Puerto Rico's Financial Reorganization Plan Reverses Attorneys' Fee Award
A U.S. District Court ruling has been reversed concerning an award of nearly $65,000 in attorneys' fees to plaintiffs Belia Arlene-Ocasio and Efraín Colón-Damiani. The plaintiffs had previously won a favorable judgment against the Comisión Estatal de Elecciones and its President under 42 U.S.C. §1983. However, the defendants filed a 'Notice of Injunction' claiming that the plaintiffs were barred from collecting the fee award due to Puerto Rico's financial reorganization plan under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The district court initially rejected this claim, stating the fee award was unrelated to Puerto Rico's debt restructuring. The appellate court has now reversed this decision, citing that the plaintiffs' claim for attorneys' fees is a post-petition claim against Puerto Rico and was discharged under the confirmed plan and §944 of the Bankruptcy Code.