Rios-Pineiro v. United States
2013 WL 1502187
1st Cir.2013Background
- Ríos-Piñeiro, a USPS contract employee for 28+ years, was terminated after inspectors alleged mail theft and found a $5 bill with their mark, plus fluorescent powder on him.
- PSBCA conducted an evidentiary proceeding and concluded Ríos breached his contract by stealing mail; USPS termination was upheld.
- Ríos brought a Federal Tort Claims Act action in the District of Puerto Rico asserting claims including negligent supervision, invasion of privacy, and malicious prosecution.
- A magistrate judge recommended dismissing some FTCA claims; the district court adopted, and later granted summary judgment on remaining claims, incorporating PSBCA findings.
- Ríos appealed, challenging the district court’s use of the PSBCA findings and the merits of the FTCA claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether collateral estoppel applies to PSBCA findings | Ríos contends PSBCA findings should not preclude FTCA relitigation. | Government argues PSBCA findings are final and binding as collateral estoppel. | PSBCA findings preclude relitigation of factual issues. |
| Malicious prosecution under Puerto Rico law | Ríos claims lack of probable cause and malice; PSBCA factual findings do not resolve all elements. | PSBCA findings show theft and probable cause; malice not needed for FTCA if probable cause exists. | District court proper; PSBCA findings support probable cause element. |
| Negligent supervision claim under Puerto Rico law | Ríos asserts negligent supervision theory with no developed argument. | Claim inadequately briefed and thus waived. | Waived; no genuine dispute presented. |
| Invasion of privacy under Puerto Rico constitution | Search violated privacy rights; factual dispute about consent. | Consent to the search defeats claim; no contrary evidence in record. | Summary judgment proper; consent defeats invasion of privacy claim. |
Key Cases Cited
- Parklane Hosiery Co. v. Shore, 439 U.S. 322 (1979) (establishes collateral estoppel doctrine for final judgments)
- Mihos v. Swift, 358 F.3d 91 (1st Cir. 2004) (collateral estoppel respected in First Circuit when criteria satisfied)
- Astoria Fed. Sav. & Loans Ass'n v. Solimino, 501 U.S. 104 (1991) (finality of administrative determinations for issue preclusion)
- United States v. Utah Const. & Min. Co., 384 U.S. 394 (1966) (courts enforce repose when agency acts in judicial capacity)
- Bath Iron Works Corp. v. Director, Office of Workers' Comp. Programs, U.S. Dep't of Labor, 125 F.3d 18 (1st Cir. 1997) (preclusion of administrative findings via collateral estoppel)
- Monarch Life Ins. Co. v. Ropes & Gray, 65 F.3d 973 (1st Cir. 1995) (four-factor test for applying collateral estoppel)
- Abreu v. United States, 468 F.3d 20 (1st Cir. 2006) (FTCA claim compatibility with local tort rules)