Garcia v. Island Program Designer, Inc.

BREYER, Chief Judge.

This appeal requires us to resolve a conflict between 1) a federal statute that gives federal tax claims first priority to a bankrupt company’s assets, 31 U.S.C. § 3713, and 2) a Puerto Rico “insurance company liquidation” statute with filing deadlines that can force those federal claims to the end of the priority queue. P.R.Laws Ann., tit. 26, § 4019(2). A special federal statute, governing federal preemption of state insurance laws, 15 U.S.C. § 1012(b), would require us to resolve the conflict in favor of Puerto Rico’s law — if that special federal statute applies. But,…