The Puerto Rico Court of Appeals recently ruled on a case involving José O. Rodríguez Santiago and Thompson Construction Group, Inc. The court denied Thompson Construction's request to overturn a lower court's decision regarding an unjust dismissal claim. This ruling is significant as it addresses the legal standards surrounding employee dismissals in Puerto Rico.
The case, docketed as TA2026CE00386, began when Rodríguez Santiago filed a complaint against Thompson Construction on August 18, 2025. He alleged that he was unjustly dismissed from his position on June 27, 2025, during a supposed reorganization and closure of the company’s warehouse. Rodríguez Santiago claimed that even after his dismissal, the company continued to operate in the same capacity, suggesting that his termination lacked just cause as defined under Puerto Rico's Law No. 80, which protects workers from unjust dismissals.
Thompson Construction responded to the complaint by asserting that the dismissal was justified due to a bona fide reorganization of the company. They argued that the company had to let go of 77 employees between 2024 and 2025 due to economic losses and that Rodríguez Santiago's position was eliminated as part of this legitimate restructuring process. On February 5, 2026, Thompson Construction filed a motion for summary judgment, seeking to dismiss the case entirely, claiming there was no genuine dispute regarding the facts of the case.
On March 18, 2026, the lower court ruled against Thompson Construction's motion for summary judgment. The court found that there were unresolved factual issues regarding the company's reorganization plan and whether the dismissal was justified under the law. The court noted that the evidence presented did not sufficiently demonstrate that the reorganization was bona fide or that it complied with the legal requirements for dismissing employees based on seniority and efficiency.
In its ruling, the court stated, "[E]xist controversy over whether the employer considered the criterion of seniority in the classification of positions at the time of the dismissal of the complainant." The court emphasized that the employer needed to provide clear evidence of the reorganization plan and how it justified the dismissal of Rodríguez Santiago. The court concluded that it could not determine at that stage whether the dismissal was justified.
Thompson Construction subsequently filed a petition for certiorari, seeking to have the Appeals Court review the lower court's decision. They argued that the lower court erred in finding factual disputes that precluded summary judgment and that it failed to apply established legal standards regarding dismissals due to reorganization. They contended that the evidence they presented was sufficient to warrant a summary judgment in their favor.
The Appeals Court, however, upheld the lower court's decision, stating that the evidence provided by Thompson Construction did not meet the necessary legal standards to justify the dismissal at this stage. The court reiterated that the employer must demonstrate that the dismissal was not arbitrary and that it was part of a legitimate business decision, not merely a whim. The court noted that the documentation submitted by Thompson Construction did not sufficiently clarify the origins or validity of the claims made regarding the business's financial state and the reorganization plan.
The court ruled, "The determination that the petitioner must provide the First Instance Court with the alleged economic loss of the company is sensible." This indicates that the court recognized the need for clear and credible evidence to support claims of justified dismissals based on organizational changes.
This ruling is significant for employees and employers in Puerto Rico, as it underscores the importance of adhering to legal standards when dismissing employees. It highlights the necessity for employers to provide substantial evidence when claiming that a dismissal was part of a bona fide reorganization. The decision also reinforces the protections afforded to employees under Law No. 80, which aims to prevent unjust dismissals.
Moving forward, this case may influence how employers approach dismissals related to organizational changes. Companies will need to ensure they have robust documentation and justification for any layoffs to avoid potential legal challenges. Employees, on the other hand, may feel more empowered to challenge dismissals that they believe do not comply with legal standards.
As for what’s next, Thompson Construction has the option to appeal the decision further, although the court filing did not specify whether they intend to do so. The ruling leaves the door open for further litigation in the lower court, where the case will continue to unfold as each party presents their evidence and arguments.