Hector Manuel Laffitte

The case involved plaintiff Loyda Sanchez-Figueroa and her family suing her former employer, Banco Popular de Puerto Rico, under the ADA for failing to provide reasonable accommodations for her emotional disorder (diagnosed as a mixed situational disorder) and under Title VII for race-based discrimination. The court granted the bank's motion for summary judgment, dismissing both claims. It found that Sanchez did not qualify as disabled under the ADA because her condition was not permanent and did not substantially limit major life activities, that she had rejected multiple offered accommodations and alternative positions, and that her termination after 365 days of leave under Puerto Rico's Workers' Accident Compensation Act was based on exhaustion of the statutory employment reserve rather than discrimination. The court also noted a complete absence of any evidence supporting the Title VII race discrimination claim.

labor & employmentcivil rights

The case involved Don King Productions, the producer and copyright holder of a pay-per-view boxing match broadcast, suing the Comité PPD under Section 705 of the Communications Act for allegedly intercepting and displaying the event to patrons without authorization. The defendant moved for summary judgment, asserting it had legally purchased the transmission from its cable provider, displayed it only privately to members without commercial or political gain, and qualified for the private viewing exception. The court denied the motion, holding that genuine issues of material fact existed regarding whether the display constituted a statutory private viewing, involved any benefit or gain, and was properly authorized, which precluded summary judgment under Federal Rule of Civil Procedure 56.

business & regulatoryprocedure

The case involved claims by Marta Carrasquillo and her family against officials of the Puerto Rico Department of Corrections and Rehabilitation for alleged political discrimination in employment actions, brought under 42 U.S.C. § 1983 and Puerto Rico law. The court granted the defendants' motion for summary judgment. The core reasoning was that the plaintiffs failed to comply with local procedural rules requiring a proper response to the defendants' statement of uncontested facts, leading the court to deem the defendants' assertions admitted, including lack of knowledge of the plaintiff's political affiliation, and that the plaintiffs provided only conclusory allegations insufficient to show political animus as a motivating factor in the employment decisions.

civil rightslabor & employmentprocedurefree speech

This case involves a plaintiff's efforts to enforce a jury verdict awarding both compensatory and punitive damages against two Puerto Rico government officials in a civil rights lawsuit. After the defendants paid only the compensatory damages, fees, and costs, citing a Commonwealth law exempting it from paying punitive damages, the plaintiff filed motions to compel full payment, arguing that the government had waived any objection by providing legal representation. The court denied the motions to compel and enforce the judgment. It reasoned that under Puerto Rico statutes such as Act No. 9 (P.R. Laws Ann. tit. 32, § 3085), the decision whether the Commonwealth will indemnify officials for judgments is a benefit afforded to the defendants, not the plaintiff, who therefore lacks standing to demand payment from the government; any challenge to the Secretary of Justice's partial payment decision must come from the officials themselves.

civil rightsprocedure

The case involves plaintiff Ana M. Hirsbrunner suing her former employers for sex discrimination and retaliation under Title VII of the Civil Rights Act, along with related claims under Puerto Rico law. The defendants moved for summary judgment, arguing that the court lacked subject matter jurisdiction because the employers did not meet Title VII's requirement of having at least 15 employees. The court denied the motion, finding that there was a genuine issue of material fact regarding whether the defendants collectively employed the requisite number of employees in Puerto Rico, as the plaintiff had presented evidence of 20 employees. The court also dismissed the claims against one individual defendant, Claudia Rajchevich, due to lack of evidence of her involvement.

labor & employmentcivil rightsprocedure

In this copyright case, plaintiff Fernando Torres Negron alleged that defendants Antonio Rivera and J & N Records infringed his copyrights in songs he composed titled Noche de Fiesta and Bebo por Ti by commercially recording and distributing them without authorization or compensation after he shared the works orally with intermediaries. Following a jury trial that apparently favored the plaintiff, the court granted the defendants' renewed motions for judgment as a matter of law and dismissed related claims. The core reasoning centered on the plaintiff's failure to adequately prove the defendants' gross profits from the infringing phonorecords, including insufficient evidence of non-duplicative revenues, deductible expenses, and specific attribution to individual defendants or tracks, along with standing issues for later distributions.

propertyprocedure

This case involved plaintiffs Royal Siam Corporation and Surasak Srisang challenging the U.S. Citizenship and Immigration Services' denial of an H-1B visa extension petition for Srisang to work as a restaurant manager. The court reviewed the agency action under the Administrative Procedure Act, which allows reversal only if the decision is arbitrary, capricious, an abuse of discretion, or contrary to law. Plaintiffs had previously received an H-1B visa in 1999, but the agency denied the 2004 extension petition on grounds that the position did not qualify as a specialty occupation and due to findings of a fraudulent marriage. The court granted summary judgment to the defendants, finding that the agency's decision was supported by substantial evidence, properly applied the law, and adequately explained its departure from the prior approval, which is not binding precedent. Accordingly, the court denied the plaintiffs' motion for declaratory judgment.

immigration

This case involved plaintiffs who prevailed on their Americans with Disabilities Act claims against Wal-Mart for disability discrimination in employment, after originally bringing additional claims under the ADEA and Puerto Rico laws that were unsuccessful. The court addressed post-judgment motions for attorneys' fees under 42 U.S.C. § 12205, in which plaintiffs sought nearly $190,000 based on hours billed by three attorneys. The court granted the motions in part and denied them in part, reducing the requested fees after determining that the failed claims were related to the successful ones but that the hours expended were excessive, duplicative, and reflected overstaffing. The reductions were based on a line-by-line review of billing records to exclude unnecessary or redundant time.

civil rightslabor & employmentprocedure

In this case, petitioner Francisco Irizarry Mendoza filed a motion under 28 U.S.C. § 2255 seeking post-conviction relief from his guilty plea and sentence in a drug conspiracy and firearm case. He argued that the Rule 11 colloquy was defective because he was not informed that drug type and quantity were elements of the offense, rendering his plea unknowing, and that his sentence violated Apprendi and Blakely principles. The magistrate judge recommended denial after reviewing the plea agreement, which detailed the charges, penalties, and sentencing range, and the district court adopted the recommendation following de novo review. The court concluded that the plea was knowing and voluntary based on the written agreement and proceedings, and that Apprendi and Blakely claims lacked merit because the sentence did not exceed the statutory maximum. The § 2255 motion was therefore denied.

criminal lawprocedure

In this case, petitioner Rafael Seguí Rodríguez filed a motion under 28 U.S.C. § 2255 seeking to vacate his federal convictions for conspiracy to possess cocaine and aiding and abetting possession of 81 kilograms of cocaine, arguing that a five-year delay between indictment and trial violated his speedy trial rights and that his trial counsel provided ineffective assistance by failing to introduce a DEA report showing the government knew his location while he was incarcerated. The magistrate judge recommended denial of the petition, and the district court adopted that recommendation after de novo review. The court held that the speedy trial claims had already been rejected on direct appeal and were therefore barred from relitigation in collateral proceedings. It further concluded that the ineffective assistance claim failed because the petitioner could not show prejudice from the delay or that counsel's performance fell below an objective standard of reasonableness under Strickland v. Washington. The petition was denied without an evidentiary hearing.

criminal lawprocedure

This case involves plaintiff Norman T. Olson's federal civil action seeking a preliminary injunction to stop his ongoing prosecution in Puerto Rico courts for alleged bribery under Article 212 of the Commonwealth Penal Code. The district court denied the injunction, adopting the magistrate judge's report and recommendation to abstain under the doctrine of Younger v. Harris. The court determined that the three prerequisites for Younger abstention were met because state criminal proceedings were ongoing, the Commonwealth had a significant interest in enforcing its bribery laws, and the state forum afforded Olson an adequate opportunity to litigate his federal constitutional claims. The court also found that Olson had not shown bad faith, harassment, or other extraordinary circumstances that would warrant an exception to abstention.

criminal lawfederal powerprocedure

This case concerned the appropriate statute of limitations for moral rights claims under Puerto Rico's Intellectual Property Act in a dispute between plaintiff Fernando Torres-Negrón and defendants Sony Discos, Inc. and J & N Records. The court reconsidered its prior ruling and held that the limitations period for such claims is one year. The Intellectual Property Act is silent on the issue for moral rights, and its three-year period applies only to specific resale-value claims under a separate section. Moral rights protections are extra-patrimonial in nature and akin to tort claims for personal harm under the Civil Code's general fault and negligence provision, which carries a one-year limitations period, supported by policy considerations favoring prompt resolution of such claims to avoid fading evidence and liability confusion.

propertyproceduretorts & liability

This case is a personal injury diversity action in which plaintiffs Yomar Vazquez-Filippetti and her family obtained a jury verdict against Banco Popular de Puerto Rico and co-defendants. On limited remand from the First Circuit to address an apparent grant of prejudgment interest, the district court corrected a clerical error in its docket order and clarified that it had never ruled on plaintiffs' motion for prejudgment interest and attorneys' fees. Applying Puerto Rico Rules of Civil Procedure 44.1(d) and 44.3(b), the court denied the motion because defendants had not acted obstinately or rashly, as they made multiple good-faith settlement offers that plaintiffs rejected before the case went to trial. The court also ordered defendants to post a supersedeas bond in a specified amount.

proceduretorts & liability

This case concerned a challenge by a private schools association and individual Puerto Rico schools to Regulation 6458 and Law 116, which govern disclosure and distribution of textbooks by requiring certain information to parents' associations and limiting frequent edition changes. Plaintiffs alleged the measures violated their First Amendment rights to academic freedom and free speech by interfering with curriculum choices. Following a bench trial, the court made findings that textbooks form an integral part of lesson planning and are selected to align with each school's educational philosophy and mission. The court determined that any burden on speech was incidental, the rules were content-neutral, and they served the substantial government interest of protecting consumers from unnecessary costs without suppressing protected expression.

free speechbusiness & regulatorycivil rights

This case involved nineteen former employees of Puerto Rico's Department of Natural and Environmental Resources who sued several agency officials under 42 U.S.C. § 1983, alleging that they were subjected to political harassment, demotion, and termination because of their affiliation with the New Progressive Party. The defendants moved to partially dismiss the complaint on grounds including lack of due process and equal protection claims, Eleventh Amendment immunity, and qualified immunity. The court granted the motion in part, dismissing the due process claims for lack of a protected property interest in transitory appointments, dismissing damages claims against defendants in their official capacities, and dismissing the supplemental state-law claims without prejudice, while denying dismissal of the First Amendment and equal protection claims and finding it premature to grant qualified immunity. The core reasoning was that the complaint sufficiently alleged politically motivated adverse actions that violated clearly established constitutional rights, but plaintiffs lacked the requisite property interest or other elements for the dismissed claims.

civil rightslabor & employmentfederal power

The case involved a plaintiff employee suing her employer store and two individual coworkers for sexual harassment creating a hostile work environment, along with related claims of sex discrimination, unjust dismissal, and retaliation under Title VII of the Civil Rights Act and multiple Puerto Rico employment statutes. The court adopted the magistrate judge's recommendation and granted in part the individual defendants' motion to dismiss, dismissing the Title VII and Law 80 claims against them because those statutes do not impose liability on individuals who are not employers. The court denied dismissal of the claims under Puerto Rico Laws 100, 17, and 69, finding sufficient allegations of sexual harassment to proceed at this stage, and retained supplemental jurisdiction over the remaining state-law claims against the individuals because they shared a common nucleus of facts with the claims against the employer.

civil rightslabor & employment

This case involved a personal injury lawsuit brought by Yomar Vázquez-Filippetti and her family against Banco Popular de Puerto Rico (BPPR) and its insurer after she was struck and severely injured by a car while using an ATM at a BPPR branch in Ponce, Puerto Rico; the car had accelerated from the adjacent drive-thru lanes due to the layout placing the ATM user's back toward exiting vehicles with no barriers or adequate separation. A jury found BPPR 75% liable and awarded $6 million in damages. BPPR and its insurer filed a renewed motion for judgment as a matter of law under Federal Rule of Civil Procedure 50(b), arguing insufficient evidence of negligence. The court denied the motion, holding that the trial evidence was legally sufficient for a reasonable jury to conclude that the ATM's placement and lack of protective measures made a collision foreseeable and that BPPR's failure to mitigate this risk proximately caused the injuries.

torts & liabilityprocedure

In this case, plaintiff Rafael José Díaz Rodríguez, a well-known media personality, sued Dr. Arcelio Torres Mártir and the publisher of Vea Magazine for libel, unjust enrichment, and violations of his rights to self-image, name, and privacy under Puerto Rico law after the magazine published an advertorial featuring his photo and stating he was a client of the doctor's clinic without permission. The defendants moved for summary judgment, arguing that the plaintiff failed to show actual malice, actual damages, or unjust enrichment. The court denied the motion, finding that triable issues of material fact remained regarding whether the publication was false, whether actual malice could be shown, the extent of any damages, and whether the defendants were unjustly enriched by the use of the plaintiff's image. The decision was based on the summary judgment standard requiring sufficient evidence to create genuine disputes for trial, including the plaintiff's evidence of reputational harm and financial benefit to the defendants.

free speechcivil rightstorts & liability

Plaintiff Mary Flor Morón Barrada sued the Department of Education of Puerto Rico under Title VII of the Civil Rights Act of 1964, claiming national origin discrimination and retaliation after the denial of her application for a marketing teaching license. The defendant moved for summary judgment, arguing that the plaintiff had not established a prima facie case and that some claims were barred by res judicata and collateral estoppel. The motion was unopposed, and the court treated the defendant's statement of facts as uncontested. The court granted summary judgment, finding no evidence that the plaintiff was qualified for the license or that the denial was motivated by retaliation, including a lack of temporal proximity between her EEOC complaint and the adverse action. The court concluded there were no genuine issues of material fact and dismissed the case.

labor & employmentcivil rights

Plaintiff Miriam Ramirez, a former Puerto Rico Senator from the New Progressive Party, brought a §1983 action alleging violations of her First, Fifth, and Fourteenth Amendment rights after she and other party leaders were charged under Article 261 of the Puerto Rico Penal Code (the Riot Act) for participating in a peaceful protest to display the U.S. flag at the Office of the Women's Advocate. The only remaining claim sought declaratory and injunctive relief to invalidate the Riot Act. The district court dismissed the case for lack of subject matter jurisdiction, finding it moot because the charges against Ramirez had been dismissed for lack of probable cause, the Calderón administration was no longer in power, Ramirez was no longer an elected official, and the other prosecuted NPP leaders had been acquitted, rendering any opinion on the merits advisory.

free speechcriminal lawcivil rights