Garcia-Navarro v. Universal Insurance Company

CourtCourt of Appeals for the First Circuit
DecidedApril 10, 2026
Docket24-1323
StatusPublished

This text of Garcia-Navarro v. Universal Insurance Company (Garcia-Navarro v. Universal Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Garcia-Navarro v. Universal Insurance Company, (1st Cir. 2026).

Opinion

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 alleges, in relevant part, the following.

Navarro-Ayala suffered from anemia while at Hogar. María

Betancourt ("Betancourt"), the licensed practical nurse who opened

Hogar, incorrectly informed the doctors that Navarro-Ayala was a

Jehovah's Witness. Based on that erroneous information, the

analysis" in the "Issue Preclusion" and "Law of the Case and Coverage Exclusions" portions of the Order on Cross Motions for Partial Summary Judgment found in ECF No. 473, pages 71-76; and (4) "the legal determinations and analysis" in portions of the "Application of the Settlement Agreement" section of the Opinion and Order on Pending Motions found in ECF No. 427, pages 46-58. Appellant's opening brief, however, only specifically mentions the judgment entered in Universal's favor, the Order on Cross Motions for Partial Summary Judgment, and the Judgment on a Stipulated Record. Because the basis for her argument as to all three of those orders is the same, we proceed in the opinion without delineating between the three specific orders.

- 4 - doctors treating Navarro-Ayala while she was at Hogar did not order

a blood transfusion for her, even though she had chronic anemia.

As a result, Navarro-Ayala died from heart failure on

March 26, 2016. Universal was Hogar's insurer at all relevant

times but, in bad faith, denied Hogar's claim for coverage under

its insurance policy for its alleged liability to García-Navarro.

On August 15, 2018, Universal filed a motion for summary

judgment to dismiss García-Navarro's claims against it. The motion

argued that there was no genuine dispute of material fact that

Universal's general commercial liability insurance policy with

Hogar excluded from its coverage all bodily injury or property

damage that resulted from Hogar rendering "professional services."

The motion further argued that García-Navarro's claims against

Universal were all predicated on Hogar having engaged in acts and

omissions that constituted the rendering of "professional

services." Accordingly, the motion contended, Universal was

entitled to summary judgment on García-Navarro's claims against it

because it had no obligation under Hogar's insurance policy to

provide coverage to the assisted living facility for any of its

alleged liability to García-Navarro, as that liability was based

entirely on Hogar having rendered "professional services."

In opposing Universal's motion for summary judgment,

García-Navarro identified at least three actions by Hogar on which

her claims against Universal rested that she contended were

- 5 - ministerial and so did not constitute "professional services"

within the meaning of the insurance policy at issue. Those actions

were Hogar's: (1) failure to keep proper records; (2) failure to

call 911; and (3) failure to drive Navarro-Ayala to the hospital.

Accordingly, García-Navarro argued, the "professional services"

exclusion in Hogar's policy with Universal could not provide the

basis for Universal's denial of Hogar's claim for coverage and

therefore also could not provide the basis for Universal's defense

against García-Navarro's claim that Universal had denied Hogar

coverage in bad faith.

In its reply to García-Navarro's opposition to its

motion for summary judgment, Universal responded that the three

actions by Hogar that García-Navarro contended were

ministerial -- and so did not constitute "professional

services" -- did constitute "professional services" under Hogar's

insurance policy. In doing so, Universal relied on the Puerto

Rico Supreme Court's decision in Viruet v. SLG Casiano-Reyes, 2015

TSPR 160, which stated that "the failure to provide services

derived from the obligation to secure the wellbeing and security

of the elderly patients constitutes a professional service."

On December 11, 2018, the judge assigned to

García-Navarro's case at the time, Judge William G.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Gomez
255 F.3d 31 (First Circuit, 2001)
United States v. Leahy
473 F.3d 401 (First Circuit, 2007)
United States v. Severino-Pacheco
911 F.3d 14 (First Circuit, 2018)
Rosario Domínguez v. Estado Libre Asociado De Puerto Rico
2017 TSPR 90 (Supreme Court of Puerto Rico, 2017)
Rivera Matos v. Triple-S Propiedad, Inc. Y ACE Insurance Company
2020 TSPR 89 (Supreme Court of Puerto Rico, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Garcia-Navarro v. Universal Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/garcia-navarro-v-universal-insurance-company-ca1-2026.