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Rafael L. Balaguer-Santiago v. Hon. Jaime Torres-Gaztambide, Etc.
Citations: 932 F.2d 1015; 1991 U.S. App. LEXIS 9571; 1991 WL 75999Docket: 90-1513
Court: Court of Appeals for the First Circuit; May 14, 1991; Federal Appellate Court
Rafael L. Balaguer-Santiago initiated a civil rights lawsuit under 42 U.S.C. § 1983 after being demoted from his position at the Puerto Rico Rural Housing Administration (RHA) shortly after the 1984 gubernatorial election. He alleged that the demotion was politically motivated and violated his First and Fourteenth Amendment rights. The defendants, senior officials at RHA, sought partial summary judgment based on qualified immunity, which the district court denied. The Court of Appeals for the First Circuit focused on whether the defendants were entitled to qualified immunity. The doctrine protects public officials from personal liability unless their actions violated a "clearly established" right. The defendants contended that there was no clearly established right against politically motivated demotions not amounting to dismissal at the time of Balaguer's demotion in January 1985. The district court, however, ruled that such a right was clearly established. The appellate court referenced its prior decision in Nunez-Soto v. Alvarado, which found that the law did not clearly establish a violation of the federal Constitution for politically motivated demotions in 1985. The court acknowledged that while a public official might not be entitled to qualified immunity for a politically motivated "constructive discharge," this issue required further examination. The appellate court determined that a "constructive discharge" claim had been adequately raised, despite being described generally as a demotion. Consequently, it reversed the district court's order denying summary judgment on the wrongful demotion claim and remanded the case for the district court to assess the defendants' qualified immunity regarding the constructive discharge claim, allowing for potential supplementation of the record. The appellate court's decision reinforces the necessity for the district court to evaluate the qualified immunity claim with respect to whether the adverse personnel action constituted a constructive discharge.