Case Citator › Muniz Ramirez v. Puerto Rico Fire Service

Muniz Ramirez v. Puerto Rico Fire Service

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
First Circuit
Citation
715 F.2d 694
Decided
Confirmed treatments
2
Flagged citations read
38 of 38
Citing cases (total)
38
Treatment dates
1996–2000
Abrogated
A reviewed court treats this case as abrogated by later authority. Muniz Ramirez v. Puerto Rico Fire Service has been abrogated on private ADEA damages suits. All 38 flagged citations have been read, and the two confirmed treatments are listed below.
More on how this was screened

The Supreme Court held in Kimel v. Florida Board of Regents that the ADEA did not validly remove state immunity from those suits, contrary to Muniz Ramirez's holding. The First Circuit later acknowledged that result in State Police for Automatic Retirement Association v. DiFava. Muniz Ramirez's separate rulings on Puerto Rico's immunity and prospective relief were not displaced by that decision.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

38 later cases cite Muniz Ramirez v. Puerto Rico Fire Service; 38 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Muniz Ramirez v. Puerto Rico Fire Service?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Abrogated

  • The Supreme Court held that the ADEA did not validly remove states' immunity from private damages suits, displacing Muniz Ramirez's contrary ADEA holding.

    Kimel v. Florida Board of Regents · Supreme Court of the United States · filed

    we hold that the ADEA is not a valid exercise of Congress’ power under §5 of the Fourteenth Amendment. The ADEA’s purported abrogation of the States’ sovereign immunity is accordingly invalid.
    Read the full opinion on CourtListener →

Declined to Follow

  • Before Kimel, the Northern District of Alabama rejected Muniz Ramirez's view that Congress used its Fourteenth Amendment power to remove state immunity under the ADEA.

    MacPherson v. University of Montevallo · N.D. Alabama · filed

    This court takes note of the well reasoned analysis of the First Circuit Court of Appeals in Ramirez v. Puerto Rico Fire Service, 715 F.2d 694, 700 (1st Cir.1983). However, this court fundamentally disagrees with the notion that it slipped the collective minds of Congress to mention the Fourteenth Amendment in the 1974 amendments to the ADEA, but remember it in the 1972 amendments to Title VII.
    Read the full opinion on CourtListener →

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