Oquendo-Lorenzo v. Hospital San Antonio, Inc., 47 F.4th 1

In July 2013 Jessica Oquendo-Lorenzo sought prenatal care at San Antonio Hospital; her newborn, J.L.O., suffered birth injuries, was hospitalized, and later died in August 2014.
Plaintiffs sued Hospital San Antonio, Inc. (HSA), Dr. Osvaldo Quiles-Giovannetti, and insurers for medical malpractice alleging negligence by hospital staff and physicians.
HSA moved for partial summary judgment asserting immunity/limited liability under Puerto Rico law: Article 41.050 (P.R. Laws Ann. tit. 26, § 4105) and Section 3077 (P.R. Laws Ann. tit. 32, § 3077). The district court denied the motion.
Parties reached a settlement: plaintiffs released claims against Quiles and insurers for $75,000 and against HSA’s insurers for $270,000; the settlement stipulated that, because the court had denied HSA’s cap defense, a $105,000 judgment would be entered against HSA if reconsideration failed. The district court entered judgment and HSA appealed.
While the appeal was pending, Puerto Rico enacted Law 99 (Aug. 13, 2017) amending Article 41.050 to broaden coverage. HSA filed a Rule 60(b) motion in district court seeking relief based on Law 99; the court denied it as foreclosed by the settlement. Appeals of the final judgment and the Rule 60(b) denial were consolidated.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Article 41.050 / § 3077 limit HSA's liability?	Oquendo: No; limits apply to public entities or specified professionals only.	HSA: § 4105 and § 3077 extend statutory caps to San Antonio Hospital and thus to HSA as operator.	Held: No. § 4105 extends § 3077 caps to specified healthcare professionals at the hospital, not to HSA, a private operator; § 3077 applies to public institutions, not private administrators.
Does Law 99 (2017) apply retroactively to confer caps on HSA?	Oquendo: No; the case had been finally adjudicated/settled before Law 99's enactment.	HSA: Law 99 contains an express retroactivity clause, so it governs pending cases back to June 27, 2011.	Held: Law 99 does not apply; the settlement and final judgment were entered before August 13, 2017, so the retroactivity exception excludes this dispute.
Was denial of HSA's Rule 60(b) motion an abuse of discretion?	Oquendo: Denial proper because settlement reserved only appellate remedies, precluding post-judgment district-court relief.	HSA: Intervening change in law (Law 99) merits Rule 60(b) relief.	Held: No abuse; settlement did not reserve district-court Rule 60(b) relief, so HSA’s remedy was appeal, not a post-judgment motion below.

Galvin v. U.S. Bank, N.A., 852 F.3d 146 (1st Cir. 2017) (consolidated appeals and independent jurisdiction principles)
Stone v. I.N.S., 514 U.S. 386 (U.S. 1995) (denial of Rule 60(b) motion is appealable as separate final order)
Puerto Rico v. S.S. Zoe Colocotroni, 601 F.2d 39 (1st Cir. 1979) (district court retains power to act in aid of an appeal)
Miller v. Sunapee Difference, LLC, 918 F.3d 172 (1st Cir. 2019) (de novo review of summary judgment denial)
Hannon v. City of Newton, 744 F.3d 759 (1st Cir. 2014) (de novo review of statutory interpretation)
In re Plaza Resort at Palmas, Inc., 741 F.3d 269 (1st Cir. 2014) (statutory interpretation begins and ends with text if unambiguous)
González Figueroa v. J.C. Penney Puerto Rico, Inc., 568 F.3d 313 (1st Cir. 2009) (federal courts in diversity predict state supreme court rulings)
Sangiovanni Hernandez v. Dominicana de Aviacion, C. Por A., 556 F.2d 611 (1st Cir. 1977) (stipulation accepted by court generally constitutes a binding, final compromise)
Mitchell v. First Nat. Bank of Chicago, 180 U.S. 471 (U.S. 1901) (a court's judgment binds the parties while it remains unmodified or unreversed)