Allman v. Garcia-Padilla, No. 13-2384 (1st Cir. 2015)
Annotate this CaseAfter the government of Puerto Rico changed hands in 2012, the legislature enacted a law repealing Reorganization Plan No. 1-2011 and abolished four positions that the Plan had created. The legislature also enacted other laws creating new positions that were substantially similar to the abolished positions. Several of the displaced former officials brought suit in federal court. This interlocutory appeal was from one of those suits. Plaintiff brought federal 42 U.S.C. 1983 claims, as well as Commonwealth law claims. The district granted a preliminary injunction on due process grounds that reinstated Plaintiff and vacated the political appointment of his replacement. The Puerto Rico Supreme Court subsequently issued its opinion in the nearly identical case of Diaz-Carrassquillo v. Garcia-Padilla, which confirmed the availability of relief in Commonwealth court. The First Circuit remanded with instructions to vacate the preliminary injunction, holding that, in light of the relief now available in Puerto Rico courts under Diaz-Carrasquillo and the importance of this case to the Commonwealth’s constitutional balance of powers, the rule that “no injunction ought to issue against officers of a State” except under certain circumstances applied here.
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