action under federal anti-bias law. That “unresolved question” is better left “for another day,” it said.

Charles Boykin appealed a lower court’s summary judgment against him on claims under 42 U.S.C. §1981, Title VII of the 1964 Civil Rights Act, and Massachusetts civil rights law. Boykin fell short ...