Ocasio-Hernandez v. Fortuno-Burset, 777 F.3d 1

Fourteen trust-service employees were terminated from the Puerto Rico governor’s mansion shortly after a new governor took office.
Termination letters gave no specific reasons, citing only statutory authority to freely dismiss trust-service employees.
Plaintiffs alleged they were fired due to opposition-party affiliation in violation of the First Amendment and related state laws.
District court initially dismissed all federal and state claims; on appeal we vacated and remanded some claims, prompting further proceedings.
On summary judgment, the district court held there was no evidence that Fortuño, Vela, Blanco, or Berlingeri knew the plaintiffs’ political affiliations or that politics motivated the terminations; the court dismissed the claims against all defendants.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants knew plaintiffs' political affiliations	Workers argue knowledge can be inferred from circumstantial evidence.	Defendants contend no direct or circumstantial evidence shows knowledge.	Summary judgment affirmed for lack of knowledge evidence.
Whether political affiliation motivated the terminations (Mt. Healthy analysis not reached)	Discrimination shown prima facie; burden shifts to show same action would occur anyway.	Defendants argue lack of evidence of motivation or knowledge.	Court affirmed dismissal on lack of evidence of knowledge and causation.
Whether Berlingeri’s knowledge was sufficient to defeat summary judgment	Knowledge of affiliations by Berlingeri could be inferred from role and timing.	Record lacked sufficient evidence of Berlingeri’s knowledge.	Affirmed on the ground of insufficient knowledge evidence for Berlingeri as well.
Whether the district court properly denied a Rule 59(e) motion to alter judgment	Disputed hearsay evidence should have been before the court.	Hearsay issue was ancillary since the judgment is being affirmed on other grounds.	Rule 59(e) denial affirmed; no reversible error identified.

Ocasio-Hernández v. Fortuño-Burset, 640 F.3d 1 (1st Cir. 2011) (standard for political discrimination and knowledge element in First Amendment claims)
Padilla-Garcia v. Guillermo Rodriguez, 212 F.3d 69 (1st Cir. 2000) (Mt. Healthy-type analysis for political discrimination; evidentiary burden)
Martínez-Vélez v. Rey-Hernández, 506 F.3d 32 (1st Cir. 2007) (circumstantial evidence can show knowledge of political affiliation)
Anthony v. Sundlun, 952 F.2d 603 (1st Cir. 1991) (timing and partisan connections can support knowledge inference)
Ruiz v. Bally Total Fitness Holding Corp., 496 F.3d 1 (1st Cir. 2007) (de novo review of summary judgment; not bound by district court’s reasoning)
Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 () (burden on causation after prima facie showing; not necessary to reach in this case)
García-González v. Puig-Morales, 761 F.3d 81 (1st Cir. 2014) (political affiliation as an employment requirement exception context)