Grajales v. Puerto Rico Ports Authority

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The First Circuit affirmed the district court's grant of summary judgment to the Puerto Rico Ports Authority (the PRPA) on Plaintiffs' suit alleging that the PRPA violated the First Amendmen and Puerto Rico law by terminating Plaintiff's employment, holding that Plaintiffs' claims were barred by res judicata. Daniel Grajales, his wife, their children brought this suit under 42 U.S.C. 1983 and Puerto Rico law against the PRPA alleging that Grajales was transferred to a new job location and subsequently terminated from his employment because of both his political affiliation and his reporting of alleged safety violations by PRPA employees. Just before Grajales filed his federal complaint, the Secretary of Labor and Human Resources of Puerto Rico filed a civil complaint against the PRPA in the Puerto Rico Court of First Instance, which entered judgment for the PRPA. The PRPA moved for summary judgment in the federal case on res judicata grounds in light of the Court of First Instance's ruling. The district court ruled in favor of the PRPA. The First Circuit affirmed, holding (1) the district court properly found that the two actions shared a "common nucleus of operative fact"; (2) Grajales's claims were barred by res judicata; and (3) the derivative claims of Grajales's family members necessarily failed. View "Grajales v. Puerto Rico Ports Authority" on Justia Law