Baum-Holland v. Hilton El Con Management, LLC, No. 18-2061 (1st Cir. 2020)Annotate this Case
The First Circuit affirmed the judgment of the district court granting summary judgment for Defendants and dismissing Plaintiff's tort action stemming from the death of Dr. George Holland while he was vacationing at a hotel located in Fajardo, Puerto Rico, holding that there was insufficient evidence to establish the causation element of Plaintiffs' tort claim.
Plaintiffs, Dr. Holland's wife and their children, asserted a tort claim under Article 1802 of the Puerto Rico Civil Code against the hotel, its insurer and other entities stemming from Dr. Holland's death while he was snorkeling close to an island near the hotel. The district court granted Defendants' motion for summary judgment in its entirety. The First Circuit affirmed, holding that Appellants did not point to evidence in the record from which a reasonable jury could rule in their favor as to the causation element of their tort claim, and therefore, summary judgment was appropriate.