AI-measured from their own opinions — each lever cites its cases
Willing to revisit precedentStrong stare decisis
In [10], Torruella applies established quasi-judicial immunity doctrine without questioning its validity, indicating strong adherence to precedent. Guzman-Rivera v. Lucena-Zabala ↗
Deference to government powerSkepticism of government power
In [4], Torruella scrutinizes federal jurisdiction over tribal internal matters while upholding most convictions for misuse of federal funds, showing moderate skepticism of expansive government authority. United States v. Newell ↗
The case concerned disputes between Puerto Rico Telephone Company (PRTC) and SprintCom over payments due under their 2000 interconnection agreement, specifically whether the FCC's ISP Remand Order triggered the agreement's change-of-law clause to require reciprocal compensation for ISP-bound traffic, and whether Sprint could recover alleged overcharges by PRTC for transit traffic. The First Circuit reversed the district court's upholding of the Puerto Rico Telecommunications Regulatory Board's order on the ISP-bound traffic issue, ruling that the change-of-law provision was not triggered, and remanded for injunctive relief and further Board proceedings. It affirmed the dismissal of Sprint's transit-traffic claims, holding that Sprint had waived its right to challenge the relevant invoices under the agreement's waiver clause. The court found no properly preserved argument that an exception for intentional breach (dolo) applied to override the waiver.
In Rodriguez v. Municipality of San Juan, plaintiff Ricardo Ríos, a municipal purchasing officer and Popular Democratic Party supporter, sued the municipality, Mayor Jorge Santini, and a supervisor under 42 U.S.C. § 1983, alleging that his 2006 termination and prior mistreatment stemmed from political discrimination and retaliation for protected speech criticizing the mayor, in violation of the First and Fourteenth Amendments; he also brought related local-law claims. The district court granted summary judgment to the defendants on the federal claims and declined supplemental jurisdiction over the local claims. The First Circuit affirmed summary judgment on the procedural due process and equal protection claims, as well as all claims against defendant Díaz, but vacated summary judgment for Santini and the municipality on the political discrimination and free-speech retaliation claims. It held that the record contained triable issues of fact about whether Ríos’s political affiliation or speech motivated the adverse actions and whether Santini, as a final policymaker, caused any constitutional injury sufficient to support municipal liability. The court also vacated the dismissal of the local-law claims against those two defendants and remanded for further proceedings.
The case involved Jorge Pérez-Cordero, a butcher at Wal-Mart in Puerto Rico, who sued his employer and supervisors under Title VII and Puerto Rico law, alleging that his female supervisor sexually harassed him by making unwanted advances and that management retaliated against him after he rejected her and complained. The district court granted summary judgment to the defendants, finding insufficient evidence of unwelcome, pervasive harassment based on sex. On appeal, the First Circuit vacated the judgment, holding that the evidence, viewed favorably to the plaintiff, could support claims of a hostile work environment due to sex and retaliation for opposing it, including temporal links between complaints and adverse actions.
In this case, Omar Santiago Miranda pleaded guilty to conspiring to possess with intent to distribute cocaine, crack, and marijuana, but later moved to withdraw his plea, claiming it was involuntary due to prescription drug use, lack of sleep, familial coercion, and bipolar disorder. The district court denied the motion without an evidentiary hearing and sentenced him to 380 months in prison. On appeal, Santiago challenged the denial and the lack of a hearing, while the government argued the appeal was barred by a waiver in the plea agreement. The First Circuit bypassed the waiver issue and affirmed the district court's judgment, reasoning that the change-of-plea colloquy demonstrated Santiago's competence and lack of coercion, supported by unchallenged facts from the plea agreement and presentence report.
The case involved plaintiff Áurea Vázquez-Rijos suing her deceased husband's parents, Abraham and Barbara Anhang, in federal court after removal from Puerto Rico Superior Court, seeking a share of his estate based on prenuptial agreements, usufructuary rights, and community property rules under Puerto Rico law, plus damages for alleged obstruction. More than three years after filing, the district court dismissed the suit with prejudice due to the plaintiff's repeated noncompliance with court orders, extensive delays in prosecution, and failure to serve Barbara Anhang. On appeal, the First Circuit affirmed, holding that the district court did not abuse its discretion in choosing dismissal after issuing multiple warnings, granting a motion to compel, and attempting lesser measures over time, as the plaintiff's conduct included missed deadlines, incomplete discovery responses, and refusal to appear for continued deposition. The court rejected arguments that the delays were non-willful or that lesser sanctions were inadequately considered, noting that bad faith is not required for such sanctions and that the record showed flagrant and repeated abuses.
In United States v. Chaney, the defendant, a guest in a motel room raided by police executing an arrest warrant for another person on drug charges, moved to suppress crack cocaine and ammunition found in his pockets after he consented to a search for identification while handcuffed on the floor. After the district court denied the motion, Chaney entered a conditional guilty plea to simple possession of cocaine and being a felon in possession of a firearm. The First Circuit affirmed, holding that the search fell within the scope of Chaney's voluntary consent because the officer removed the drugs before locating the ID card, that the consent was not coerced, and that the initial detention did not amount to a de facto arrest given the circumstances of the protective sweep and efforts to identify the unknown occupant.
