The Puerto Rico Court of Appeals ruled on April 28, 2026, in the case of Loyda Colón Jiménez v. José R. Meléndez Figueroa (Docket TA2026CE00261), reinstating jurisdiction over a child support matter. This decision affects the ongoing support obligations of Meléndez Figueroa, who resides in Florida, and emphasizes the importance of child support enforcement across jurisdictions.
The case began when Loyda Colón Jiménez filed a motion for review of child support on May 10, 2024, claiming that the previously set amount of $200 per month was no longer adequate for her 14-year-old daughter’s needs. Colón Jiménez requested a review and an urgent referral for a pension examiner to reassess the support amount. The father, José R. Meléndez Figueroa, was reported to be living outside Puerto Rico, in Florida.
After several procedural steps, the pension examiner recommended an increase in child support to $907 per month. The Superior Court of Guayama accepted this recommendation on November 15, 2024. However, Meléndez Figueroa failed to comply with the payment order, leading Colón Jiménez to file multiple motions for contempt and to register an arrest order in Florida for his non-payment.
On January 26, 2026, the Superior Court of Caguas ruled that it lacked jurisdiction over Meléndez Figueroa, referencing the earlier ruling from Guayama. Colón Jiménez then sought a certiorari from the Court of Appeals, arguing that the Caguas court had erred in its jurisdictional assessment.
The Court of Appeals, led by Judge Boria Vizcarrondo, reviewed the case and determined that the Caguas court had indeed made an error regarding its jurisdiction. The court stated, "The forum primario sí cometió uno de los señalamientos de error, específicamente el que se refiere a su jurisdicción," meaning the primary court did commit an error regarding its jurisdiction.
The court emphasized that child support cases are of high public interest and that the obligation to provide support is a constitutional right. The ruling highlighted that the courts must ensure that children receive the necessary support and that jurisdiction can be established even when a parent resides outside Puerto Rico.
Going forward, this ruling reinstates the jurisdiction of the Puerto Rican courts over Meléndez Figueroa, allowing for the enforcement of child support obligations. It also sets a precedent for similar cases where one parent resides outside the jurisdiction, reinforcing the idea that courts can maintain authority over child support matters even when parents live in different states.
As for what’s next, the case has been sent back to the lower court for further proceedings, including a contempt hearing regarding Meléndez Figueroa’s failure to pay child support. There is potential for further appeals, but the immediate focus will be on the contempt proceedings in the Superior Court of Caguas.