Lopez Cotto, Milagros v. Bayamon Medical Center
KLAN202201000
Tribunal De Apelaciones De Pue...Feb 29, 2024Background
- Milagros López Cotto worked as a registered nurse for Bayamón Medical Center (BMC) from 1987 until her dismissal on February 8, 2022.
- López Cotto suffered a permanent disability following cervical surgery, which required her to take a year-long medical leave under SINOT (Temporary Disability Benefits Law).
- After exhausting her disability leave, López Cotto requested a reasonable accommodation due to her medical limitations but was denied by BMC, which stated she was unable to safely perform essential job functions.
- López Cotto’s employment was terminated after her period of job reservation expired; she then filed claims for unjust dismissal, discrimination, and retaliation, invoking protections under various statutes including Law 80 (unjust dismissal), Law 44 (disability discrimination), Law 115 (retaliation), and Law 100 (general employment discrimination).
- The trial court granted BMC’s motion for summary judgment, finding the dismissal lawful, and dismissed López Cotto’s claims with prejudice. López Cotto appealed, challenging both the legal standard applied and the evaluation of her qualifications under disability statutes.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of Law 80 vs. Law 4, Art. 2.16 | Dismissal should be analyzed under Law 80 (unjustified dismissal, requiring compensation) | Dismissal governed by Law 4, Art. 2.16 (employment extinguished by incapacity post-reservation period) | Court applied Law 4, Art. 2.16, as it specifically governs dismissal post-reservation; no error. |
| Determination of Material Facts | TPI failed to consider date of hiring and arguments/evidence in opposition to summary judgment | Plaintiff failed to contradict key facts with admissible evidence or detailed responses on summary judgment | No manifest error or abuse of discretion in TPI’s findings; summary judgment appropriate. |
| Qualification under ADA/Law 44 | López Cotto was entitled to reasonable accommodation despite her disability | López Cotto could not perform the essential functions of her job, even with accommodation; thus not “qualified” | Not a qualified person under ADA or Law 44; employer not obligated to accommodate. |
| Retaliation/Discrimination Claims | Termination was discriminatory and/or retaliatory for her disability and activities | Termination was based on inability to perform essential job functions after a legally-defined leave period | Employer provided a legitimate nondiscriminatory reason; no pretext or evidence of discrimination found. |
Key Cases Cited
- Rivera v. Pan Pepín, 161 DPR 681 (P.R. 2004) (discussing presumption of unjustified dismissal under Law 80)
- Santiago v. Kodak Caribbean, Ltd., 129 DPR 763 (P.R. 1992) (internal regulations as employee rights under Puerto Rico law)
- Izagas Santos v. Family Drug Center, 180 DPR 463 (P.R. 2011) (job reservation during disability leave and reinstatement rights)
- Dávila Nieves v. Meléndez Marín, 187 DPR 750 (P.R. 2013) (standard for appellate review of factual determinations)
- Ramírez v. Policía de PR, 158 DPR 320 (P.R. 2002) (abuse of discretion standard for trial court fact-finding)