Federal Court May Not Impose Sanctions for Misconduct Occurring in Prior State Court Action That Was Dismissed with Prejudice before Federal Action Was Filed

Rivera-Carrasquillo v. Centro Ecuestre Madrigal, Inc., 2016 U.S. App. LEXIS 1180 (1st Cir. Jan. 25, 2016):

Spending time astride an animal as magnificent, spirited, and powerful as a horse can be risky business. Unfortunately, Ángela Rivera-Carrasquillo experienced this first-hand when she was thrown from a horse in the midst of a guided ride she and her husband, José Hernández-Quiñones, were taking at a ranch outside San Juan, Puerto Rico.

Rivera suffered some pretty significant injuries in her fall, so she and her husband filed suit, and they ultimately secured a jury verdict in their favor at the Puerto Rico federal district court. In this Court, the appealing defendants say the district court erred in refusing either to grant them judgment as a matter of law or, failing that, to submit the question of whether the plaintiffs' suit is time-barred to the jury. They also argue [*2]  that certain parties may not be held liable for the negligence of the company who rented the horse to Rivera and put on the tour.

After careful review of the at-times-confusing trial record and counsels' appellate arguments, we are unable to discern the district court's reasons for its rulings. Because "we deem this a case where we feel we need the reasoning of the district court," Anderson v. Boston Sch. Comm., 105 F.3d 762, 764 (1st Cir. 1997), we remand for the district court to explain its decision with respect to the statute of limitations defense and articulate the ground(s) on which two of the defendants are liable for Rivera's injuries. And given our inability to parse what happened below from the limited record submitted on appeal (which keeps us from figuring out exactly what we should be reviewing and what standard of review we should apply), we necessarily explain in considerable detail just why we think remand is necessary.

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30   The parties seem to agree that if in fact the district judge sanctioned the defendants, he did so as a result of the defendants' conduct during discovery in Puerto Rico Superior Court. We are, of course, mindful of the defendants' argument that a federal judge [*48]  lacks the power to sanction a party for conduct occurring in a state court. See In re Lothian Oil, Inc., 531 F. App'x 428, 445 (5th Cir. 2013) (observing that a federal court's "inherent power to punish bad-faith conduct does not extend to actions in a separate state court proceeding"); Hunter v. Earthgrains Co. Bakery, 281 F.3d 144, 157 n.20 (4th Cir. 2002) (noting that a district judge "lacked authority under the federal rules to sanction [an attorney] for conduct occurring in state court"). We, however, can't tell what (if anything) the district court sanctioned or where, from the judge's perspective, any misconduct occurred. Accordingly, we note the argument has been raised, but we take no position on its merits and leave it to the district court to sort out (if necessary) in the first instance.

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