Santiago-Diaz v. Rivera-Rivera, No. 13-2180 (1st Cir. 2015)
Annotate this CasePlaintiff was a supervisor at the Programmatic Area of the Department of Education’s Special Education Center in Bayamon when the New Progressive Party came to power in Puerto Rico. Plaintiff claimed that, as a result of his membership in the Popular Democratic Party, he was subject to impermissible political discrimination when he was reassigned to a new position, a diminution of his supervisory responsibilities, and other adverse employment actions. The district court granted summary judgment for Defendants. The First Circuit affirmed, holding (1) Plaintiff failed to generate facts that would allow a rational jury to conclude that Plaintiff’s reassignment was an act of political discrimination or that his job responsibilities were diminished in his new position; and (2) Plaintiff’s remaining allegations of workplace discrimination were insufficient to constitute adverse employment actions.
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