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Do It For The Caselaw
Do It For The Caselaw
Do It For The Caselaw

Federal appellate decisions, explained in plain English for working lawyers and legal operators.

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May 31, 2026

Case Explained: Nos. 24-1786 25-1067 KEILA GARCÍA COLÓN v. STATE INSURANCE FUND CORPORATION INSURANCE COMPANY A, B AND C APPEALS FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO [Hon. Raúl M. Arias-Marxuach, U.S. District Judge] Before Gelpí, Hamilton,* and Aframe Circuit Judges Juan R. González Muñoz, with whom Gonzalez Muñoz Law Offices P.S.C., Natalia E. del Nido Rodríguez, and Casillas, Santiago & Torres LLC were on brief, for appellant Peter W. Miller, with whom Javier A. Vega Villalba, and Weinstein-Bacal, Miller & Vega, P.S.C. were on brief, for appellee * Of the Seventh Circuit, sitting by designation Case: 24-1786 Document: 00118410120 Page: 1 Date Filed: 02/27/2026 Entry ID: 6789376 – 2 – February 27, 2026 Case: 24-1786 Document: 00118410120 Page: 2 Date Filed: 02/27/2026 Entry ID: 6789376 – 3 – HAMILTON, Circuit Judge. Plaintiff Keila García Colón (“García”) works as a nurse for Puerto Rico’s State Insurance Fund Corporation (“SIFC”). In 2021, after making a complaint against another employee, she brought this suit alleging unlawful retaliation in violation of Title VII of the Civil Rights Act of 1964 and Puerto Rico Law 115. García won a jury verdict and was ultimately awarded $300,000 in damages These appeals are not about that verdict but about what came after. They present three distinct sets of issues. First the district court denied García’s motion for a permanent injunction. García challenges that denial. Second, the district court later awarded García approximately $301,000 in attorney fees and costs under the Title VII fee-shifting provision, 42 U.S.C § 2000e-5(k). García challenges the fee award as insufficient Third, the SIFC did not appeal the final judgment or the fee award Citing Puerto Rico Act No. 66-2014, as amended by Act No. 68-2023 P.R. Laws Ann. tit. 3, §§ 9141-42, the district court nevertheless stayed execution of the judgment and fee award until the Secretary of Justice approves a payment plan stretching out payments over at least three years. García also challenges that stay of execution We affirm the denial of the permanent injunction and the award of attorney fees and costs. We already lifted the stay of execution shortly after oral argument in October 2025. We explain our reasons in this opinion Case: 24-1786 Document: 00118410120 Page: 3 Date Filed: 02/27/2026 Entry ID: 6789376 – 4 – Part I of this opinion lays out the relevant facts and procedural history. Part II affirms the denial of a permanent injunction. Part III affirms the attorney fee award. Part IV explains why § 9141 cannot be applied to delay indefinitely the execution of this federal judgment I FACTUAL BACKGROUND AND PROCEDURAL HISTORY We state the facts in the light most favorable to the jury’s verdict, without necessarily vouching for the objective accuracy of each fact. Diaz v. Jiten Hotel Management, Inc., 671 F.3d 78, 80 (1st Cir. 2012) A GARCÍA’S EMPLOYMENT AND SEXUAL HARASSMENT COMPLAINT García has worked as a nurse since 2004 for the State Insurance Fund Corporation