Colon-Torres v. Negron-Fernandez, No. 18-1579 (1st Cir. 2021)
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The First Circuit vacated the order of the district court requiring immediate payment of a $10,000 settlement sum by Defendant, the Secretary of Corrections to Puerto Rico, and remanded with instructions to stay Plaintiff's effort to recover on the settlement, holding that the automatic stay provision of the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA) applied.
Plaintiff brought this suit under 42 U.S.C. 1983 against Defendant and others, alleging that the defendants had been deliberately indifferent to his medical needs while he was an inmate at the Baymon Correctional Facility. The parties eventually settled for $50,000. At issue was who was responsible to pay the remaining $10,000 of that sum. The district court ordered Defendant, and not the Commonwealth, to pay the balance of the settlement amount. Defendant appealed, arguing that Plaintiff's effort to collect the $10,000 should have been stayed under the automatic stay provision of PROMESA. The First Circuit agreed, holding that, given the manner in which Plaintiff styled his effort to recover, the automatic stay properly applied.
The court issued a subsequent related opinion or order on May 17, 2021.
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