Medina & Medina v. Puerto Rico
2011 U.S. Dist. LEXIS 24009
D.P.R.2011Background
- Medina filed a charge with the EEOC on March 18, 2008 and received a Right-to-Sue notice on April 8, 2009.
- Medina, his wife Ramirez, and their Conjugal Partnership sued the Commonwealth, OAT, and John/Richard Doe entities in July 2009.
- Medina alleges wrongful adverse personnel action, due process violations, and ADA-based damages arising from supervision and hearing delays.
- OAT was previously dismissed for failure to serve process within 120 days; Commonwealth and unnamed defendants remained.
- Plaintiffs also asserted claims under Puerto Rico Civil Code Articles 1802 and 1803 for emotional distress.
- Defendants moved to dismiss on grounds of sovereign immunity, statute of limitations, and lack of cognizable Section 1983 claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ADA claim barred by Eleventh Amendment immunity | Medina seeks monetary relief under Title I of the ADA. | Commonwealth immune; no waiver for monetary damages. | ADA claim dismissed with prejudice |
| Section 1983 claim against Commonwealth permissible | Medina asserts due process violation under color of state law. | Commonwealth not a 'person' under §1983; immunity applies. | Section 1983 claim dismissed |
| Supplemental jurisdiction over Puerto Rico Civil Code claims | Articles 1802/1803 claims arise from same nucleus of federal claims. | No federal claim remaining; decline jurisdiction. | Dismissed without prejudice |
Key Cases Cited
- Correa-Martinez v. Arrillaga-Belendez, 903 F.2d 49 (1st Cir. 1990) (standard for resolving motion to dismiss; accept pleadings as true)
- Bd. of Tr. of Univ. of Ala. v. Garrett, 531 U.S. 356 (U.S. 2001) (Congress cannot abrogate States' immunity for monetary ADA claims)
- Will v. Michigan Dept. of State Police, 491 U.S. 58 (U.S. 1989) (states/officials acting in official capacity not 'persons' under §1983)
- Diaz-Fonseca v. P.R., 451 F.3d 13 (1st Cir. 2006) (standards for waiver of sovereign immunity in federal court)
- Arecibo Community Health Care Inc. v. P.R., 270 F.3d 17 (1st Cir. 2001) (waiver via participation in federal programs requires express language)
- Pennhurst State School & Hosp. v. Halderman, 465 U.S. 89 (U.S. 1984) (limitations on state immunity and where suit may be brought)