Salvador E. Casellas

In this case, petitioner Walter Batiz filed a motion under 28 U.S.C. § 2255 to vacate his sentence from a prior criminal conviction, claiming ineffective assistance of counsel during pre-trial proceedings and plea negotiations. The claims were that counsel failed to explain the elements of the charged offense and the government's burden of proof, and failed to secure a 15-year plea offer as instructed. After an evidentiary hearing with testimony from the petitioner, his former counsel, and the prosecutor, the court denied the motion in full. It found the petitioner's testimony not credible and unsupported by the record, while crediting counsel's account of negotiations that reduced an initial offer from 40 years to 15 years, and concluded that the petitioner failed to satisfy either prong of the Strickland test for ineffective assistance.

criminal lawprocedure

This case involves employees of Puerto Rico's State Insurance Fund Corporation who were demoted from managerial positions after an audit of internal appointments made between 2001 and 2008. The plaintiffs alleged the demotions were politically motivated to replace Popular Democratic Party loyalists with New Progressive Party supporters, violating their rights under the Equal Protection, Due Process, and Contract Clauses of the U.S. Constitution, along with Puerto Rico law. Defendants moved to dismiss the complaint. The court granted the motion in part by dismissing the Due Process and Contract Clause claims with prejudice for failure to state a viable claim, but denied dismissal of the Equal Protection claim. It also rejected qualified immunity on the Equal Protection claims at the pleading stage, finding the rights clearly established though further factual development was needed, and declined to address the state-law claims.

civil rightslabor & employment

This diversity case involved plaintiffs from Vietnam who sued Sanco Metals and related parties for breach of contract and damages after allegedly being induced to pay nearly $3 million under agreements to extract steel and scrap metal from a Puerto Rico mill. Plaintiffs sought to annul their contract with Sanco, recover funds, and obtain judgments based on Puerto Rico contract law, tort principles, and unjust enrichment. The court granted partial summary judgment to the plaintiffs against Sanco, annulling the contract due to deceit in its formation—including use of a falsified inspection report—and ordering repayment of $2.28 million, while deferring claims against LAREB pending further discovery. The decision rested on uncontested facts showing material misrepresentations and the plaintiffs' inexperience as foreign investors, which supported nullification under Puerto Rico's doctrine of dolo rather than mere performance issues.

business & regulatorytorts & liability

This case involved a contract dispute between plaintiff Banks Channel, LLC, a North Carolina company, and two defendant companies from Washington and Barbados, who removed the action to federal court in Puerto Rico and sought to compel arbitration in Barbados under the parties' agreement. The plaintiff accepted the contract's validity but argued that the arbitration clause was inoperable under Puerto Rico law or, alternatively, that arbitration should occur in Puerto Rico instead of Barbados as an unreasonable forum. The court granted the defendants' motion, dismissed the case without prejudice, and enforced the arbitration clause. It reasoned that the Federal Arbitration Act mandates enforcement of a valid, broad arbitration agreement when the claims fall within its scope, that the plaintiff's objections did not address the general arbitration provision, and that forum selection for arbitration is enforceable absent fraud, coercion, or grounds for revocation under applicable law.

business & regulatoryprocedure

The case involved a former employee's state-court lawsuit against her employer for breach of contract and tort claims arising from alleged nonperformance under a severance agreement. The employer removed the action to federal court on the ground that the severance benefits formed part of an ERISA employee welfare benefit plan, triggering complete preemption under ERISA § 502(a)(1)(B). The employee moved to remand, contending that the well-pleaded complaint rule barred removal because the complaint made no reference to ERISA. The court denied the motion, reasoning that the severance plan involved an ongoing administrative program, was explicitly designated as an ERISA plan, and therefore fell within the scope of ERISA's civil-enforcement provision, which completely preempts the state-law claims and confers federal jurisdiction.

labor & employmentprocedurefederal power

The case Gutierrez v. Toledo involved plaintiffs suing Puerto Rico police officers and officials under 42 U.S.C. § 1983 and the Fourth and Fourteenth Amendments for alleged illegal search, seizure, false arrest, and deprivation of liberty. The defendants moved for summary judgment after discovery. The court granted the motion, dismissing the federal claims with prejudice and state law claims without prejudice, reasoning that there was no genuine issue of material fact and the defendants were entitled to judgment as a matter of law based on the evidence presented and plaintiffs' failure to properly oppose with supported facts.

civil rightsprocedure

The case involved a Title VII lawsuit filed by Sandra Haydee Romero-Perez, a correctional counselor at a federal detention center, against the U.S. Department of Justice and Bureau of Prisons, alleging sexual harassment by a lieutenant at her workplace. The district court granted the defendants' motion for summary judgment. The court determined that there was no genuine issue of material fact after reviewing the uncontested facts, which showed the agency had comprehensive anti-harassment policies that the plaintiff was aware of and that required reporting, along with annual training on the topic. The ruling followed application of Federal Rule of Civil Procedure 56 standards, including the requirement that the non-moving party present specific, competent evidence to rebut the motion rather than relying on unsupported allegations.

labor & employmentcivil rights

In this case, plaintiffs Replay, Inc. and others sued the Puerto Rico Secretary of the Treasury under 42 U.S.C. § 1983, alleging that the cancellation of their licenses and seizure of video entertainment machines without a warrant or probable cause violated their Fourth, Fifth, and Fourteenth Amendment rights, as well as related provisions of the Puerto Rico Constitution. The defendant moved to dismiss for failure to state a claim and Eleventh Amendment immunity. The court granted the motion in part and denied it in part, concluding that the Department of Treasury qualifies as an arm of the state entitled to Eleventh Amendment immunity, that takings claims failed because any taking was not for public use, and that the Parratt-Hudson doctrine applied to certain due process claims arising from unauthorized conduct.

civil rightspropertyprocedurefederal power

In this case, Marta Maldonado-Ortiz sued her former employer, HVPH Motor Corporation d/b/a Lexus de San Juan, under the Americans with Disabilities Act, Title VII of the Civil Rights Act of 1964, the Family and Medical Leave Act, and related state laws, alleging discrimination based on medical conditions, sexual harassment, and interference with FMLA rights. The U.S. District Court for the District of Puerto Rico granted the defendant's motion for summary judgment after reviewing the record under the applicable standard. The court found no genuine issues of material fact, determining that the plaintiff failed to establish a prima facie case under the ADA because she was not disabled within the meaning of the statute as defined by controlling precedent, did not suffer an adverse employment action, and could not perform essential job functions with or without accommodation, while her remaining claims under Title VII and the FMLA also lacked sufficient evidentiary support.

labor & employmentcivil rights

The case involved a former municipal employee who sued the Municipality of Aibonito and several officials under Section 1983, alleging that her transfer and resulting working conditions amounted to political discrimination based on her Popular Democratic Party affiliation, violating her First Amendment rights and leading to constructive discharge. The court granted the defendants' motion for summary judgment after reviewing the undisputed facts and applicable law. The court determined that the plaintiff failed to establish a prima facie case of political discrimination, as she did not suffer an adverse employment action, and the evidence did not support claims that the transfer lacked a legitimate basis or was politically motivated.

civil rightslabor & employment

This case involved relatives of passengers who died in a plane crash during a private international flight from the Dominican Republic to Puerto Rico, suing ATIS Corporation and its insurer under the Montreal Convention for wrongful death damages. The defendants moved to dismiss for lack of subject-matter jurisdiction, arguing the Convention applies only to commercial air carriers engaged in transporting passengers for hire. After an evidentiary hearing, the court granted the motion and dismissed the claims with prejudice, concluding that ATIS was not an air transport enterprise under the Convention because the flight was a private, unpaid arrangement among friends rather than a business operation.

proceduretorts & liability

In Gonzalez v. Hurley International, Inc., the plaintiff sued under Puerto Rico Law 21 claiming she was terminated without just cause from her role as the defendant's exclusive sales representative in Puerto Rico and the Caribbean. The defendant moved to compel arbitration, citing a 2007 Sales Representative Agreement that included a clause requiring binding arbitration in California for disputes arising from the contract. The plaintiff countered that the agreement expired in July 2009, before the December 2009 termination, and that a new non-contractual relationship had formed afterward. The court denied the motion to compel, holding that the arbitration provision did not govern the dispute because the agreement had expired and the question of whether the parties' conduct extended it fell to judicial determination rather than an arbitrator. The decision applied the Federal Arbitration Act and Puerto Rico contract law principles to assess the agreement's validity and scope.

business & regulatoryprocedure

This case involved a motion for attorneys' fees under 42 U.S.C. § 1988 by defendants who prevailed on federal civil rights claims under 42 U.S.C. § 1983, after those claims were dismissed on summary judgment and state tort claims were remanded to local courts. The court granted most of the requested fees for work on pleadings, discovery, summary judgment, and related matters, but denied fees for pretrial work. The reasoning centered on the fact that the federal and state claims were factually and legally interrelated, making segregation of much of the work impossible, while pretrial efforts could not be clearly attributed solely to the federal claims; the court followed precedents emphasizing equitable discretion to balance deterrence of frivolous federal claims with recovery only for work tied to those claims.

civil rightsprocedure

This case involved a foreclosure action filed by Citimortgage against defendants Reinaldo Paniagua Latimer, Cynthia Marie Muñoz Zayas, and their conjugal partnership for failure to pay a mortgage note, in which the court entered a default judgment after granting service by publication. Defendants later moved under Rule 60(b)(4) to vacate the 2009 default judgment, arguing that the plaintiff failed to comply with Rule 4.5 of the Puerto Rico Rules of Civil Procedure by not submitting a verified complaint or affidavit attesting to the merits of the claim. The court granted the motion, holding that the judgment was void because the improper service by publication deprived it of personal jurisdiction over the defendants. The decision rested on First Circuit precedent requiring strict adherence to Rule 4.5's affidavit or verification requirements for such service, and the case was dismissed without prejudice.

propertyprocedure

This case involves a breach of contract and damages claim under diversity jurisdiction, in which Plaintiff Plaza Realty alleged that Defendants concealed material facts about tenant leases, rent reductions, and financial conditions for a Puerto Rico shopping center property sold under an Option to Purchase Agreement and Deed, leading to an overstated purchase price. Defendants moved to dismiss based on a forum selection clause in the Option Agreement. Applying Federal Rule of Civil Procedure 12(b)(6) standards, the court reviewed the clause's enforceability and the complaint's allegations, ultimately denying the motion to dismiss and allowing the case to proceed in the current forum.

business & regulatoryproperty

The case involved a pro se prisoner suing federal officers under Bivens for allegedly seizing his cash, boat, and religious belt without probable cause during a 2005 vessel search tied to drug charges, claiming constitutional violations and seeking damages for the failure to return the property. The court granted the defendants' motion to dismiss. The core reasoning was that the claims were barred by collateral estoppel because the legality of the search had already been upheld in the plaintiff's criminal proceedings, sovereign immunity barred suits against the United States and officials in their official capacities, and qualified immunity protected the officers given the prior findings that the search was consensual and lawful as a border search.

criminal lawcivil rightsprocedureproperty

This case involved a commercial lease dispute in which the landlord defendants sought attorneys' fees and costs after prevailing on a motion for judgment on the pleadings that dismissed the tenant plaintiffs' claims, ordered them to vacate the premises, and required payment of holdover rent. The court granted the fee request in part and denied it in part, awarding $15,000 rather than the $25,450 sought. It based the award on an express provision in the lease agreement requiring the tenant to pay the landlord's reasonable fees in litigation arising from the lease, as well as Puerto Rico Rule of Civil Procedure 44.1 authorizing fees for obstinate or frivolous conduct by the losing party. The court found the requested hourly rate reasonable but reduced the total hours because the case was uncomplicated, lasted under three months, and involved no discovery, hearings, or trial.

propertyprocedurebusiness & regulatory

The case involved plaintiffs suing Puerto Rico officials, the Commonwealth, and the Puerto Rico Police Department under 42 U.S.C. § 1983, alleging that police entered their home pursuant to a search warrant supported by false statements, in violation of the Fourth Amendment. Co-defendants Commonwealth of Puerto Rico and PRPD moved to dismiss, arguing Eleventh Amendment immunity. The court granted the motion, ruling that the Commonwealth enjoys sovereign immunity from suit in federal court and that the PRPD is an alter ego entitled to the same protection, resulting in dismissal of the federal claims with prejudice and the supplemental state-law claims without prejudice.

civil rightsfederal powerprocedure

In Capezano v. Arcor Saic, the plaintiff, an Argentinian employee, sued his former employer for unjust dismissal, national origin discrimination and retaliation under Title VII, plus violations of COBRA notice requirements, after he was terminated in 2009 following complaints about the company's FDA regulatory compliance. The court granted the defendant's motion to dismiss the Title VII claims and related state-law claims with prejudice, but denied dismissal of the COBRA claims. It reasoned that the discrimination claim was time-barred for failure to file a timely EEOC charge, the retaliation claim failed because complaints to the FDA did not constitute protected activity under Title VII and lacked sufficient temporal proximity to show causation, and the defendant had not moved to dismiss the COBRA allegations.

labor & employmentcivil rightshealthcare

In this case, a municipal employee sued the Municipality of Guaynabo under Title VII, alleging that the Police Chief subjected her to unwanted sexual advances and that the municipality retaliated against her after she filed an internal harassment complaint. The municipality moved to dismiss the claims for failure to state a claim. The court applied the plausibility standard under Twombly and Iqbal, finding the sexual harassment allegations sufficient to proceed but dismissing the retaliation claims with prejudice because the complaint lacked specific factual details showing materially adverse actions or a hostile work environment tied to protected activity. The motion to dismiss was therefore granted in part and denied in part.

civil rightslabor & employment