The Puerto Rico Court of Appeals recently ruled in the case of MCG Therapy Group LLC v. Maestre Rivera, docket number KLCE202500513. This decision addresses the disqualification of attorneys involved in a contract dispute, which has significant implications for legal representation rights in Puerto Rico.
MCG Therapy Group, LLC (MCG) filed a lawsuit against Arlene J. Maestre Rivera and others on April 3, 2023. The lawsuit involved claims of breach of contract, tortious interference, and damages. MCG later amended its complaint to include AM Therapeutic Service for Children, Inc. (AMTSC), an entity incorporated by Maestre Rivera. The case was initially heard in the Superior Court of Arecibo.
After several procedural incidents, the Superior Court issued a partial judgment on August 10, 2023, dismissing the cause of action related to a non-compete clause. MCG appealed this decision, but the appellate court confirmed the ruling on August 8, 2024. MCG then sought further review from the Puerto Rico Supreme Court, which initially denied the discretionary appeal but later granted certiorari for reconsideration.
The dispute escalated when the Superior Court disqualified three attorneys involved in the case. MCG challenged the disqualification of its attorneys, Kayra A. Dávila Torres and Catalina Sierra López, while Maestre Rivera contested the disqualification of her attorney, Jaime A. Alcover Delgado. Both parties filed petitions for certiorari to the Court of Appeals, seeking to review the disqualifications.
The Court of Appeals, consisting of Judges Grana MartÃnez, Pérez Ocasio, and Campos Pérez, ultimately ruled on August 25, 2026. The court found that the disqualification of Alcover Delgado was improper. The court stated, "the tribunal primario debe dar oportunidad para oÃr a la representación legal de la peticionaria Maestre Rivera y recibir prueba, antes de resolver si procede o no la descalificación decretada." This translates to the primary tribunal must provide the legal representation of petitioner Maestre Rivera the opportunity to be heard and present evidence before deciding on the disqualification.
The court emphasized the importance of due process, stating that the disqualification of an attorney should not occur without allowing the attorney a chance to defend themselves. The ruling highlighted that the disqualification process should include a hearing where evidence can be presented, adhering to the principles of fairness and justice.
In contrast, the court denied MCG's petition for certiorari regarding the disqualification of its attorneys. The court ruled that the disqualification of MCG's attorneys was not warranted based on the evidence presented. The judges noted that the procedural errors raised by MCG did not merit a reversal of the disqualification of its counsel.
This ruling has significant implications for future cases involving attorney disqualifications in Puerto Rico. It reinforces the necessity of due process in legal proceedings, ensuring that attorneys have the opportunity to defend their right to represent their clients. The decision also sets a precedent for how courts should handle disqualification motions, particularly regarding the requirement for evidentiary hearings.
Looking forward, this ruling may influence how attorneys approach disqualification motions and how courts evaluate such requests. The emphasis on due process could lead to more rigorous standards for attorney conduct and representation in future cases.
The parties involved in this case may still seek further appeals, although the ruling from the Court of Appeals is significant. There is no indication of any related cases pending at this time.