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Massachusetts Lie Detector Law Class Actions Reach First Circuit Over JPMorgan's AI Interview Tool

Published
Score
19

Why it matters

The First Circuit heard oral argument on July 28, 2026, in Saint Cyr v. JPMorgan Chase, where a proposed class of job applicants asks the court to revive a suit that U.S. District Judge Brian Murphy dismissed. Plaintiff Mozart Saint Cyr, a Massachusetts financial consultant, claims that JPMorgan's HireVue one-way video interview functioned as a lie detector under M.G.L. c. 149, § 19B. Murphy found the complaint did not plausibly allege that the tool was used to assess truthfulness. He also separately remanded the notice claim for lack of Article III standing. The district court decision is dated October 22, 2025.

The First Circuit has not ruled. Law360 reported that the panel appeared skeptical that the HireVue tool falls within the statute. The pending appeals address statutory aggrievement, federal standing, and when a screening tool counts as a lie detector test. A separate state-court appeal over a notice claim against AT&T Mobility is also pending. Lower courts are divided. A federal court in Massachusetts allowed a challenge to Amazon's "Workstyle Assessment" to proceed in February 2026. Plaintiff counsel Julian Diamond argued that HireVue is marketed to "scale your lie detection."

The statute bars employers from requiring or administering lie detector tests as a condition of employment, and it requires every Massachusetts job application to carry a specific written notice. Its definition reaches beyond polygraphs to devices, instruments, and written examinations used to assess truthfulness. Notice violations carry criminal penalties and civil liability. Fisher Phillips counts dozens of class actions over AI interview and assessment tools, and the litigation started with applications that lacked the required notice. Employers should audit Massachusetts application forms for compliant notice language now and review any AI screening tools against the statute's broad definition. A First Circuit decision would be the first appellate guidance on whether AI screening falls under § 19B.

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