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Boateng v. Interamerican University
Citations: 36 F. Supp. 2d 60; 1998 U.S. Dist. LEXIS 21251; 1998 WL 983341Docket: CIV. 96-1060CCC
Court: District Court, D. Puerto Rico; December 9, 1998; Federal District Court
Dr. Peter Boateng filed a lawsuit against Interamerican University and several officials, alleging violations of Title VII of the Civil Rights Act due to race and nationality discrimination, breach of contract, and other Puerto Rico law claims. Boateng, a black professor from Ghana, claims his tenure was denied based on discriminatory factors, leading to an extended probationary period instead of a permanent contract. Additionally, he asserts that the university retaliated against him for filing discrimination charges, including unfounded plagiarism allegations. The defendants moved to dismiss the case, arguing that a related state court case involving the same parties and claims had been resolved in their favor. Boateng contended that the judgment was not final because he had not exhausted the appeal process. However, the defendants later informed the court that the appeal had been dismissed for lack of jurisdiction due to timeliness issues. Boateng's brief opposition claimed that the current case involved different matters than the state court case. The complaint outlines various causes of action, including unlawful employment practices under Title VII, violations of privacy rights, tort claims, breach of contract, and defamation. The court noted that federal courts must recognize the res judicata effects of state court judgments, which requires meeting specific criteria under Puerto Rico law. The Supreme Court of Puerto Rico in Bolker v. Superior Court; Sosa, Int. 82 P.R.R. 785 established that a prior judgment must be final, issued by a court with appropriate jurisdiction, and determined on the merits. The complaint alleges that Dr. Boateng was denied tenure based on nationality, race, and color, although no specific employment contract was identified. The court found the denial of tenure was exclusively based on discriminatory factors, citing violations of regulatory provisions governing the University. Dr. Boateng was coerced into accepting a probationary contract under threat of termination, conflicting with Puerto Rican and U.S. law. The ruling from the Commonwealth court, issued on March 27, 1998, followed a six-day hearing involving oral testimony and documentary evidence. The court made detailed findings that the University fulfilled its contractual obligations and did not discriminate against Dr. Boateng. The breach of contract claim was dismissed due to the lack of evidence supporting such violations, and the case was dismissed in full, imposing costs and attorney's fees against Dr. Boateng for pursuing the litigation in bad faith. Federal courts typically respect the res judicata effects of state court judgments, as mandated by 28 U.S.C. 1738. This statute requires federal courts to give the same credit to state judgments as the state courts would. The court determined that the issues in the current case had already been resolved in the Commonwealth court, leading to the granting of Interamerican University's Motion to Dismiss. Additionally, prior partial judgments were noted, dismissing some causes of action, and the motion was treated as one for summary judgment because it included relevant opinions and judgments. The court also expressed skepticism regarding Dr. Boateng's credibility based on his evasive testimony.