Summary
In this Opinion and Order, the United States District Court for the District of Puerto Rico grants summary judgment to the Puerto Rico Aqueduct and Sewer Authority and two individual defendants in a political-discrimination action arising from the plaintiff’s termination. The court analyzes the alleged workplace altercation, the collective bargaining agreement’s disciplinary procedures, the investigation and termination decision, and the plaintiff’s evidence of political animus. The document indicates that the court concluded the plaintiff failed to establish a triable claim of First Amendment political discrimination and addressed related qualified-immunity and Puerto Rico-law claims.
Court
United States District Court for the District of Puerto Rico
Jurisdiction
United States District Court for the District of Puerto Rico
Decision date
April 16, 2026
Docket number
Civil No. 23-1509 (RAM)
Disposition
other
Questions Presented
- Whether the summary judgment record permitted a reasonable jury to find that González-Ortiz's termination was causally connected to political animus in violation of the First Amendment.
- Whether the individual defendants could be liable under a cat's-paw theory based on alleged manipulation of information relied upon by the neutral termination decisionmaker.
- Whether PRASA established under Mt. Healthy that it would have terminated González-Ortiz for nondiscriminatory reasons regardless of his political beliefs.
- Whether the court should exercise supplemental jurisdiction over the remaining Puerto Rico constitutional and statutory claims after dismissing all federal claims.
Holdings
- Plaintiff failed to establish a prima facie political-discrimination claim because the summary judgment record did not show that the ultimate decisionmaker knew his political affiliation or acted with political animus, and plaintiff lacked evidence connecting the termination to politically discriminatory motivation.
- Plaintiff could not proceed under a cat's-paw theory because he presented no competent evidence that the individual defendants manipulated information relied upon by López-Faría or that any such manipulation was a proximate cause of the termination.
- Even assuming plaintiff established a prima facie political-discrimination claim, PRASA proved by a preponderance of the evidence that it would have terminated him for nondiscriminatory reasons regardless of his political beliefs.
- The court declined to exercise supplemental jurisdiction over the remaining Puerto Rico constitutional and Civil Code claims after dismissing all claims within its original jurisdiction and dismissed those claims without prejudice.
Court Document
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