The Puerto Rico Court of Appeals recently ruled on a case involving Ángel A. Rosario Maisonet, a teacher who appealed his dismissal from the Department of Education (DE). The court's decision, delivered on April 27, 2026, impacts the rights of unionized employees in administrative disciplinary actions.

The court found that Rosario Maisonet had been incorrectly notified about where to file his appeal after his dismissal, which led to confusion about the appropriate legal process. This ruling is significant as it highlights the importance of proper notification in administrative procedures, particularly for unionized employees.

Background

Ángel A. Rosario Maisonet was a teacher at the Violeta Reyes Pérez School in Cidra, Puerto Rico. His troubles began when the school’s principal filed a complaint against him, prompting the DE to initiate an investigation. Following the investigation, Rosario Maisonet was suspended on July 15, 2025, without loss of pay.

Disagreeing with the suspension, Rosario Maisonet requested an informal hearing with the DE, which took place on September 9, 2025. After the hearing, he was officially dismissed on November 7, 2025. The DE informed him in their final decision that he could appeal to the Office of Appeals of the Education System (OASE), despite him being a unionized employee.

On December 8, 2025, Rosario Maisonet filed an appeal with the OASE, challenging his dismissal. However, on December 15, 2025, the OASE issued an order indicating that it lacked jurisdiction over the case because Rosario Maisonet was a unionized employee. This led to his appeal being dismissed without prejudice.

The Ruling

The court ruled that the OASE's dismissal of Rosario Maisonet's appeal was incorrect due to a defective notification regarding the appropriate forum for his appeal. The court emphasized, "an administrative error by the agency regarding the forum to appeal does not create jurisdiction where none exists." This ruling was made by Judge Adames Soto, along with the panel including Judges Candelaria Rosa, Campos Pérez, and Trigo Ferraiuoli.

The court acknowledged that the DE admitted to the notification error and requested that the appeal be dismissed to allow for proper notification. The court agreed, stating that Rosario Maisonet should not be penalized for following the instructions given in the erroneous notification.

Impact

This ruling is significant for several reasons. It underscores the necessity for administrative agencies to provide accurate information regarding appeal processes, particularly for unionized employees. The court's decision clarifies that if an agency fails to adequately notify an employee about where to appeal, the employee cannot be held accountable for filing in the wrong forum.

The ruling also sets a precedent for future cases involving administrative notifications and appeals. It reinforces the principle that proper notification is essential for due process in administrative proceedings. This case may encourage other unionized employees facing similar situations to pursue their rights without fear of losing their appeals due to administrative errors.

What's Next

The court's ruling allows Rosario Maisonet to have his case re-evaluated under the correct forum, the Commission on Public Service Appeals (CASP). The DE is expected to issue a new notification to Rosario Maisonet regarding his dismissal, allowing him to appeal appropriately. Details regarding any further appeals were not available in the court filing.