Medina Morales, Carina v. Estado Libre Asociado De Puerto Rico
KLAN202400891
Tribunal De Apelaciones De Pue...Oct 31, 2024Background
- Carina Medina Morales and Solanya Vargas González, former Examiners at the Puerto Rico Retirement Board, sued the Commonwealth, the Retirement Board, and its administrator Luis M. Collazo Rodríguez for wrongful termination on May 31, 2019.
- Plaintiffs alleged: (1) dismissal without due process for career employees; (2) retaliation (under Law 115); (3) political discrimination; (4) Vargas also alleged age discrimination.
- The lower court dismissed the due process, political discrimination, and age discrimination claims, but allowed the claims for retaliation and workplace harassment to proceed, finding unresolved factual disputes.
- Defendants moved to dismiss under PROMESA's injunction, arguing the claims were barred or "discharged" by the Commonwealth’s bankruptcy and confirmed Adjustment Plan; appealed after denial.
- The case reached the Court of Appeals on certiorari after the lower court and Supreme Court of Puerto Rico refused to dismiss or stay the remaining claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does PROMESA’s injunction bar plaintiffs’ harassment and retaliation claims? | Retaliation claims fall under "willful misconduct," which PROMESA does not discharge; trial on merits needed. | Claims are general dischargeable obligations under the Adjustment Plan; should be enjoined and dismissed. | Not barred; claims of "willful misconduct" are expressly excluded from discharge; must proceed to trial. |
| Did the lower court err in refusing to summarily dismiss the claims? | There are material factual disputes about retaliation needing trial. | All claims should be summarily dismissed per PROMESA’s injunction and Adjustment Plan. | Lower court did not err; factual disputes on retaliation/harassment must proceed to trial. |
| Should the doctrine of vicarious liability apply to Collazo in his official capacity? | Collazo engaged in actionable conduct in his official capacity. | Collazo’s acts were as administrator, shielded by Board immunity under PROMESA. | Claims against Collazo in official capacity survive for conduct alleged in reprisals; not shielded by PROMESA. |
| Did the Court abuse its discretion by failing to follow PROMESA’s adjustment plan? | Claims fit established PROMESA exceptions, notably “willful misconduct.” | PROMESA demands full preclusion of all prior/pending claims, with no exceptions. | No abuse; Board’s wide discretion and established PROMESA exceptions recognized. |
Key Cases Cited
- Torres González v. Zaragoza Meléndez, 211 DPR 821 (guides certiorari discretion standards in Puerto Rico courts)
- IG Builders et al. v. BBVAPR, 185 DPR 307 (defines scope of appellate review of interlocutory orders, including use of certiorari)
- García v. Asociación, 165 DPR 311 (sets standard for appellate intervention in trial court’s discretionary procedural rulings)
- COTIARI v. Dpto. de Hacienda, 203 DPR 1031 (Puerto Rican courts’ concurrent jurisdiction to decide application of PROMESA stay)