IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF PUERTO RICO

In re: 

THE FINANCIAL OVERSIGHT AND 

MANAGEMENT BOARD FOR PUERTO 

RICO, 

as representative of 

THE COMMONWEALTH OF PUERTO 

RICO, et al., 

Debtors.

PROMESA Title III 

No. 17 BK 3283-LTS (Jointly Administered) 

BRIEF OF THE CIVIL RIGHTS 

COMMISSION OF PUERTO RICO AS 

AMICUS CURIAE 

MOTION FOR LEAVE TO FILE AMICUS CURIAE BRIEF ON 

INTERNATIONAL HUMAN RIGHTS LAW STANDARDS FOR PUBLIC DEBT 

RESTRUCTURING

TO THE HONORABLE COURT:

COMES NOW the Civil Rights Commission of Puerto Rico, through the undersigned attorney, 

and before this Honorable Court respectfully states and prays as follows:

1. The Civil Rights Commission of Puerto Rico (hereinafter Commission) was created 

through Law No. 102 of June 28, 1965, as amended.1 Although its organizational structure is 

within the Legislative branch of the government of Puerto Rico, the Commission operates with 

complete autonomy and independence of the government. This entity operates as what, under 

international human rights law, is considered the National Human Rights Institution (NHRI) of 

our jurisdiction, vested with the responsibility to educate, investigate and seek redress for human 

and civil rights violations against people in Puerto Rico. As per Article 5 of the aforementioned 

 

1 1 L.P.R.A. §151 et seq.

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Act, the Commission, after the approval of a majority of the Commissioners, has the faculty to 

intervene in judicial processes as an amicus curiae.

2 The Commission is faithful to its duties to

(a) To educate the entire population on the significance of the fundamental rights

and the means of respecting, protecting and exalting them.

(b) To seek with individuals and before the government authorities’ protection of

the human rights and strict enforcement of the laws protecting such rights.

[...]

(e) To evaluate the laws, standards and acts of the Commonwealth and municipal

governments in connection with the civil rights, and to suggest reforms in respect

to same.

2. Concerned about the lack of discussion on human rights and international human rights

law standards within Puerto Rico’s public debt affairs, with the best interest to promote

adjudication practices aware of the human rights impact of debt restructuring, and with the express

mandate of the majority of its Commissioners3, this entity respectfully moves this Court for leave 

to participate as amicus curiae in this case.

3. Although the local rules do not address the issue of amicus curiae briefs, federal district 

“courts have inherent authority and discretion to appoint amici.” Boston Gas Co. v. Century Indem. 

Co., 2006 WL 1738312, at n.1 (D. Mass. June 21, 2006). Indeed, district courts “frequently 

welcome amicus briefs from non-parties concerning legal issues that have potential ramifications 

beyond the parties directly involved,” NGV Gaming, Ltd. V. Upstream Point Molate, LLC, 355 F. 

Supp. 2d 1061, 1067 (N.D. Cal. 2005), particularly when the amicus has “unique information or 

perspective that can help the court beyond the help that the lawyers for the parties are able to 

provide,” Ryan v. Commodity Futures Trading Comm’n, 125 F.3d 1062, 1064 (7th Cir. 1997). 

The amicus brief attached to this motion meets these standards. 

 

2 Art. 5, 1 L.P.R.A. §155

3 Civil Rights Commission of Puerto Rico, Resolution 2018-1, of March 2, 2018. 

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4. For the reasons stated above, the Civil Rights Commission of Puerto Rico respectfully

prays from this Honorable Court to grant the present motion and allow the attached amicus curiae

brief for filing. 

WHEREFORE, the Civil Rights Commission of Puerto Rico respectfully prays from this 

Honorable Court to grant the present motion and allow the attached amicus curiae brief for filing.

RESPECTFULLY SUBMITTED.

It is hereby certified that, on this same date, I electronically filed the foregoing with the 

Clerk of the Court using the CM/ECF system which will send notification of such filing to all 

parties who have made an electronic appearance.

In San Juan, Puerto Rico, on this 11th day of July, 2018.

/s/María A. Rodríguez Medina

USDC-PR 301404

In representation of

Civil Rights Commission of Puerto Rico

416 Ponce de León Ave.

Suite 901

San Juan, P.R. 00918

P.O. Box 192338

San Juan, P.R. 00919-2338

T.: (787) 764-8686

F.: (787) 250-1756

E.: mrodriguez@cdc.pr.gov

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