López-Santos v. Metro. Sec. Servs., Inc., 320 F. Supp. 3d 338

In Sept. 2015 the U.S. Marshals Service (USMS) awarded a contract to Walden Security to provide armed Court Security Officers (CSOs) for federal courthouses in Puerto Rico; the contract set a minimum qualification: completion of a certified law‑enforcement academy or a USMS‑recognized waiver.
Plaintiffs Rafael López‑Santos and Erasmo Domena‑Ríos had worked as CSOs for Akal (the prior contractor) for ~32 years but lacked the specified academy certificates.
Walden held town halls and offered employment to Akal CSOs conditioned on meeting the contract's qualification requirements; Walden informed López and Domena they were ineligible because they lacked certificates.
Plaintiffs were informed their services would not be required as of December 1, 2015; Walden did not request USMS waivers that might have preserved their employment despite no certificates.
Plaintiffs sued under Puerto Rico Law 80 seeking statutory separation pay for wrongful discharge; both parties filed cross‑motions for summary judgment and agreed no material facts were in dispute.
The court framed the dispute as a legal question whether Law 80 applied given Walden’s status and whether Walden was a successor employer under Article 6 of Law 80.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Law 80 applies because Walden was plaintiffs' employer	López & Domena contend they were effectively displaced by Walden and entitled to Law 80 protections	Walden argues it never employed plaintiffs; Law 80 applies only to employer‑employee relationships	Court held Law 80 inapplicable because Walden never employed plaintiffs; plaintiffs concede they were not Walden employees
Whether Walden is a "successor" employer under Law 80 Article 6 (liability on business transfer)	Plaintiffs argue Walden succeeded Akal in providing courthouse security and thus should be liable as successor employer	Walden contends there was no transfer/acquisition of a going business—USMS simply awarded a new contract—so Article 6 does not apply	Court held Walden is not a successor: no business acquisition occurred; Article 6 inapplicable

Celotex Corp. v. Catrett, 477 U.S. 317 (summary judgment burden and standard)
Hoyos v. Telecorp Commc'ns, Inc., 488 F.3d 1 (1st Cir. 2007) (Law 80 wrongful discharge framework)
Quality Cleaning Prod. R.C., Inc. v. SCA Tissue N. Am., LLC, 794 F.3d 200 (1st Cir. 2015) (choice of substantive law in diversity actions; Puerto Rico law applies)
Alvarado‑Rivera v. Oriental Bank & Tr., 914 F. Supp. 2d 198 (D.P.R. 2012) (analysis of successor‑employer concept under Law 80)
Rodríguez v. Exec. Airlines, Inc., 180 F. Supp. 3d 129 (D.P.R. 2016) (defining successorship as transfer of business ownership)