Employment – Transfer – Retaliation – Sexual orientation

An award of summary judgment in favor of a defendant employer charged with retaliatory transfer must be affirmed given a lack of evidence that the plaintiff employee’s pay, rank or duties changed after he was transferred.

Ayala-Sepúlveda v. Municipality of San Germán (Lawyers Weekly No. 01-015-12) (16 pages) (Torruella, J.) (1st Circuit) Appealed from the U.S. District Court for the District of Puerto Rico (Docket No. 10-2123) (Jan. 18, 2012).