Arocho-Rodriguez v. Roldan-Concepcion

CourtCourt of Appeals for the First Circuit
DecidedMay 21, 2026
Docket24-2041
StatusPublished

This text of Arocho-Rodriguez v. Roldan-Concepcion (Arocho-Rodriguez v. Roldan-Concepcion) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Arocho-Rodriguez v. Roldan-Concepcion, (1st Cir. 2026).

Opinion

United States Court of Appeals For the First Circuit

No. 24-2041

JENSEN AROCHO-RODRÍGUEZ,

Plaintiff, Appellant,

v.

JULIO ROLDÁN CONCEPCIÓN, Mayor, Municipality of Aguadilla; RUBÉN NIEVES-ROLDÁN, Director, Office of Technologies; MAVIAEL MORALES-NIEVES, Municipality Administrator; MUNICIPAL GOVERNMENT OF AGUADILLA; JOHN DOE; JANE DOE; RICHARD ROE,

Defendants, Appellees,

XAYMARA MESONERO, Director, Human Resources,

Defendant.

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

[Hon. Francisco A. Besosa, U.S. District Judge, Hon. Giselle López-Soler, U.S. Magistrate Judge]

Before

Gelpí, Thompson, and Rikelman, Circuit Judges.

Israel Roldán-González for appellant. Omar Andino-Figueroa, Solicitor General of Puerto Rico, Frank A. Rosado Méndez, Deputy Solicitor General, and Mariola Abreu-Acevedo, Assistant Solicitor General, for appellees Julio Roldán Concepción, Rubén Nieves-Roldán, and Maviael Morales-Nieves. Carlos M. Hernández-López for appellee the Municipality of Aguadilla. May 21, 2026 PER CURIAM. Plaintiff-Appellant Jensen Arocho-Rodríguez

sued various defendants for, among other claims, political

discrimination in violation of the First Amendment. When

some -- but not all -- of the defendants moved for summary

judgment, the district court adopted a Report & Recommendation

("R&R"), granted the motion, and dismissed the entire case sua

sponte. Arocho-Rodríguez appealed, and we now reverse.

I. BACKGROUND

Arocho-Rodríguez is a member of Puerto Rico's New

Progressive Party ("NPP") and a former System Technician

Coordinator for the Municipality of Aguadilla. In January of 2021,

Aguadilla Mayor Julio Roldán Concepción, a member of the Popular

Democratic Party ("PDP"), took office. He appointed PDP members

Rubén Nieves-Roldán and Maviael Morales-Nieves to the positions of

Director of the Office of Technologies and City Administrator,

respectively. Thereafter, Arocho-Rodríguez alleges that Mayor

Roldán and his appointees retracted Arocho-Rodríguez's server

access (rendering it impossible to complete his work), gave him a

poor employment evaluation, and created such a "humiliating" work

environment that he felt forced to resign, all because of his NPP

membership.

Arocho-Rodríguez then sued Defendant-Appellee the

Municipality of Aguadilla, and individual Defendants-Appellees

Mayor Roldán, Nieves-Roldán, and Morales-Nieves in their official

- 3 - and individual capacities pursuant to 42 U.S.C. § 1983. He brought

a political discrimination claim under the First Amendment, an

equal protection claim under the Fourteenth Amendment, and

concomitant claims under Puerto Rico law.1

After motion practice and discovery, the individual

Defendants-Appellees moved for summary judgment on the claims

against them in their individual capacities. They asserted that

Arocho-Rodríguez had not established a prima facie claim of

political discrimination under the First Amendment. They also

asserted a qualified immunity defense. They did not, however,

brief the equal protection, Puerto Rico law, or official capacity

claims. The accompanying statement of facts cited to the Second

Amended Complaint and to Arocho-Rodríguez's deposition, and the

sole exhibit attached to the facts consisted of excerpts from said

deposition. The individual Defendants-Appellees did not submit

any other evidence with their motion. The Municipality did not

move for summary judgment.

In response, Arocho-Rodríguez admitted all of the facts

save one (which does not impact this appeal), but he contended

that factual disputes rendered summary judgment inappropriate. In

making that argument, he did not cite to his deposition testimony

1 Arocho-Rodríguezalso brought a Fifth Amendment claim, which was dismissed with his consent.

- 4 - directly, but he did cite to the individual Defendants-Appellees'

statement of facts, which, as just stated, cited his deposition.

The district court referred the motion to a magistrate

judge for a R&R. On July 2, 2024, the magistrate judge issued the

R&R and recommended that the district court grant the motion for

summary judgment. The R&R first concluded that in opposing the

motion, Arocho-Rodríguez had "failed to develop any legal and

factual argument in support of his claim under the First

Amendment," and that he "merely cited to case law without providing

any explanation or analysis of how these authorities support his

position or support a finding that there is a triable issue of

fact." Then, citing our rule that "undeveloped arguments are

waived," the R&R concluded that summary judgment could be granted

on the ground of waiver "alone." Nevertheless, the R&R also

concluded that Arocho-Rodríguez had failed to establish a prima

facie political discrimination claim because "there [were]

absolutely no facts" or "admissible evidence" that showed Mayor

Roldán knew of Arocho-Rodríguez's NPP affiliation, or that

Nieves-Roldán and Morales-Nieves "participated in the employment

decisions at issue." Given these findings, the R&R did not reach

qualified immunity.

Arocho-Rodríguez filed objections to the R&R, asserting

many of the same arguments he advances on appeal, which we will

discuss below. His objections, however, did not sway the district

- 5 - court. On October 8, 2024, the district court entered a memorandum

opinion adopting the R&R and granting the individual

Defendants-Appellees' motion for summary judgment. The district

court thought Arocho-Rodríguez only supported his arguments with

"allegations and speculation." It thus concluded: "Because

Arocho-Rodríguez has failed to fully develop his arguments or cite

evidence to support his objections, the R&R properly recommended

that summary judgment be granted." The district court then entered

judgment and dismissed the entire case with prejudice. In doing

so, the district court did not address the Fourteenth Amendment

equal protection claim, the Puerto Rico law claims, or the

municipal liability and official capacity claims.

Arocho-Rodríguez timely appealed.

II. DISCUSSION2

"We review a district court's grant or denial of summary

judgment de novo, examining the record in the light most favorable

to the nonmovant and drawing all reasonable inferences in that

party's favor." Dusel v. Factory Mut. Ins., 52 F.4th 495, 502-03

(1st Cir. 2022) (citing Murray v. Kindred Nursing Ctrs. W. LLC,

789 F.3d 20, 25 (1st Cir. 2015)). It is axiomatic that summary

judgment is only appropriate if the movant shows that "there is no

2 The district court had jurisdiction under 28 U.S.C. §§ 1331 and 1367, and we have appellate jurisdiction under 28 U.S.C. § 1291

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