Cordero-Suarez v. Rodriguez, No. 11-1991 (1st Cir. 2012)Annotate this Case
In 1996, Cordero began working as an agent in the Internal Revenue Division of the Puerto Rico Treasury Department. Her supervisor, Rodríguez, was brother of the mayor of Mayagüez, who was head of the Popular Democratic Party's city office. Politically, Cordero affiliates with the New Progressive Party. Cordero says that on many occasions Rodríguez made disparaging comments about the NPP within her earshot. She also claims that Rodríguez took many subtle steps to inconvenience her, such as repeatedly changing her schedule and falsely claiming that she left early so he could deduct ten minutes of pay from her check. She also claims that Rodríguez "physically and verbally assaulted" her and that there were several other incidents, including incidents after she received a transfer. The district court rejected her suit under 42 U.S.C. 1983. The First Circuit affirmed, finding the allegations “troubling” but untimely. Although the continuing violation doctrine can render otherwise time-barred conduct actionable, the doctrine still requires some anchoring violation within the limitations period, and none of Rodríguez's post-transfer conduct meets that test. Cordero's transfer occurred more than a year before she filed suit, and none of Rodríguez's conduct within that one-year limitations period was actionable.