## Facts

- Daniel Grajales worked for the Puerto Rico Ports Authority (PRPA).
- In 2006, PRPA appointed Grajales to a “trust” (policymaking) position during a Popular Democratic Party (PDP) administration.
- In 2008, Grajales left the trust position and moved into protected “career” positions, ultimately becoming a security supervisor at the Aguadilla airport.
- After the November 2008 election brought the New Progressive Party (NPP) into power, Grajales alleged that PRPA officials subjected him to adverse actions in early 2009.
- The alleged actions included banishment from the Aguadilla airport, transfer to a distant airport in Ponce, removal of his service sidearm, negative performance evaluations, and threats of suspension and termination.
- Grajales alleged that there was no legitimate reason for these actions and that they were politically motivated, including an official’s comment that his career appointment was a “political favor.”

## Issues

1. Whether the second amended complaint plausibly alleged that political affiliation was a substantial or motivating factor in adverse employment actions, sufficient to survive a Rule 12(c) motion under the Twombly/Iqbal pleading standard.

## Decision

- The First Circuit reversed the district court’s judgment on the pleadings and remanded.
- The court treated the Rule 12(c) standard as equivalent to Rule 12(b)(6), accepting well-pleaded facts as true and drawing reasonable inferences for the plaintiff.
- Although conclusory assertions of political animus were not credited, the court held that the complaint’s nonconclusory allegations, considered in context, plausibly supported an inference of political discrimination.

## Legal Principles

- To survive dismissal, a complaint must plead enough nonconclusory facts to state a claim that is plausible on its face; labels, conclusions, and formulaic recitations are insufficient.
- Courts apply a two-step approach: disregard legal conclusions, then assess whether the remaining factual allegations plausibly suggest liability in context.
- In First Amendment political discrimination claims under 42 U.S.C. § 1983, a plaintiff may plead political motivation through circumstantial facts and reasonable inferences; direct admissions of animus are not required at the pleading stage.
- Timing relative to a change in political administration, a clustered pattern of adverse actions, and allegations that the actions lacked legitimate justification may collectively support a plausible inference of political discrimination.

## Conclusion

The First Circuit held that Grajales’s allegations—political turnover, a rapid series of adverse actions, lack of legitimate reasons, and indicia of politically tinged employment decisions—were sufficient to plausibly state a First Amendment political discrimination claim, making dismissal on the pleadings improper.


Grajales v. P.R. Ports Auth., 682 F.3d 40 (1st Cir. 2012)