The case was a 42 U.S.C. § 1983 suit brought by a municipal consortium employee who claimed his employer retaliated against him after he reported alleged manipulation of program data to inflate compliance figures and secure additional federal Workforce Investment Act funds, asserting violations of his First Amendment free speech rights and Fifth Amendment due process rights, plus supplemental claims under Puerto Rico law. The district court granted the defendants' motion for summary judgment and dismissed the federal claims with prejudice. It held that the plaintiff's statements were made pursuant to his official duties as MIS director and interim director rather than as a private citizen, so they were not protected speech under Garcetti v. Ceballos, and that the due process allegations failed to identify any conscience-shocking conduct or protected liberty interest. The court then declined supplemental jurisdiction and dismissed the Puerto Rico claims without prejudice.
The case involved a former adjunct and assistant law professor at the University of Puerto Rico who sued the university and several officials under Title VII for sex discrimination and retaliation, and under 42 U.S.C. § 1983 for due process violations, after her request for a one-year extension of her probationary period was denied. The plaintiff alleged that comments criticizing her handling of an incident between a male colleague and a pregnant student reflected gender stereotypes and that officials reversed a favorable recommendation after she complained of discrimination. The court granted the defendants' motion to dismiss, holding that the complaint failed to state plausible Title VII claims because the allegations did not show discrimination based on sex or protected activity and that the § 1983 claim failed because the plaintiff had not identified a protected liberty or property interest requiring due process protections. The court declined to exercise supplemental jurisdiction over the remaining Puerto Rico law claims and dismissed them without prejudice.
Plaintiff Jenise Canman brought a Section 1983 equal protection claim against the Puerto Rico Real Estate Examining Board, its members, various state officials including former and current Secretaries of State, and Test Innovations Inc., alleging that she was disadvantaged and failed on her real estate licensing exam because she took it in English as a non-local New York native. She relied heavily on a prior similar case from two decades earlier but made no specific factual allegations of personal involvement by any current individual defendant in discriminatory conduct. The court granted the defendants' motions to dismiss, holding that the complaint failed to state a plausible claim under the Iqbal/Twombly standard, that many defendants lacked any connection to the events or were entitled to Eleventh Amendment immunity in their official capacities, and that the prior litigation did not establish liability for the present defendants. State-law claims against Test Innovations were dismissed without prejudice for lack of supplemental jurisdiction.
The case involved an employee, Victor Ortiz, who was discharged by UPS and whose union pursued arbitration, resulting in an award upholding the discharge. Ortiz, acting individually after the union declined to challenge the award, sought judicial review in court. The court granted UPS's motion for summary judgment, dismissing the petition because an individual employee lacks standing to challenge an arbitration award under a collective bargaining agreement unless there is evidence of fraud, deceit, or breach of the union's duty of fair representation, none of which were alleged.
This case involved a motion for reconsideration of an order denying dismissal of supervised release revocation proceedings against defendant Migdalia Collazo-Castro. The defendant argued that the arrest warrant issued before her supervised release term expired was invalid under the Fourth Amendment because it lacked an oath or affirmation, and that the First Circuit's rejection of fugitive tolling in United States v. Hernández-Ferrer required dismissal. The court held that 18 U.S.C. § 3583(i) allows jurisdiction to extend beyond the term's expiration as long as a warrant or summons issues beforehand, and that the statute does not require the warrant to be supported by sworn facts. It adopted the reasoning of the Fifth, Eleventh, and Fourth Circuits that the Warrant Clause does not apply to such warrants, which often address minor supervision violations rather than criminal offenses. The motion for reconsideration was therefore denied.
The case involved a former receptionist at the Puerto Rico Governor's Mansion suing the governor and other officials under 42 U.S.C. § 1983, alleging that her termination after the 2008 election was due to her affiliation with the Popular Democratic Party in violation of her First Amendment rights, along with denial of Fourteenth Amendment due process and various state law claims. The defendants moved to dismiss, contending that the complaint failed to meet pleading standards under Ashcroft v. Iqbal and that the position lacked a protected property interest. The court granted the motion, holding that the allegations were generic and conclusory rather than plausibly stating a claim for political discrimination or due process, as the role was classified as a trust position without expectancy of continued employment. The state law claims were dismissed without prejudice.