Carrasquillo-Serrano v. Municipality of Canovanas, No. 18-1701 (1st Cir. 2021)Annotate this Case
The First Circuit affirmed the judgment of the district court denying the Municipality of Canovanas's Fed. R. Civ. P. 60(b) motion to overturn the default judgment entered for Plaintiffs on Plaintiffs' claims brought under the Emergency Medical Treatment and Labor Act (EMTALA), 42 U.S.C. 1395dd, and Puerto Rico law, holding that Canovanas's arguments were unavailing.
Plaintiffs, Julio Carrasquillo-Serrano (Carrasquillo) and his family, alleged that Canovanas owned, operated, and/or managed CDT of Canovanas, the emergency medical facility that provided medical services to Carrasquillo and that Carrasquillo was permanently disabled as a result of Defendants' negligence. The district court entered judgment for Plaintiffs. The First Circuit affirmed, holding (1) the judgment was not void for lack of jurisdiction; (2) service of process was sufficient; (3) a statutory limitation of liability is an affirmative defense; and (4) the district court had jurisdiction to determine the merits of Plaintiffs' EMTALA claims.