Crispin-Taveras v. Municipality of Carolina, 647 F.3d 1

Crispin filed a civil rights action in Puerto Rico against the Municipality of Carolina, officials, and others after a stadium incident in 2007.
Officers allegedly assaulted Crispin during stadium ejection; he sustained a head injury and was hospitalized.
Several defendants faced discovery disputes and sanctions for noncompliance; the district court imposed a liability default against some defendants.
Trial proceeded on damages; Crispin sought evidence of psychological treatment while the Municipality challenged disclosure shortcomings.
Jury awarded damages: Crispin $35,000 and individual officers $10,000 each; appellate review followed on multiple issues including service, sanctions, and evidentiary rulings.
Key procedural posture includes service defects under Rule 4(m), a default sanction for discovery violations, and challenging evidentiary and instruction rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether service of process complied with Rule 4(m) for individual defendants	Crispin argues service was timely or harmless.	Defendants claimed improper service; contested timing.	Service defects were not reversible; motions timely and waiver occurred; no abuse of discretion.
Whether the district court properly imposed default sanctions for discovery noncompliance	Crispin supported sanctions to enforce discovery.	Defendants forfeited objections by failing to respond timely.	Default sanctions affirmed; no abuse of discretion; forfeiture analysis applied.
Whether admission of Crispin's psychological treatment evidence was error under Rule 37(c) admissibility	Crispin identified treating physicians in disclosures; testimony should be allowed.	Ignored disclosure failures should preclude expert testimony.	No abuse of discretion; harmless error since records obtained by subpoena and undisclosed records were not used.
Whether the district court properly instructed on causation and damages	Jury should be instructed to award only if causation proven by preponderance.	Proposed causation instruction unnecessary; instructions already covered causation.	Instruction sufficed; no reversible error.

Perez-Sanchez v. Pub. Bldg. Auth., 531 F.3d 104 (1st Cir. 2008) (timeliness and waiver on Rule 4(m) matters; service issues)
Remexcel Managerial Consultants, Inc. v. Arlequin, 583 F.3d 45 (1st Cir. 2009) (sanctions under Rule 37(b); default as remedy for discovery violations)
Goya Foods, Inc. v. Unanue, 233 F.3d 38 (1st Cir. 2000) (plain-erro r standard in sanctions context; advance warning relevance)
Beisinger Indus. Corp. v. SEC, 552 F.2d 15 (1st Cir. 1977) (waiver and objections to motions under Rule 12(g)(2) and (h)(1)(A))
Rivera-Torres v. Ortiz Velez, 341 F.3d 86 (1st Cir. 2003) (forfeiture of objections due to failure to timely oppose motion)
White v. N.H. Dep't of Corr., 221 F.3d 254 (1st Cir. 2000) (standard for reversible error on jury instructions)
United States v. DeStefano, 59 F.3d 1 (1st Cir. 1995) (interpretation of trial instructions; causation framework)
Jadlowe v. United States, 628 F.3d 1 (1st Cir. 2010) (evidence-admissibility under Rule 37; abuse of discretion)