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Jose A. Muniz-Olivari; Conjugal Partnership Muniz-Duran v. Stiefel Laboratories, Inc

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Not for Publication in West’s Federal Reporter

Before Lynch, Chief Judge, Boudin and Thompson, Circuit Judges.

In 2005, a jury found that Jose Muniz-Olivari had been promised continued employment by Stiefel Laboratories, Inc., and that Stiefel was in breach of that promise. Under Puerto Rico law, a breach of contract may give rise to both a contract claim under Article 1054 of the Civil Code, P.R. Laws Ann. tit. 31, § 3018, and a corollary tort claim under Article 1802, id. § 5141, so the jury was instructed on both. The jury awarded Muniz-Olivari about $600,000 for back pay, front pay, and benefits. It also awarded $100,000 each to Muniz-Olivari and his wife, Annabelle Duran-Lopez, for mental pain and suffering. On appeal, this court affirmed the finding of liability. Muniz-Olivari v. Stiefel Labs., Inc., 496 F.3d 29 (1st Cir. 2007).

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