Ruiz-Lugo v. Municipality San Juan

382 F. Supp. 3d 173
CourtUnited States District Court
DecidedMarch 25, 2019
DocketCIVIL NO. 18-1203 (JAG)
StatusPublished
Cited by1 cases

This text of 382 F. Supp. 3d 173 (Ruiz-Lugo v. Municipality San Juan) is published on Counsel Stack Legal Research, covering United States District Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ruiz-Lugo v. Municipality San Juan, 382 F. Supp. 3d 173 (usdistct 2019).

Opinion

GARCIA-GREGORY, D.J.

On April 11, 2018, Mr. Pedro Ruiz-Lugo ("Plaintiff")1 filed this civil rights action under 42 U.S.C. § 1983 against his employer, the Municipality of San Juan ("MSJ"),2 alleging "political discrimination, constructive dismissal, and deprivation of his property and rights," in violation of the First and Fourteenth Amendments to the U.S. Constitution. Docket No. 1. For purposes of this Memorandum and Order, Plaintiff's claims are best described as a set of three (3) specific acts: (i) that the MSJ eliminated some of Plaintiff's workplace duties on April 23, 2014 (at the latest);3 (ii) that an MSJ official gave Plaintiff *175a negative performance evaluation in November 2016 to deprive him of a salary increase; and (iii) that, for the "last two years" (presumably, since April 11, 2016), Plaintiff's desk has been placed in a hallway and "little to no work at all has been assigned to him." Id. at 4-11. During each of these acts, Plaintiff charges, the PPD-controlled MSJ was discriminating against him for his affiliation with the rival NPP. Id. at 1-4.

The MSJ now moves to dismiss Plaintiff's suit under Fed. R. Civ. P. 12(b)(6), contending (in relevant part) that his federal claims are time-barred by the one-year statute of limitations applicable to Section 1983 actions in Puerto Rico. Docket No. 27 at 6-8; see also Ayala-Sepúlveda v. Municipality of San Germán , 727 F.Supp.2d 67, 72-73 (D.P.R. 2010) ("A claim under [ Section] 1983 borrows its limitations period from state law and, therefore, carries a one-year statute of limitations in Puerto Rico."). In short, the MSJ argues that Plaintiff's Complaint is devoid of "a single independent event" occurring within this limitations period-that is, on or after April 11, 2017, a year before he filed the Complaint. Docket No. 48 at 7; see also Blackstone Realty LLC v. FDIC , 244 F.3d 193, 197 (1st Cir. 2001) (holding that a statute of limitations defense may be raised at this stage where, as here, "the facts establishing the defense [are] clear on the face of [the] pleadings.") (internal citation and quotation marks omitted). Plaintiff responds that, because the effects of these actions have lasted until today, the MSJ's conduct constitutes "a continuing violation amounting to a single wrong occurring within the limitations period." Docket No. 31 at 6-10. After carefully reviewing the applicable law and the Parties' respective positions, the Court sides with the MSJ and concludes that the applicable one-year statute of limitations time-bars Plaintiff's federal claims under Section 1983.

Under the "continuing violation" doctrine, Plaintiff surely could "incorporate allegations that would ordinarily be time-barred if they are part of the same unlawful employment practice and at least one act falls within the [applicable limitations] period." Ayala-Sepúlveda , 727 F.Supp.2d at 72-73 (D.P.R. 2010) (internal citations and quotation marks omitted). This doctrine, however, does not apply to "discrete" acts that are "instantaneously actionable"-including, as in this case, (i) a failure to assign work to an employee; (ii) a negative performance evaluation; and (iii) a transfer to another work area. Ayala v. Shinseki , 780 F.3d 52, 57 (1st Cir. 2015). Rather, the one-year statute of limitations for these discrete acts (and, by extension, Plaintiff's Section 1983 claims) begins to run upon their initial occurrence, even if Plaintiff continues to feel the effect of such adverse employment actions for as long as he remains employed with the MSJ. See Gorelik v. Costin , 605 F.3d 118, 122 (1st Cir. 2010) (" Section 1983 claims generally accrue when the plaintiff knows, or has reason to know of the injury on which the action is based, and a plaintiff is deemed to know or have reason to know at the time of the act itself and not at the point that the harmful consequences are felt.") (quoting Morán-Vega v. Cruz Burgos , 537 F.3d 14, 20 (1st Cir. 2008) ).

Here, each of the MSJ's alleged actions-stripping Plaintiff of his duties, issuing a negative performance evaluation, failing to assign him work, and placing his *176desk in a hallway-constitutes a "discrete" act. Ayala , 780 F.3d at 56-57 ; see also Malone v. Lockheed Martin , 610 F.3d 16, 20-22 (1st Cir. 2010) (refusing to apply the continuing violation doctrine to plaintiff's claims that he "received a series of escalating reprimands, deteriorating performance reviews, and eventually a demotion" because these acts were discrete); Rivera v. P.R. Aqueduct & Sewers Auth. , 331 F.3d 183, 186-89 (1st Cir. 2003) (holding that moving plaintiff to a smaller office and transferring her to a supervisor who did not assign plaintiff any work constitute discrete acts). And, by Plaintiff's own admission, the last of these "discrete" acts-failing to assign him any work and placing his desk on a hallway-occurred on April 11, 2016 at the latest. Docket No. 1 at 4-11. As a result, the MSJ's alleged unconstitutional conduct burgeoned into an actionable injury (one last time) at least two (2) years before Plaintiff filed his Complaint on April 11, 2018. Gorelik , 605 F.3d at 121-22.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
382 F. Supp. 3d 173, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ruiz-lugo-v-municipality-san-juan-usdistct-2019.