Ángel J. Valencia
Ángel J. Valencia is a Senior Counsel at the Liberty Justice Center, where he litigates to defend individual liberties and challenge government overreach.
The Liberty Justice Center represents four University of Puerto Rico employees in a constitutional challenge to an agreement that conditioned an illegal $3,000 one-time, employer-funded payment on union membership.
The Liberty Justice Center’s efforts in the Supreme Court’s ruling in Janus v. AFSCME in 2018 affirmed that public employees cannot be compelled to subsidize a union and have a protected right not to associate. Following this decision, Plaintiffs Orlando Méndez López, José Cotto Meléndez, José A. Ramos Ramos, and Ciprián Centeno Rodríguez exercised their constitutional rights and resigned from the University of Puerto Rico Workers’ Union and stopped paying dues.
In late 2024, the University of Puerto Rico (UPR) and the Union negotiated a one-time $3,000 payment to be funded entirely by public dollars but illegally reserved this only for employees who were current on union dues as of September 5, 2024. UPR disbursed the payment in two installments: $2,000 on January 15, 2025, and $1,000 on July 15, 2025. The plaintiffs, who work in the same bargaining unit as union members, were denied the payment solely because they exercised their First Amendment right not to join the Union.
The Constitution prohibits public employers from coercing union membership or discriminating against nonmembers by conditioning employer-provided compensation on union status. By awarding public funds only to union members, UPR and the Union violated the plaintiffs’ rights to free speech and free association under the First and Fourteenth Amendments. The Liberty Justice Center’s case seeks declaratory and injunctive relief, restitution/compensatory damages equal to the withheld payment, nominal and punitive damages, and attorneys’ fees and costs.
Public institutions must respect the constitutional rights of all employees. Denying publicly funded compensation because an employee declines union membership is unlawful coercion and discrimination.
Méndez v. University of Puerto Rico was filed in the United State District Court for the District of Puerto Rico on December 19, 2025.
Ángel J. Valencia is a Senior Counsel at the Liberty Justice Center, where he litigates to defend individual liberties and challenge government overreach.