Reyes-Perez v. State Ins. Fund Corp.
When control of the Puerto Rican government changes parties, the political party assuming office often terminates the employment of public employees affiliated with the party going out of power and fills the vacancies with its own members. Plaintiff, a Popular Democratic Party (PDP) activist, was employed with a trust position at Puerto Rico’s State Insurance Fund Corporation (SIFC) while the PDP was in power. Plaintiff was moved into a career position at the SIFC when it became clear the opposing party would win an upcoming election. Had Plaintiff remained in a trust position, his employment could have been terminated without violating the First Amendment. A subsequent audit of employees performed by the new administration revealed that Plaintiff’s appointment did not conform with Puerto Rican law. Plaintiff’s reclassification to a career position was subsequently annulled, and he was dismissed. Plaintiff filed suit against SIFC and other defendants, alleging that he was terminated because of his political association in violation of the First and Fourteenth Amendments. The district court concluded that Defendants were entitled to summary judgment under the Mt. Healthy doctrine. The First Circuit affirmed, holding that Plaintiff failed to produce any evidence that undermined Defendants’ proffered nondiscriminatory reasons for his reclassification and later termination. View "Reyes-Perez v. State Ins. Fund Corp." on Justia Law