Four University of Puerto Rico employees sued the university president and the Sindicato de Trabajadores de la Universidad de Puerto Rico after the union continued deducting dues from their paychecks despite their resignation requests following the Supreme Court's 2018 Janus decision. The workers—José A. Ramos-Ramos, Orlando Méndez-López, Igneris A. Pérez-Rosario, and José Cotto-Meléndez—demanded that UPR and the union stop the deductions, but the practice continued for nearly three years before ending.
Circuit Judge Aframe wrote that the union's acknowledgment of error and policy changes to comply with Janus distinguished this case from other post-Janus challenges. "An admission of error is not always necessary to conclude that a claim is moot based on changed conduct," Aframe noted, but here "the presence of such admissions is crucial to our mootness conclusion." The court found that UPR and the union stopped deducting dues because of Janus rather than "legal gamesmanship."
The district court had largely granted summary judgment for the defendants while ordering the union to reimburse employees for post-resignation deductions. The employees appealed only the denial of declaratory relief, seeking both backward-looking declarations that past deductions were unconstitutional and forward-looking declarations that future deductions would violate the Constitution.
The ruling demonstrates how defendants' admissions of error can moot declaratory judgment claims in post-Janus litigation. The decision may encourage unions and employers to promptly acknowledge violations and implement compliance policies to avoid prolonged litigation, while highlighting the limits of seeking purely declaratory relief after challenged conduct has ceased.