Keila García Colón, a nurse for Puerto Rico's State Insurance Fund Corporation (SIFC), sued alleging unlawful retaliation in violation of Title VII after complaining about sexual harassment. Following a jury verdict in her favor awarding $300,000 in damages, the district court denied her motion for a permanent injunction to reinstate her to her original office and expunge disciplinary records. The court also awarded her approximately $301,000 in attorney fees. However, citing Puerto Rico Act No. 66-2014, the district court stayed execution of the judgment and fee award, requiring SIFC to wait for the Secretary of Justice to approve a payment plan that could stretch over three years. García appealed these three distinct issues: the denial of the injunction, the sufficiency of the fee award, and the stay of execution.
The court addressed three issues. First, regarding the permanent injunction, the court clarified that while Rule 54(c) allows relief not explicitly pleaded if the issue was tried, the jury's general verdict on retaliation did not necessarily find that the specific transfer to the Manatí Dispensary was retaliatory. The district court had the authority to make independent factual findings, and its conclusion that the transfer was based on legitimate non-retaliatory reasons (nurse shortages and ADA accommodation for a co-worker) was not clearly erroneous. Second, on attorney fees, the court affirmed the district court's use of the lodestar method. It found no abuse of discretion in excluding 'generic' time entries that lacked sufficient detail and in applying a twenty percent downward adjustment for the plaintiff's limited success, given she voluntarily dismissed her sexual harassment claim and lost on the injunction request. Third, and most significantly, the court addressed the stay of execution. The court held that applying Puerto Rico Act No. 66-2014 to delay payment of a federal judgment violates the Supremacy Clause. While Federal Rule of Civil Procedure 69(a) generally defers to state procedures for execution, a state law that substantively frustrates federal remedies by allowing a public corporation to delay payment indefinitely is preempted. The court emphasized that Title VII's remedial policies require immediate enforcement, and state laws cannot create barriers that impede the 'private attorney general' role of civil rights plaintiffs.
The stay of execution on the $300,000 damages and $301,000 fee award was lifted, requiring SIFC to pay the plaintiff immediately. The decision establishes that Puerto Rico statutes cannot be used to delay the enforcement of federal civil rights judgments, reinforcing that federal supremacy overrides local laws that impede the immediate payment of federal court awards. The case is remanded for proceedings consistent with the opinion, ensuring the funds are disbursed without further delay.