Rodríguez-García v. Municipality of Caguas

LYNCH, Circuit Judge.

The American common law rule is that generally the filing of a prior judicial action does not toll the statute, of limitations. Puerto Rico has chosen a different rule, permitting such tolling. That rule gives rise to this appeal.

The federal civil rights claims brought by Carmen L. Rodríguez-García, a terminated public employee, were not timely unless they were saved by tolling based on an earlier complaint that she filed in the courts of Puerto Rico and later amended. Her claims are tolled only if either her original or her amended complaint in the Puerto Rico courts was…