Puerto Rico's Financial Reorganization Plan Affects Attorney Fee Awards
A recent ruling by the 1st Circuit Court has reversed a previous award of nearly $65,000 in attorney fees to plaintiffs Belia Arlene-Ocasio and Efraín Colón-Damiani. The plaintiffs had won a favorable judgment against the Comisión Estatal de Elecciones and its President under 42 U.S.C. §1983. However, the defendants argued that the fee award was enjoined under Puerto Rico's financial reorganization plan, confirmed under the Puerto Rico Oversight, Management, and Economic Stability Act (PROMESA). The district court initially rejected this argument, but the 1st Circuit Court reversed the decision, stating that the plaintiffs' claim for attorney fees is a post-petition claim against Puerto Rico and is therefore discharged under the confirmed plan. 
