Rodriguez-Reyes v. Molina-Rodriguez, No. 12-1647 (1st Cir. 2013)
Annotate this CasePlaintiffs were former employees of the Puerto Rico Administration of Juvenile Institutions. After an election that produced a regime change, Plaintiffs were ousted from their positions, notwithstanding solid qualifications and positive evaluations. Plaintiffs sued several government defendants, invoking 42 U.S.C. 1983 and alleged discrimination based on political affiliation in violation of the First Amendment. Plaintiffs also lodged pendent claims under Puerto Rico law. The district court ruled that the complaint failed to state a claim for relief because it did not assert facts sufficient to establish a prima facie case of political discrimination. The First Circuit Court of Appeals reversed in part, holding (1) the prima facie case is not the appropriate benchmark for determining whether a complaint has met the plausibility standard under Bell Atlantic v. Twombly; (2) the factual allegations in Plaintiffs' complaint, taken as true, state plausible section 1983 claims for political discrimination with respect to two of the defendants; and (3) the pendent claims against those two defendants, which were dismissed without prejudice when the district court declined to exercise supplemental jurisdiction, must be reinstated. Remanded.
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