Alejandro-Ortiz v. P.R. Elec. Power Auth.

Orlando Alejandro-Ortiz (Alejandro) was injured by an electric shock during an encounter with a power line owned by Puerto Rico Electric Power Authority (PREPA). Alejandro and his wife, Sonia Rodriguez-Jimenez (Rodriguez), sued PREPA. The only claims at issue in this appeal were Rodriguez’s. PREPA moved for judgment as a matter of law under Fed. R. Civ. P. 50, arguing that Rodriguez’s claims were time barred by the relevant one-year statute of limitations. The district court denied the motion but submitted to the jury the question of whether Rodriguez had been reasonably diligent in pursuing her claims. The jury answered the question in the affirmative and found PREPA liable. PREPA then renewed its Rule 50 motion. The district court denied the motion, concluding that there was sufficient evidence for a jury to find that Rodriguez acted diligently in pursuing her claims. The First Circuit Court of Appeals reversed and vacated the award on Rodriguez’s claims, holding (1) the statute of limitations on Rodriguez’s claims had run; and (2) there remained no question for the jury to answer regarding Rodriguez’s claims, and therefore, the jury should never have been led down the path towards deliberation on Rodriguez’s claim. View "Alejandro-Ortiz v. P.R. Elec. Power Auth." on Justia Law