Ocasio v. Comision Estatal de Elecciones

── Ocasio v. Comision Estatal de Elecciones ── Case No.: 24-1822 Court: Court of Appeals for the First Circuit Date: April 01, 2026 Category: General United States Court of Appeals For the First Circuit No. 24-1822 BELIA ARLENE-OCASIO; EFRAÍN COLÓN-DAMIANI, Plaintiffs, Appellees, v. COMISIÓN ESTATAL DE ELECCIONES; JORGE RIVERA RUEDA, in the official capacity as Acting President of the Comisión Estatal de Elecciones,* Defendants, Appellants. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO [Hon. Pedro A. Delgado-Hernández, U.S. District Judge] Before Gelpí, Hamilton,** and Aframe, Circuit Judges. Omar J. Andino Figueroa, with whom Luis R. Román-Negrón, Román Negrón Law, PSC, and Fernando Figueroa-Santiago, Solicitor General of Puerto Rico, were on brief, for appellants. Ryanne E. Perio, with whom George W. Shuster, Jr., Thomas B. Davis, Wilmer Cutler Pickering Hale and Dorr LLP, Fermín L. Arraiza-Navas, American Civil Liberties Union Foundation of Puerto * Pursuant to Fed. R. App. 43(c)(2), Jorge Rivera Rueda has been substituted for Jessika Padilla as President of the Comisión Estatal De Elecciones. ** Of the Seventh Circuit, sitting by designation. Rico, Adriel I. Cepeda Derieux, Victoria Ochoa, Theresa J. Lee, Sophia Lin Lakin, and American Civil Liberties Union Foundation were on brief, for appellees. April 1, 2026  AFRAME, Circuit Judge. Following a favorable judgment against the Comisión Estatal de Elecciones ("CEE") and the President of CEE in his official capacity (collectively, "Defendants") under 42 U.S.C. § 1983, Plaintiffs Belia Arlene-Ocasio and Efraín Colón-Damiani obtained an award of almost $65,000 in attorneys' fees under 42 U.S.C. § 1988. Defendants subsequently filed a "Notice of Injunction" with the district court, asserting that Plaintiffs were enjoined from collecting their fee award under Puerto Rico's financial reorganization plan, which was confirmed pursuant to the Puerto Rico Oversight, Management, and Economic Stability Act ("PROMESA"). The district court rejected Defendants' contention, concluding that the fee award was unrelated to Puerto Rico's debt restructuring. We reverse. I. A. In 2016, Congress enacted PROMESA to address Puerto Rico's financial crisis. Pub. L. No. 114-187, 130 Stat. 549 (2016) (codified at 48 U.S.C. §§ 2101-2241). Title III of PROMESA created a debt restructuring process "akin to municipal debt restructuring under Chapter 9 of the bankruptcy code." In re Fin. Oversight & Mgmt. Bd. for P.R., 899 F.3d 13, 18 (1st Cir. 2018). On May 3, 2017, Puerto Rico filed a debt restructuring petition under Title III ("the Title III petition"). Municipality of San Juan v. Puerto - 3 - Rico, 919 F.3d 565, 571 (1st Cir. 2019). After nearly five years, on January 18, 2022, the court charged with overseeing the Title III proceedings (the "Title III Court") issued a Confirmation Order ratifying Puerto Rico's Plan of Adjustment (together, the "Confirmed Plan") to restructure its debt. See In re Fin. Oversight & Mgmt. Bd. for P.R., 636 B.R. 1 (D.P.R. 2022). The Confirmed Plan took effect on March 15, 2022 (the "Effective Date"). In re Fin. Oversight & Mgmt. Bd. for P.R., 32 F.4th 67, 74 (1st Cir. 2022). Under the Confirmed Plan, all claims