Santiago-Diaz v. Rivera-Rivera, 793 F.3d 195

Santiago-Díaz, a PDP member, worked for Puerto Rico DOE in the Center for Special Education in Bayamón for 27 years, with supervisory roles in the Programmatic and Academic Areas.
After the PDP loss in 2008, the NPP took power in January 2009; Law 7 (March 2009) empowered broad employee dismissals at DOE.
In August 2009, Santiago was reassigned from supervising the Programmatic Area to supervising the Academic Area, while his salary remained the same.
The reassignment allegedly shifted duties to an NPP sympathizer, Orsini, and Ortiz (director) oversaw the change; López (HR) approved, Andújar (Associate Secretary) was copied on complaints; Rivera (Regional Director) empowered Ortiz and Andújar.
Santiago claimed political discrimination and humiliation, but remained in a more complex role in the Academic Area; in August 2010, he was reinstated to supervise both areas.
District court granted summary judgment; First Circuit reviews de novo and affirmed, finding no genuine issue that the reassignment or diminished duties were politically motivated or adverse.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the reassignment and diminished duties were a politically based adverse action	Santiago asserts PDP affiliation motivated the move and reduced duties.	Record shows no diminished duties and not clearly motivated by politics; administrative necessity and Law 7 provided context.	No genuine issue; not shown that reassignment was politically motivated.
Whether timing with the political transition supports discrimination	Transfer coincides with PDP-to-NPP shift suggesting motive.	Temporal coincidence alone is insufficient; other facts do not prove motive.	Timing alone insufficient to establish political discrimination.
Whether the challenged conduct (humiliation, absence inquiry) supports a First Amendment claim	Ortiz’s conduct evidences political discrimination and harassment.	Actions reflect ordinary supervisory duties and do not deter constitutional rights.	Not adequate to state a First Amendment political-discrimination claim.
Whether the district court correctly applied Mt. Healthy defense considerations	—	Court would have to consider whether action would have occurred regardless of political beliefs.	Not reached given absence of evidence of political motivation.

Mt. Healthy City Sch. Dist. Bd. of Educ. v. Doyle, 429 U.S. 274 (1977) (pretext defense for political patronage claims; same-action defense after showing motive)
Ocasio-Hernández v. Fortuño-Burset, 777 F.3d 1 (1st Cir. 2015) (standard to prove political discrimination in First Amendment context)
Ocasio-Hernández v. Fortuño-Burset, 640 F.3d 1 (1st Cir. 2011) (adverse action and motivating factor framework)
Rivera–Cotto v. Rivera, 38 F.3d 611 (1st Cir. 1994) (genuine issue of material fact for political discrimination)
Padilla-Garcia v. Guillermo Rodriguez, 212 F.3d 69 (1st Cir. 2000) (political affiliation protection for non-confidential employees)
Agosto-de-Feliciano v. Aponte-Roque, 889 F.2d 1209 (1st Cir. 1989) (en banc discussion on political discrimination standards)
Torres-Santiago v. Municipality of Adjuntas, 693 F.3d 230 (1st Cir. 2012) (timing and evidence considerations in political-discrimination claims)
Barzingus v. Wilheim, 306 F.3d 17 (10th Cir. 2010) (comparative standard for administrative actions and dispositive motions)
Adamson v. Walgreens Co., 750 F.3d 73 (1st Cir. 2014) (summary judgment standard and burden on non-movant)