Gomez v. Rodriguez-Wilson, No. 14-1538 (1st Cir. 2016)Annotate this Case
After Enrique Ojeda-Morales (Ojeda) died, his widow and his sister (collectively, Plaintiffs) filed a negligence action against two doctors, including Dr. Jorge Rodriguez-Wilson (Dr. Rodriguez), and related medical facilities. The medical facilities and one medical doctor (collectively, the settling parties) entered into settlement agreements with Plaintiffs. The district court dismissed the settling parties from the case, leaving Dr. Rodriguez as the sole defendant. After a trial, the jury concluded that Dr. Rodriguez’s negligent care was the proximate cause of Ojeda’s death and awarded Plaintiffs $475,000. The district court issued a judgment in favor of Plaintiffs. Dr. Rodriguez sought to alter the judgment, arguing that the jury’s damages award should be offset against the $700,000 that Plaintiffs received from the settling parties. The district court agreed and vacated the jury award. The First Circuit vacated the district court’s ruling, holding (1) the district court improperly vacated the jury award, as the district court misapplied Puerto Rico law when it implemented a dollar-for-dollar offset, and furthermore, Dr. Rodriguez waived any argument that he was entitled to offset; and (2) Dr. Rodriguez engaged in obstinate conduct trial trial, and therefore, the district court erred in refusing to grant Plaintiffs attorneys’ fees.