Lopez-Santos v. Metropolitan Security Services, No. 18-1694 (1st Cir. 2020)Annotate this Case
The First Circuit affirmed the order of the district court granting summary judgment in favor of Walden Security and dismissing the suit brought by Plaintiffs for statutory separation pay pursuant to Puerto Rico Law 80, holding that Plaintiffs had no remedy pursuant to Law 80.
Plaintiffs had served as court security officers for the District of Puerto Rico for thirty-two years when Walden Security assumed the federal contract to provide courthouse security services. Walden refused to hire Plaintiffs because they lacked certification from a law enforcement training academy. Plaintiffs subsequently filed the instant lawsuit for statutory separation pay. The district court granted summary judgment for Walden, reasoning that Law 80 did not apply to Plaintiffs' claims. On appeal, Plaintiffs argued that the district erred in ignoring the theory of liability that Plaintiff's advanced: Puerto Rico's common law successor employer doctrine. The First Circuit affirmed, holding (1) the district court misconstrued Plaintiffs' theory of liability; but (2) the successor employer doctrine was clearly inapplicable to Plaintiffs' case.