Mendez-Aponte v. Commonwealth of Puerto Rico, 645 F.3d 60

Méndez-Aponte served as Assistant Secretary of State for Protocol Affairs in Puerto Rico from 2001–2006 and was fired in August 2005 amid allegations he was involved in selling Iraqi dinars.
Plaintiffs allege the firing was due to his political affiliation, a claim the district court denied on summary judgment.
The district court granted summary judgment for Bonilla, finding Méndez-Aponte held a trust position with no First Amendment protection.
Rule 11 sanctions were imposed on Méndez-Aponte's attorneys for failures in disputing uncontested facts and for a sloppy, inconsequential filing.
Ménde-Aponte and attorneys appealed, challenging summary judgment and sanctions; the First Circuit affirmed both.
The court used the job description to determine whether political affiliation was an appropriate qualification and held it was for this position.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether political affiliation is a permissible basis for dismissal	Méndez-Aponte argues affiliation protected by First Amendment	Bonilla contends affiliation is an appropriate requirement for the role	Affirmed: affiliation permissible; position is not protected
Whether the district court properly granted summary judgment	Plaintiffs dispute the facts and show triable issues	Record shows no genuine dispute; plaintiff failed to show prima facie case	Affirmed: no genuine dispute; Bonilla entitled to judgment as a matter of law
Whether sanctions under Rule 11 were proper	Sanctions improper due to contested issues	Opposition was evasive and frivolous; not colorably meritorious	Affirmed: sanctions upheld; filings violated Rule 11(b)
Whether Méndez-Aponte’s job classification as a trust position affected First Amendment protection	Trust status may bear on protection	Trust position allows party affiliation as a criterion	affirmed: trust position not protected; allowed to be based on political affiliation
What evidence standard governs the summary judgment record	Denials should controvert facts with record evidence	Bonilla’s uncontested facts supported granting summary judgment	affirmed: district court properly relied on uncontested facts

Branti v. Finkel, 445 U.S. 507 (1980) (political affiliation may be a valid job qualification in some settings)
Ocasio-Hernández v. Fortuño-Burset, 640 F.3d 1 (1st Cir. 2011) (elements for political discrimination claim)
Hadfield v. McDonough, 407 F.3d 11 (1st Cir. 2005) (two-prong test for political-appointment decisions)
Duriex-Gauthier v. López-Nieves, 274 F.3d 4 (1st Cir. 2001) (two-prong framework for judging polit. affiliation as a criterion)
Olmeda v. Ortiz-Quiñonez, 434 F.3d 62 (1st Cir. 2006) (agency decisions on goals/implementation involve political discretion)
Flynn v. City of Boston, 140 F.3d 42 (1st Cir. 1998) (policymaking duties indicate affiliation allowed)
Uphoff-Figueroa v. Alejandro, 597 F.3d 423 (1st Cir. 2010) (spokesperson-like duties suggest policymaking role)
Roldán-Plumey v. Cerezo-Suárez, 115 F.3d 58 (1st Cir. 1997) (position function informs policymaking analysis)
Jiménez Fuentes v. Torres Gaztambide, 807 F.2d 236 (1st Cir. 1986) (en banc decision relevant to profiling duties)