Garcia-Navarro v. Universal Insurance Company

── Garcia-Navarro v. Universal Insurance Company ── Court: Court of Appeals for the First Circuit Date: April 10, 2026 Category: General United States Court of Appeals For the First Circuit No. 24-1323 JACQUELINE GARCÍA-NAVARRO, Plaintiff, Appellant, v. UNIVERSAL INSURANCE COMPANY, Defendant, Appellee, HOGAR LA BELLA UNIÓN, INC., d/b/a Bella Unión; INSTITUTO MÉDICO FAMILIAR DEL ESTE, PSC; INSTITUTO MÉDICO FAMILIAR, INC.; MARÍA M. BETANCOURT; DR. OSCAR GARCÍA-ROMÁN; DR. IVONNE MAESTRE-GARCÍA; JOHN ROE, husband of Maria M. Betancourt; ABC INSURANCE CO.; ADMIRAL INSURANCE COMPANY; PUERTO RICO MEDICAL DEFENSE INSURANCE COMPANY; SIMED; CONJUGAL PARTNERSHIP ROE-BETANCOURT, Defendants. APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO [Hon. John A. Woodcock, Jr.,* U.S. District Judge] Before Barron, Chief Judge, Gelpí and Hamilton,** Circuit Judges. Paúl Rodríguez-Vélez, with whom PRV Law Office was on brief, for appellant. * Of the District of Maine, sitting by designation. ** Of the Seventh Circuit, sitting by designation.  José A. Andreu-Collazo, with whom José A. Andréu-Fuentes and Andrew & Sagardia were on brief, for appellee. April 10, 2026  BARRON, Chief Judge. This appeal arises out of a suit that Jacqueline García-Navarro ("García-Navarro") brought under Puerto Rico law after her mother died while residing in an assisted living facility in the Commonwealth. García-Navarro filed the suit in the United States District Court for the District of Puerto Rico based on diversity jurisdiction. She named as defendants, among others, the assisted living facility and its insurer, Universal Insurance Company ("Universal"). García-Navarro eventually settled her claims against all the defendants other than Universal and her claims against the insurer then proceeded to judgment on a stipulated record. The District Court ultimately entered judgment in favor of Universal based on a Puerto Rico Supreme Court decision that came down while García-Navarro's claims against the insurer were still pending. On appeal, García-Navarro contends that, in doing so, the District Court improperly gave that Puerto Rico Supreme Court decision "retroactive" effect and thus that we must reverse the judgment in favor of Universal.1 For the reasons that follow, we disagree and so affirm the challenged judgment. 1 García-Navarro's notice of appeal challenged: (1) the judgment entered in favor of Universal Insurance Company as to "whether there is indemnity coverage" found in ECF No. 571; (2) "the legal determinations and analysis" in the section "Evaluating Jacqueline García-Navarro's Arguments" of the Opinion and Order on Motion for Judgment on a Stipulated Record found in ECF No. 567, pages 49-53; (3) "the legal determinations and - 3 -  I. García-Navarro filed her suit on February 23, 2017. In her third amended complaint, she named as defendants, in relevant part, Hogar La Bella Unión, Inc. ("Hogar"), an assisted-living facility; and Universal. The complaint set forth Puerto Rico law claims that stemmed from events that occurred while García-Navarro's mother, Carlina Navarro-Ayala ("Navarro-Ayala"), resided at Hogar. Specifically, it set forth claims for negligence, commercial liability, commercial liability due to negligent clerical mistake, negligent staffing and hiring, and bad faith by Universal in denying coverage to Hogar under Hogar's general liability insurance policy. The complaint alleg