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Justia Daily Opinion Summaries

US Court of Appeals for the First Circuit
July 24, 2020

Table of Contents

Lopez-Santos v. Metropolitan Security Services

Labor & Employment Law

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US Court of Appeals for the First Circuit Opinions

Lopez-Santos v. Metropolitan Security Services

Docket: 18-1694

Opinion Date: July 23, 2020

Judge: Kermit Victor Lipez

Areas of Law: Labor & Employment Law

The First Circuit affirmed the order of the district court granting summary judgment in favor of Walden Security and dismissing the suit brought by Plaintiffs for statutory separation pay pursuant to Puerto Rico Law 80, holding that Plaintiffs had no remedy pursuant to Law 80. Plaintiffs had served as court security officers for the District of Puerto Rico for thirty-two years when Walden Security assumed the federal contract to provide courthouse security services. Walden refused to hire Plaintiffs because they lacked certification from a law enforcement training academy. Plaintiffs subsequently filed the instant lawsuit for statutory separation pay. The district court granted summary judgment for Walden, reasoning that Law 80 did not apply to Plaintiffs' claims. On appeal, Plaintiffs argued that the district erred in ignoring the theory of liability that Plaintiff's advanced: Puerto Rico's common law successor employer doctrine. The First Circuit affirmed, holding (1) the district court misconstrued Plaintiffs' theory of liability; but (2) the successor employer doctrine was clearly inapplicable to Plaintiffs' case.

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