Natanael María, et al. v. Héctor Emilio Colón

Summary

The United States District Court for the District of Puerto Rico considers Defendant Héctor Emilio Colón’s motion for summary judgment in a diversity personal-injury action arising from alleged sexual abuse of Natanael María Román. The court concludes that Natanael’s Article 1802 tort claims are barred by Puerto Rico’s one-year statute of limitations, while the excerpted text begins but does not complete the court’s analysis of Natanael’s parents’ emotional-distress claims under Article 1536. The motion is granted in part and denied in part.

Holdings

1. Natanael's claims were time-barred because the record established that he possessed, or reasonably should have possessed, knowledge of his injury and the identity of the person who caused it no later than 2018 and, at the latest, by November 2020.
2. Natanael failed to produce evidence from which a rational jury could find that a reasonable adult in his position remained unable to recognize the alleged abuse before June 30, 2022.
3. Pastor López's testimony could not establish that Lorenzo knew of Natanael's abuse on June 27, 2022 because it relayed two out-of-court statements offered for their truth and no exception to either layer of hearsay was identified.
4. Summary judgment was denied as to the parents' derivative claims because a genuine dispute of material fact existed regarding when they acquired knowledge of Natanael's abuse.

Questions Presented

1. Whether Natanael's Article 1802 tort claims were barred by Puerto Rico's one-year statute of limitations because he knew or reasonably should have known of his injury and its cause before June 30, 2022.
2. Whether the summary-judgment record contained sufficient evidence, including evidence concerning grooming and delayed recognition of abuse, to create a genuine dispute regarding accrual of Natanael's claims.
3. Whether Pastor López's deposition testimony concerning statements by Lorenzo and Natanael was inadmissible hearsay within hearsay and therefore could not establish that Lorenzo knew of Natanael's abuse before July 2022.
4. Whether the text messages between Lorenzo and Pastor López established, as a matter of law, that Lorenzo knew of Natanael's abuse before June 30, 2022.
5. Whether summary judgment was appropriate on Natanael's parents' derivative Article 1536 claims.

Disposition

other