One-year Term of Employment a Protected Property Interest In Puerto Rico

In Chaparro v. Ruiz-Hernandez, No. 08-1989, the First Circuit faced a challenge to the district court's grant of plaintiffs' motion for summary judgment in their 42 U.S.C. section 1983 suit brought by a group of twenty-two contract employees against a Puerto Rican municipality and its officers, arising from early termination of their employment some five months prior to expiration of their one-year contract.

In affirming part of the judgment, the court held that plaintiffs had a reasonable expectation of continued employment, and that a one-year term of employment with Puerto Rican government bodies is generally considered a protected property interest for procedural due process purposes.  The court rejected defendants' claim that plaintiffs were not deprived of protected property interests without due process of law because the process Puerto Rico provided was adequate.  However, the judgments against the individual defendants is vacated, as well as an award of punitive damages against them. 

Related Resource:

• Full text of Chaparro v. Ruiz-Hernandez