In this maritime tort case arising from a 2009 boating accident in Puerto Rico's territorial waters, plaintiffs Francisco Pérez-Ortiz and Efrain Cornier-Lancara were struck and injured by defendant Zambrana's boat while snorkeling, resulting in severe injuries to Ortiz including amputation of his left leg. Several family members, including Ortiz's purported common-law wife and various children, asserted claims for emotional distress damages. Defendants moved for partial summary judgment to dismiss those emotional distress claims. The court granted the motion, dismissing the claims of the non-witness family members with prejudice. It reasoned that federal admiralty law, which applies uniformly in navigable waters, bars recovery for negligent infliction of emotional distress by those who did not witness the accident and precludes supplementing or circumventing that rule with Puerto Rico law.
This case concerns the Colegio de Abogados de Puerto Rico's requirement that all attorneys licensed to practice in Puerto Rico courts participate in a life insurance program as a condition of membership. A prior decision in Romero v. Colegio had already ruled that this mandatory program violated members' First Amendment rights, yet the Colegio continued to enforce it, obstructed opt-outs, and delayed refunds. The court granted summary judgment to the plaintiff class, finding the Romero ruling had preclusive effect and that the Colegio's actions violated constitutional rights; it awarded over $4 million in damages (subject to opt-out adjustments), issued a protective order against misleading communications with class members, and rejected claims of Eleventh Amendment immunity. The core reasoning rested on issue preclusion, due process requirements for class notice and opt-outs, and the Colegio's independent status from the Commonwealth government.
The case involves a trust beneficiary suing the trustee for breach of fiduciary duty and duty of loyalty under Puerto Rico tort and contract law, based on allegations that the trustee made a risky investment in Bank of America stock through UBS Financial, causing the trust's value to drop sharply, and then failed to pursue legal action against UBS Financial. The defendant moved to dismiss for failure to join UBS Financial as an indispensable party under Federal Rule of Civil Procedure 19 or, alternatively, to compel arbitration under an agreement between the trustee and UBS Financial. The court analyzed whether UBS Financial qualified as a required party under Rule 19(a)(1), determining that it did not because complete relief could be accorded without it and its absence would not impair its interests or expose existing parties to inconsistent obligations, and thus did not reach the issues of joinder feasibility or dismissal under Rule 19(b); the opinion also addressed equitable estoppel arguments regarding arbitration.
This case involved a dispute between two Puerto Rico-based financial institutions, Oriental Financial Group Inc. and its subsidiaries versus Cooperativa de Ahorro y Crédito Oriental, both using variations of the name 'Oriental' and similar branding for banking and financial services. Plaintiffs alleged federal service mark infringement, dilution, and cyberpiracy under the Lanham Act, along with related claims under Puerto Rico trademark law and unfair competition statutes. After converting a preliminary injunction hearing into a bench trial on liability, the court found that Defendant's 2009 logo and color scheme created a likelihood of confusion with Plaintiffs' established marks and trade dress, constituting infringement under both federal and Puerto Rico law. The court enjoined Defendant from using the infringing elements but rejected the dilution and cyberpiracy claims due to insufficient evidence of bad faith or fame. Defendant's counterclaim for declaratory relief was resolved in line with these findings.
This diversity case involved a dispute over rights to certain payments (trade debt payments from publication sales) that served as collateral under a security agreement for a loan from Westernbank Puerto Rico (later succeeded by Banco Popular) to plaintiff Angulo-Mestas and his companies. The bank intervened seeking a declaratory judgment establishing its ownership of the collateral via its security interest, while defendants claimed priority based on an earlier assignment of the same accounts receivable in connection with a publishing distribution agreement. The court denied the bank's motion for reconsideration of a prior ruling and granted summary judgment to defendants, ordering disbursement of the deposited funds to them. The core reasoning was that the bank's belated perfection of its security interest could not defeat defendants' prior rights to the accounts receivable under applicable UCC rules as adopted in Puerto Rico.
This case concerns a dispute over liability for environmental cleanup costs at a Puerto Rico service station where underground storage tanks released hazardous substances. Plaintiffs sued Esso Standard Oil under federal environmental statutes, prompting Esso to file counterclaims and third-party claims seeking reimbursement under CERCLA for response costs unrelated to the tanks, plus indemnification under Puerto Rico law. The movants (plaintiffs and certain third-party defendants) sought judgment on the pleadings to dismiss the CERCLA claims, arguing both a security-interest exemption and insufficient pleading of compliance with the National Contingency Plan. The court denied the motion, holding that the amended pleadings adequately alleged facts showing substantial compliance with the NCP and that the movants were owners or operators rather than mere security-interest holders.