Casiano-Montanez v. State Ins. Fund Corp., No. 12-1453 (1st Cir. 2013)
Annotate this CasePlaintiffs were several dismissed or demoted employees of the State Insurance Fund Corporation, a public corporation that administered Puerto Rico's workers' compensation program. Before the adverse employment actions took effect, Plaintiffs requested informal administrative hearings before the Corporation. Plaintiffs then filed administrative appeals before the Corporation's board of appeals. The board had not acted on the appeals when Plaintiffs sued the Corporation and several of its officers in the U.S. district court, alleging political discrimination and due process violations stemming from adverse employment actions. The district court abstained under Younger v. Harris and dismissed Plaintiffs' claims, finding that Plaintiffs voluntarily engaged the wheels of an administrative procedure before filing an action in federal court. The First Circuit Court of Appeals reversed, holding (1) the district court erred in abstaining based on Younger, and dismissal was not the remedy in any event; and (2) a stay of the federal proceedings was appropriate in this case pending the Puerto Rico Supreme Court's decision in Gonzales Segarra v. State Ins. Fund Corp.
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