The U.S. Court of Appeals for the First Circuit has affirmed a lower court's decision to dismiss an employment lawsuit against the United States Postal Service after finding that the plaintiff engaged in witness tampering. In *González Tomasini v. Steiner*, decided Feb. 2, 2026, a three-judge panel upheld the district court's ruling that Orlando González Tomasini had tampered with a witness, justifying the dismissal of his case as an appropriate sanction.
The case began as an employment dispute between González Tomasini and the Postal Service, with defendants including Postmaster General Louis DeJoy and the United States Postal Service. González Tomasini was represented by his wife, Juliette Irizarry-Miranda, and their conjugal partnership, along with four minor children identified in court records by initials only.
The controversy erupted on the eve of trial when the Postal Service accused González of witness tampering. This accusation prompted the U.S. District Court for the District of Puerto Rico, presided over by Magistrate Judge Marcos E. López, to conduct a three-day evidentiary hearing to investigate the allegations.
Following the hearing, the district court concluded that González had indeed tampered with a witness and determined that dismissing his entire case was the appropriate sanction for this conduct. The severity of this sanction reflects the court's view that witness tampering represents a fundamental attack on the judicial process.
Writing for the First Circuit panel, Circuit Judge Aframe opened the opinion with a stark warning about fraud in the justice system, quoting the Supreme Court's 1944 decision in *Hazel-Atlas Glass Co. v. Hartford-Empire Co.*: "No fraud is more odious than an attempt to subvert the administration of justice." This quote sets the tone for the court's analysis and underscores the seriousness with which federal courts view attempts to interfere with witnesses.
"That is the kind of fraud we confront here," Judge Aframe wrote, characterizing the witness tampering as an attempt to subvert justice administration. The opinion indicates that the appellate court viewed González's conduct as particularly egregious given its timing—occurring just before trial when the case was about to proceed to a jury.
González challenged multiple aspects of the district court's handling of the case on appeal. He contested the district court's decision to hold the evidentiary hearing in the first place, arguing that such proceedings were unnecessary or improper. He also challenged the court's finding that he had engaged in witness tampering, disputing both the evidence and the legal conclusions drawn from it.
Additionally, González argued that even if witness tampering had occurred, dismissal of the entire case was too severe a sanction. Courts have various options when addressing litigation misconduct, ranging from monetary sanctions to case dismissal, and González apparently argued that lesser sanctions would have been more appropriate.
The First Circuit panel, consisting of Circuit Judges Aframe and Thompson, along with Seventh Circuit Judge Hamilton sitting by designation, rejected all of González's arguments. The court's decision to "affirm in all respects" indicates unanimous agreement that the district court properly conducted the hearing, correctly found witness tampering, and appropriately selected dismissal as the sanction.
The case was argued by Carlos M. Sánchez La Costa of Sanchez La Costa Law Firm representing González, while the government was represented by Assistant United States Attorney Dennise N. Longo Quiñones, working alongside United States Attorney W. Stephen Muldrow and Mariana E. Bauzá-Almonte, Assistant United States Attorney and Chief of the Appellate Division.
This decision reinforces federal courts' commitment to protecting the integrity of the judicial process. Witness tampering is considered one of the most serious forms of litigation misconduct because it directly undermines the fact-finding function that is central to civil and criminal proceedings. When parties attempt to influence witnesses improperly, they threaten the court's ability to reach accurate conclusions based on reliable evidence.
The timing of the misconduct—on the eve of trial—likely influenced both courts' decisions. At this stage, substantial judicial and party resources had already been invested in preparing for trial, making the interference particularly disruptive to the judicial process.
For employment cases against federal agencies like the Postal Service, this decision serves as a reminder that litigation misconduct can result in the complete loss of otherwise valid claims. The First Circuit's affirmance sends a clear message that courts will not tolerate attempts to manipulate the judicial process, regardless of the underlying merits of a case.
The case number is 23-1914, and the full opinion provides additional details about the specific evidence and legal standards that led to the witness tampering finding and dismissal sanction.