Santana-Vargas v. Banco Santander Puerto Rico, 948 F.3d 57

Santana worked for Island Finance/Santander for ~28 years and was a branch manager when fired at age 49.
From 2009–2013 his and his branches' performance was documented as poor; formal warnings followed.
In March/April 2014 Santana was placed on a six‑month performance improvement plan (PIP) with a stated minimum score and warned of possible dismissal for failure to meet it.
Santana failed to meet the PIP minimum in April and May; he was terminated in August 2014 (replacement was 32).
District court granted summary judgment to defendants on the ADEA claim and declined supplemental jurisdiction over Puerto Rico law claims; Santana appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Prima facie ADEA showing (met expectations)	Santana contends his performance was sufficient or improved under the PIP to establish the prima facie case	Defendants point to multi‑year poor reviews and PIP failures showing he did not meet legitimate expectations	Court assumed prima facie met for caution but found no disputed material fact on pretext; summary judgment affirmed
Legitimate nondiscriminatory reason / burden shifting	Santana argues defendants' stated reason (poor performance) was pretext for age discrimination	Defendants offered documented poor performance over years as legitimate reason	Court accepted defendants' nondiscriminatory reason; burden shifted to Santana to show pretext, which he failed to do
Early termination of PIP shows pretext	Santana argues firing before six months shows defendants ignored PIP's protections	Defendants note PIP warned dismissal for failure to comply, and Santana failed in April/May—termination before six months was permitted by PIP terms	Court found no reasonable inference of age bias from early termination given documented early failures
Supplemental jurisdiction over state‑law claims	Santana preferred federal court to retain related Puerto Rico claims	Defendants did not oppose dismissal; district court declined to exercise supplemental jurisdiction after ADEA claim failed	First Circuit held remand dismissal without prejudice was within district court's discretion (no abuse)

McDonnell Douglas Corp. v. Green, 411 U.S. 792 (1973) (establishes burden‑shifting framework for discrimination claims)
Del Valle‑Santana v. Servicios Legales de Puerto Rico, Inc., 804 F.3d 127 (1st Cir. 2015) (prima facie elements and framework in this Circuit)
Meléndez v. Autogermana, Inc., 622 F.3d 46 (1st Cir. 2010) (prima facie meeting‑expectations requirement is modest)
Kouvchinov v. Parametric Tech. Corp., 537 F.3d 62 (1st Cir. 2008) (deviation from standard business practices can show pretext)
Seaco Ins. Co. v. Davis‑Irish, 300 F.3d 84 (1st Cir. 2002) (appellate deference when district court gives a cogent rationale)
United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (1966) (federal courts often dismiss state claims when federal claims are dismissed before trial)
Redondo Const. Corp. v. Izquierdo, 662 F.3d 42 (1st Cir. 2011) (district court must use informed discretion on supplemental jurisdiction)
Roche v. John Hancock Mut. Life Ins. Co., 81 F.3d 249 (1st Cir. 1996) (factors for exercising supplemental jurisdiction)