Rodriguez-Reyes v. Molina-Rodriguez, 711 F.3d 49

Plaintiffs are former AIJ employees (Vega, Torres-Plaza, Rodríguez-Reyes, Fuentes-Rodríguez, Rivera-Rosado) alleging political discrimination under §1983 and Puerto Rico law.
New AIJ administration from the New Progressive Party (NPP) began after the 2008 election and assumed control in January 2009, initiating political assessment of employees.
Plaintiffs were ousted or not renewed; Vega's position eliminated, Torres cashiered, and others were not invited to return, with replacements by NPP affiliates.
Plaintiffs allege a ‘witch-hunt’ to discover political affiliations and that officials began to talk about politics after regime change.
District court dismissed federal claims for failure to plead a prima facie case of political discrimination; pendent state claims were dismissed without prejudice.
On appeal, court holds that pleading need not establish a prima facie case; plausibility under Iqbal/Twombly governs, with prima facie elements used as background to assess plausibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Role of prima facie case at pleading stage	Prima facie is evidentiary, not pleading standard.	District court correctly required prima facie pleading.	Prima facie not required at pleading; plausibility governs.
Knowledge of Molina about affiliations	Allegations show Molina knew plaintiffs' affiliations via witch-hunt and political atmosphere.	Conclusory assertions insufficient to show knowledge.	Allegations adequate to plausibly infer Molina's knowledge.
Antagonistic political affiliation of Ríos	Plaintiffs allege Ríos held high-level role in NPP administration with opposing affiliation.	Need for more specific linkage to actions.	Allegations sufficient to plead Ríos's antagonistic affiliation.
Causation: was political affiliation a motivating factor	Allegations show express political motive and lack of non-discriminatory explanations.	No direct causal proof required at pleading; need plausible causation.	Plausible inference of political animus supporting §1983 claim.
John Doe defendants	Claims should not be waived outright.	Insufficient development; prima facie not shown.	Claims against John Doe waived; remaining affirmed and remanded as to others.

Swierkiewicz v. Sorema, 534 U.S. 506 (U.S. 2002) (pleading standard is evidentiary, not prima facie.)
Twombly v. Bell Atlantic Corp., 550 U.S. 544 (U.S. 2007) (pleading requires plausibility, not mere possibility.)
Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (requiring plausible claims; context-specific analysis.)
Grajales v. Puerto Rico Ports Auth., 682 F.3d 40 (1st Cir. 2012) (pleading plausibility; prima facie elements as backdrop.)
Ocasio-Hernández v. Fortuño-Burset, 640 F.3d 1 (1st Cir. 2011) (elements used as prism for plausibility, not pleading.)
Educadores Puertorriqueños en Acción v. Hernández, 367 F.3d 61 (1st Cir. 2004) (Swierkiewicz line applied to political discrimination.)
Penalbert-Rosa v. Fortuño-Burset, 631 F.3d 592 (1st Cir. 2011) (carefully connections between officials and actions; plausibility standard.)