Irizarry-Robles v. Rodriguez, 3:15-cv-02461

Plaintiff Alberto R. Irizarry-Robles sued Mayor Jose G. Rodriguez, two municipal officials, and the Municipality of Mayagüez alleging termination for his political beliefs in violation of the First Amendment (42 U.S.C. § 1983) and parallel Puerto Rico constitutional and tort provisions.
Defendants moved for summary judgment; Irizarry failed to file an opposition or a Local Rule 56(c) statement, so the court treated defendants' factual presentation as uncontested.
Defendants argued (1) the plaintiff's position (Special Aide II) was a trust/policymaking position permitting at-will removal, (2) qualified immunity protected municipal actors, and (3) supplemental state claims should be dismissed if federal claims failed.
The official job description for Special Aide II indicated broad discretion, policy-related duties, and work under the Mayor/administration with initiative, report drafting, coordination with agencies, investigations, and delegated signing authority.
The court applied the First Circuit two-prong test for trust positions (political nature of agency and political nature of the position) and concluded the Special Aide II role was a trust/policymaking position.
Result: federal § 1983 political-discrimination claim dismissed with prejudice; supplemental Commonwealth claims dismissed without prejudice; case ordered closed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether termination violated First Amendment political-discrimination protections	Irizarry claimed he was fired for his political beliefs (political-discrimination under § 1983)	Defendants contended the Special Aide II role was a trust/policymaking position and thus not protected by political-discrimination doctrine	Held: Position is a trust position; no First Amendment violation; federal claim dismissed with prejudice
Whether the Special Aide II position is a trust (policymaking) position	Implied argument that position was career/protected	Defendants relied on job description and claimed Irizarry knew position was trust-based	Held: Under the two-prong test the job involved policymaking discretion and broad duties; therefore trust position
Qualified immunity for Mayor Rodriguez and other officials	Irizarry sought damages against officials	Defendants asserted qualified immunity as a defense	Held: Court did not reach merit of qualified immunity because no constitutional violation was found
Whether state-law/supplemental claims survive after dismissal of federal claims	Implied that state claims could proceed	Defendants argued dismissal of federal claims warrants dismissal of supplemental claims	Held: Supplemental Commonwealth claims dismissed without prejudice for lack of federal jurisdiction

Elrod v. Burns, 427 U.S. 347 (1976) (employees with broad, ill-defined responsibilities more likely to be policymaking/trust positions)
Rosenberg v. City of Everett, 328 F.3d 12 (1st Cir. 2003) (tests for when party affiliation is appropriate for continued tenure)
Galloza v. Foy, 389 F.3d 26 (1st Cir. 2004) (government classification relevant but not dispositive in trust-position inquiry)
O'Connell v. Marrero-Recio, 724 F.3d 117 (1st Cir. 2013) (agency function prong: decisionmaking where political disagreement exists)
Mendez-Aponte v. Bonilla, 645 F.3d 60 (1st Cir. 2011) (two-prong approach evaluating agency and position political nature)
Kauffman v. Puerto Rico Tel. Co., 841 F.2d 1169 (1st Cir. 1988) (career positions as constitutionally protected property interest)
Pearson v. Callahan, 555 U.S. 223 (2009) (qualified immunity two-step framework)
Malley v. Briggs, 475 U.S. 335 (1986) (qualified immunity does not shield officials who knowingly violate law)