DOCSLIB.ORG

Case 3:18-Cv-01095-SDD-EWD Document 58 03/24/20 Page 1 of 20

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Case 3:18-Cv-01095-SDD-EWD Document 58 03/24/20 Page 1 of 20 Case 3:18-cv-01095-SDD-EWD Document 58 03/24/20 Page 1 of 20 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA FUFC, LLC CIVIL ACTION VERSUS 18-1095 EXCEL CONTRACTORS, LLC, ET AL. RULING This matter is before the Court on the Motion to Dismiss1 by Scott Butaud (“Butaud”). Excel Contractors, LLC (“Excel”) has filed an Opposition2 to this motion. For the following reasons, Butaud’s Motion is DENIED under Rule 12(b)(2) and GRANTED under Rule 12(b)(6).3 I. FACTS AND PROCEDURAL HISTORY FUFC filed a Complaint4 on December 21, 2018 against Excel Contractors, alleging that after FUFC purchased the accounts receivable of Superior Disaster Relief, LLC (“Superior”), FUFC acquired invoices submitted to Excel by Superior. Because Superior had failed to pay for various goods and services, Excel became aware that multiple material suppliers hold or may hold claims against it due to Superior’s failure to pay for the goods and services supplied. In summary, various suppliers in Puerto Rico sold materials to Superior, who then invoiced Excel for the materials. Superior then sold those invoices to FUFC, who now has filed suit seeking 1 Rec. Doc. 35. 2 Rec. Doc. 37. 3 Rec. Doc. 35. 4 Rec. Doc. 1. 59449 Page 1 of 20 Case 3:18-cv-01095-SDD-EWD Document 58 03/24/20 Page 2 of 20 to compel Excel to pay it for the materials sold by the various suppliers in Puerto Rico. Consequently, because the funds sought by FUFC and potentially by the Puerto Rican suppliers are common in origin, Excel filed for statutory interpleader5 and was permitted to deposit funds into the registry of the Court.6 Excel also filed a Third Party Complaint asserting claims against Superior and Butaud.7 II. LAW AND ANALYSIS The Court first considers Butaud’s Motion to Dismiss under Rule 12(b)(2) for lack of personal jurisdiction. A. Rule 12(b)(2) i. Legal Standard “A federal district court has personal jurisdiction over a nonresident defendant to the same extent as a state court in the state in which the district court is located.”8 Thus, personal jurisdiction over a nonresident defendant attaches only when a defendant is amenable to service of process under the forum state's long-arm statute and the exercise of jurisdiction comports with the Due Process Clause of the Fourteenth Amendment.9 “Federal courts ordinarily follow state law in determining the bounds of their jurisdiction over persons.”10 “This is because a federal district court’s authority to assert personal jurisdiction in most cases is linked to service of process on a defendant ‘who is subject to the jurisdiction of a court of general 5 Rec. Doc. 14. 6 Rec. Doc. 57. 7 Rec. Doc. 7. 8 Walk Haydel & Assoc., Inc. v. Coastal Power Prod. Co., 517 F.3d 235, 242 (5th Cir. 2008). 9 LA. REV. STAT. art. 13:3201. 10 Walden v. Fiore, 571 U.S. 277, 283 (2014) (quoting Daimler AG v. Bauman, 571 U.S. at 125 (2014)). 59449 Page 2 of 20 Case 3:18-cv-01095-SDD-EWD Document 58 03/24/20 Page 3 of 20 jurisdiction in the state where the district court is located.”11 Consequently, the Court shall apply Louisiana law on personal jurisdiction to determine whether it has personal jurisdiction over Butaud. The Due Process and Long Arm Statute queries merge into one because Louisiana's long-arm statute extends jurisdiction coextensively with the limits of the Due Process Clause.12 Due process is satisfied for personal jurisdiction purposes when: (1) the defendant has purposefully availed itself of the benefits and protections of the forum state by establishing “minimum contacts” with that state, and (2) the exercise of personal jurisdiction does not offend “traditional notions of fair play and substantial justice.”13 The “purposeful availment must be such that the defendant ‘should reasonably anticipate being haled into court’ in the forum state.”14 The “minimum contacts” prong is split into two forms: general personal jurisdiction and specific personal jurisdiction.15 “Once a plaintiff has established minimum contacts, the burden shifts to the defendant to show that the assertion of jurisdiction would be unfair.”16 “Even if minimum contacts exist, the exercise of personal jurisdiction over a non-resident defendant will fail to satisfy due process requirements if the assertion of jurisdiction offends ‘traditional 11 Id. (quoting FED. R. CIV. P. 4(k)(1)(a)). 12 Moncrief Oil Int'l, Inc. v. OAO Gazprom, 481 F.3d 309, 311 (5th Cir. 2007); St. Martin & Mahoney v. Patton, 863 F.Supp. 311, 313–14 (E.D.La.1994). 13 Mark Doyle Construction, LLC v. TriHM Found., LLC, 2018 WL 3763014 at *6 (W.D. La. 2018) (citing Choice Healthcare, Inc. v. Kaiser Found. Health Plan of Colo., 615 F.3d 364, 367 (5th Cir. 2010)). 14 Ruston Gas Turbines, Inc. v. Donaldson Co., Inc., 9 F.3d 415, 419 (5th Cir. 1993) (quoting World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980)). See also Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475 (“This ‘purposeful availment requirement ensures that a defendant will not be haled into a jurisdiction solely as a result of ‘random,’ ‘fortuitous,’ or ‘attenuated’ contacts.”) (citations omitted); In re Chinese Manufactured Drywall Products Liability Litigation, 742 F.3d 576, 588 (5th Cir. 2014). 15 Choice Healthcare, 615 F.3d at 368. 16 Walk Haydel, 517 F.3d at 245 (quoting Wien Air Alaska, Inc. v. Brandt, 195 F.3d 208, 215 (5th Cir. 1999)). 59449 Page 3 of 20 Case 3:18-cv-01095-SDD-EWD Document 58 03/24/20 Page 4 of 20 notions of fair play and substantial justice.’”17 The second prong of the Due Process Clause analysis requires the Court to consider (1) the defendant’s burden, (2) the forum state’s interests; (3) the plaintiff’s interest in convenient and effective relief; (4) the judicial system’s interest in efficient resolution of controversies; and (5) the state’s shared interest in furthering fundamental social policies.18 Where a defendant has “substantial” and “continuous and systematic general business contacts” with the forum state, the court may exercise general personal jurisdiction over any action brought against the defendant.19 General personal jurisdiction is therefore appropriate when the defendant is essentially “at home in the forum state.”20 The “continuous and systematic contacts test is difficult to meet,”21 and its purpose is to enable potential defendants to “structure their primary conduct with some minimum assurance as to where that conduct will and will not render them liable to suit.”22 “[V]ague and overgeneralized assertions that give no indication as to the extent, duration, or frequency of contacts are insufficient to support general jurisdiction.”23 Where contacts are less pervasive, a court may still exercise specific jurisdiction “in a suit arising out of or related to the defendant's contacts with the forum”24 when the 17 Ruston Gas Turbines, 9 F.3d at 421 (quoting International Shoe Co. v. Washington, 326 U.S. 310, 316 (1945)). 18 Paz v. Brush Engineered Materials, Inc., 445 F.3d 809 (2006) (citing Ruston Gas Turbines, 9 F.3d at 421). 19 Daimler AG v. Bauman, 571 U.S. 117, 127 (2014). See also Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 414 (1984). 20 Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 919 (2011). 21 Blue Racer Midstream, LLC v. Kelchner, Inc., 2018 WL 993782 at *2 (N.D. Tex. 2018) (citing Johnston v. Multidata Systems Int’l Corp., 523 F.3d 602, 610 (5th Cir. 2008)). 22 Burger King, 471 U.S. at 472. 23 Cent. Freight Lines v. APA Transp. Corp., 322 F.3d 376, 381 (5th Cir. 2003) (quoting Johnston, 523 F.3d at 609). 24 Id. at 414; Luv N' Care, Ltd., v. Insta–Mix, Inc., 438 F.3d 465, 469 (5th Cir. 2006). 59449 Page 4 of 20 Case 3:18-cv-01095-SDD-EWD Document 58 03/24/20 Page 5 of 20 “nonresident defendant has purposefully directed its activities at the forum state.”25 The Fifth Circuit follows a three-step analysis for specific personal jurisdiction. First, a court must determine “whether the defendant has minimum contacts with the forum state, i.e., whether it purposely directed its activities toward the forum state or purposefully availed itself of the privileges of conducting activities there.”26 This minimum contacts/purposeful availment inquiry is fact intensive. No one element is decisive, and the number of contacts with the forum state is not, by itself, determinative.27 A single, substantial act directed toward the forum can support specific jurisdiction,28 but even multiple contacts, if “[r]andom, fortuitous, or attenuated . are not sufficient to establish jurisdiction.”29 For the purposes of specific personal jurisdiction, what is significant is whether the contacts suggest that the nonresident defendant purposefully availed himself of the privileges or benefits of the laws of the forum state.30 Second, a court considers “whether the plaintiff's cause of action arises out of or results from the defendant's forum-related contacts.”31 At this step, the proper focus in the analysis is on the “relationship among the defendant, the forum, and the litigation.”32 This is a claim-specific inquiry, as “the Due Process Clause prohibits the exercise of jurisdiction over any claim that does not arise out of or result from the defendant's forum 25 Choice Healthcare, 615 F.3d at 368 (quoting Walk Haydel, 517 F.3d at 243).
Load more

Recommended publications
  • District of Columbia Statehood and Voting Representation
    Updated June 29, 2020 District of Columbia Statehood and Voting Representation On June 26, 2020, the U.S. House of Representatives have included full statehood or more limited methods of considered and passed the Washington, D.C. Admission providing DC residents the ability to vote in congressional Act, H.R. 51. This marked the first time in 27 years a elections. Some Members of Congress have opposed these District of Columbia (DC) statehood bill was considered on legislative efforts and recommended maintaining the status the floor of the House of Representatives, and the first time quo. Past legislative proposals have generally aligned with in the history of Congress a DC statehood bill was passed one of the following five options: by either the House or the Senate. 1. a constitutional amendment to give DC residents voting representation in This In Focus discusses the political status of DC, identifies Congress; concerns regarding DC representation, describes selected issues in the statehood process, and outlines some recent 2. retrocession of the District of Columbia DC statehood or voting representation bills. It does not to Maryland; provide legal or constitutional analysis on DC statehood or 3. semi-retrocession (i.e., allowing qualified voting representation. It does not address territorial DC residents to vote in Maryland in statehood issues. For information and analysis on these and federal elections for the Maryland other issues, please refer to the CRS products listed in the congressional delegation to the House and final section. Senate); 4. statehood for the District of Columbia; District of Columbia and When ratified in 1788, the U.S.
    [Show full text]
  • Environmental Assessment for the Replacement of the Pier and Boat Ramp at the U.S
    Draft Environmental Assessment for the Repairs and Replacement of the Boat Ramp and Pier at the US Border Patrol Air and Marine Facility, Ponce, Puerto Rico Environmental Assessment for the Replacement of the Pier and Boat Ramp at the U.S. Border Patrol & Air and Marine Facility, Ponce, Puerto Rico U.S. Customs and Border Protection February 2019 Draft Environmental Assessment for the Repairs and Replacement of the Boat Ramp and Pier at the US Border Patrol Air and Marine Facility, Ponce, Puerto Rico Environmental Assessment for the Replacement of the Pier and Boat Ramp at the U.S. Border Patrol & Air and Marine Facility, Ponce, Puerto Rico Environmental Assessment for the Replacement of the Pier and Boat Ramp at the U.S. Border Patrol & Air and Marine Facility, Ponce, Puerto Rico Lead Agency: U.S. Customs and Border Protection (CBP) Proposed Action: The demolition and removal of the temporary structure, removal of the original pier, construction of a new pier, and replacement of the boat ramp at 41 Bonaire Street in the municipality of Ponce, Puerto Rico. The replacement boat ramp would be constructed in the same location as the existing boat ramp, and the pier would be constructed south of the Ponce Marine Unit facility. For Further Information: Joseph Zidron Real Estate and Environmental Branch Chief Border Patrol & Air and Marine Program Management Office 24000 Avila Road, Suite 5020 Laguna Niguel, CA 92677 [email protected] Date: February 2019 Abstract: CBP proposes to remove the original concrete pier, demolish and remove the temporary structure, construct a new pier, replace the existing boat ramp, and continue operation and maintenance at its Ponce Marine Unit facility at 41 Bonaire Street, Ponce, Puerto Rico.
    [Show full text]
  • Ruling America's Colonies: the Insular Cases Juan R
    YALE LAW & POLICY REVIEW Ruling America's Colonies: The Insular Cases Juan R. Torruella* INTRODUCTION .................................................................. 58 I. THE HISTORICAL BACKDROP TO THE INSULAR CASES..................................-59 11. THE INSULAR CASES ARE DECIDED ......................................... 65 III. LIFE AFTER THE INSULAR CASES.......................... .................. 74 A. Colonialism 1o ......................................................... 74 B. The Grinding Stone Keeps Grinding........... ....... ......................... 74 C. The Jones Act of 1917, U.S. Citizenship, and President Taft ................. 75 D. The Jones Act of 1917, U.S. Citizenship, and ChiefJustice Taft ............ 77 E. Local Self-Government v. Colonial Status...........................79 IV. WHY THE UNITED STATES-PUERTO Rico RELATIONSHIP IS COLONIAL...... 81 A. The PoliticalManifestations of Puerto Rico's Colonial Relationship.......82 B. The Economic Manifestationsof Puerto Rico's ColonialRelationship.....82 C. The Cultural Manifestationsof Puerto Rico's Colonial Relationship.......89 V. THE COLONIAL STATUS OF PUERTO Rico Is UNAUTHORIZED BY THE CONSTITUTION AND CONTRAVENES THE LAW OF THE LAND AS MANIFESTED IN BINDING TREATIES ENTERED INTO BY THE UNITED STATES ............................................................. 92 CONCLUSION .................................................................... 94 * Judge, United States Court of Appeals for the First Circuit. The substance of this Article was presented in
    [Show full text]
  • Testimony Medicaid and CHIP in the U.S. Territories
    Statement of Anne L. Schwartz, PhD Executive Director Medicaid and CHIP Payment and Access Commission Before the Health Subcommittee Committee on Energy and Commerce U.S. House of Representatives March 17, 2021 i Summary Medicaid and CHIP play a vital role in providing access to health services for low-income individuals in the five U.S. territories: American Samoa, the Commonwealth of the Northern Mariana Islands, Guam, Puerto Rico, and the U.S. Virgin Islands. The territories face similar issues to those in the states: populations with significant health care needs, an insufficient number of providers, and constraints on local resources. With some exceptions, they operate under similar federal rules and are subject to oversight by the Centers for Medicare & Medicaid Services. However, the financing structure for Medicaid in the territories differs from state programs in two key respects. First, territorial Medicaid programs are constrained by an annual ceiling on federal financial participation, referred to as the Section 1108 cap or allotment (§1108(g) of the Social Security Act). Territories receive a set amount of federal funding each year regardless of changes in enrollment and use of services. In comparison, states receive federal matching funds for each state dollar spent with no cap. Second, the federal medical assistance percentage (FMAP) is statutorily set at 55 percent rather than being based on per capita income. If it were set using the state formula, the matching rate for all five territories would be significantly higher, and for most, would likely be the maximum of 83 percent. These two policies have resulted in chronic underfunding of Medicaid in the territories, requiring Congress to step in at multiple points to provide additional resources.
    [Show full text]
  • Excavations at Maruca, a Preceramic Site in Southern Puerto Rico
    EXCAVATIONS AT MARUCA, A PRECERAMIC SITE IN SOUTHERN PUERTO RICO Miguel Rodríguez ABSTRACT A recent set of radiocarbon dated shows that the Maruca site, a preceramic site located in the southern coastal plains of Puerto Rico, was inhabited between 5,000 and 3,000 B.P. bearing the earliest dates for human habitation in Puerto Rico. Also the discovery in the site of possible postmolds, lithic and shell workshop areas and at least eleven human burials strongly indicate the possibility of a permanent habitation site. RESUME Recientes fechados indican una antigüedad entre 5,000 a 3000 años antes de del presente para Maruca, una comunidad Arcaica en la costa sur de Puerto Rico. Estos son al momento los fechados más antiguos para la vida humana en Puerto Rico. El descubrimiento de socos, de posible talleres líticos, de áreas procesamiento de moluscos y por lo menos once (11) enterramientos humanos sugieren la posibilidad de que Maruca sea un lugar habitation con cierta permanence. KEY WORDS: Human Remains, Marjuca Site, Preceramic Workshop. INTRODUCTION During the 1980s archaeological research in Puerto Rico focused on long term multidisciplinary projects in early ceramic sites such as Sorcé/La Hueca, Maisabel and Punta Candelera. This research significantly expanded our knowledge of the life ways and adaptive strategies of Cedrosan and Huecan Saladoid cultures. Although the interest in these early ceramic cultures has not declined, it seems that during the 1990s, archaeological research began to develop other areas of interest. With the discovery of new preceramic sites of the Archaic age found during construction projects, the attention of specialists has again been focused on the first in habitants of Puerto Rico.
    [Show full text]
  • Puerto Rico, Colonialism In
    University at Albany, State University of New York Scholars Archive Latin American, Caribbean, and U.S. Latino Latin American, Caribbean, and U.S. Latino Studies Faculty Scholarship Studies 2005 Puerto Rico, Colonialism In Pedro Caban University at Albany, State Univeristy of New York, [email protected] Follow this and additional works at: https://scholarsarchive.library.albany.edu/lacs_fac_scholar Part of the Latin American Studies Commons Recommended Citation Caban, Pedro, "Puerto Rico, Colonialism In" (2005). Latin American, Caribbean, and U.S. Latino Studies Faculty Scholarship. 19. https://scholarsarchive.library.albany.edu/lacs_fac_scholar/19 This Encyclopedia Entry is brought to you for free and open access by the Latin American, Caribbean, and U.S. Latino Studies at Scholars Archive. It has been accepted for inclusion in Latin American, Caribbean, and U.S. Latino Studies Faculty Scholarship by an authorized administrator of Scholars Archive. For more information, please contact [email protected]. 516 PUERTO RICO, COLONIALISM IN PUERTO RICO, COLONIALISM IN. Puerto Rico They automatically became subjects of the United States has been a colonial possession of the United States since without any constitutionally protected rights. Despite the 1898. What makes Puerto Rico a colony? The simple an­ humiliation of being denied any involvement in fateful swer is that its people lack sovereignty and are denied the decisions in Paris, most Puerto Ricans welcomed U.S. fundamental right to freely govern themselves. The U.S. sovereignty, believing that under the presumed enlight­ Congress exercises unrestricted and unilateral powers over ened tutelage of the United States their long history of Puerto Rico, although the residents of Puerto Rico do not colonial rule would soon come to an end.
    [Show full text]
  • Hunger and Poverty in Puerto Rico
    FACT SHEET MARCH 2019 Hunger and Poverty in Puerto Rico What’s the Problem? Even before Hurricanes Irma and Maria struck Puerto Rico in 2017, hunger and food insecurity were much more common among Puerto Ricans than among their fellow U.S. citizens in the 50 states. Before the hurricanes, 1.5 million Puerto Ricans were food insecure. The child food insecurity rate was 56 percent—nearly triple the average for the rest of the United States.1 Hurricane Maria was a Category 4 hurricane that caused extensive destruction. As of October 10, 2017, the Federal Emergency Management Agency estimated that only 15 per- cent of the island’s electricity had been restored2—leaving 85 percent of the island without electricity. The island was finally able to restore power for every resident in August 2018.3 For one year, families had limited opportunities of earning money for their basic needs such as food, water, and shelter—let alone the additional resources needed to rebuild their homes, farms, and businesses. This contributed to the majority of the island experiencing food insecurity right after the hurricanes. Unfortunately, the island still faces ongoing challenges to help residents overcome hunger. Recovery has been slow, in part, because assistance from FEMA to repair bridges and roads, clean debris, and rebuild homes has been difficult for some parts of the island, and for every resident, to access. Various iStock photo 5 PUERTO RICANS ARE FAR MORE LIKELY TO BE FOOD INSECURE barriers contribute to this, including residents not having U.S. Puerto Rico Rate Puerto Rico Rate the records or deeds for their homes.4 Rate (October 2017) (Today) Before the Hurricanes 11.8% 30-60%* N/A The Background After the Hurricanes 11.8% At least 85%** 38.3%*** In 1898, Puerto Rico became a permanent U.S.
    [Show full text]
  • The Status of Puerto Rico Revisited: Does the Current U.S.-Puerto Rico Relationship Uphold International Law?
    Fordham International Law Journal Volume 17, Issue 4 1993 Article 5 The Status of Puerto Rico Revisited: Does the Current U.S.-Puerto Rico Relationship Uphold International Law? Dorian A. Shaw∗ ∗ Copyright c 1993 by the authors. Fordham International Law Journal is produced by The Berke- ley Electronic Press (bepress). http://ir.lawnet.fordham.edu/ilj The Status of Puerto Rico Revisited: Does the Current U.S.-Puerto Rico Relationship Uphold International Law? Dorian A. Shaw Abstract This Note argues that the establishment of the Commonwealth government fails to fulfill the requirements of a free associated territory as detailed in United Nations General Assembly Resolu- tions 742 (“Resolution 742”) and 1541 (“Resolution 1541”) because the Puerto Rico Constitution remains subject to the Territorial Clause of the U.S. Constitution. The Territorial Clause gives the U.S. Congress plenary authority to govern territories of the United States. Part I of this Note introduces the factual and legal background of Puerto Rico’s hybrid legal status. Part II describes the different interpretations regarding the validity of Puerto Rico’s status in international law. Part III argues that the present status of Puerto Rico requires that the U.S. Congress enact legislation that allows a binding plebiscite to define the status of Puerto Rico in a manner consistent with U.N. General Assembly Resolutions 742 and 1541. Finally, this Note concludes that the U.S. Congress should act to prevent the continuation of a system of government where unequal treatment of U.S. citizens in Puerto Rico is allowed under the U.S.
    [Show full text]
  • PUERTO RICO Information on How Statehood Would Potentially Affect Selected Federal Programs and Revenue Sources
    United States Government Accountability Office Report to Congressional Requesters March 2014 PUERTO RICO Information on How Statehood Would Potentially Affect Selected Federal Programs and Revenue Sources GAO-14-31 March 2014 PUERTO RICO Information on How Statehood Would P otentially Affect S elected Federal Programs and Revenue Highlights of GAO-14-31, a report to Sources congressional requesters Why GAO Did This Study What GAO Found Puerto Rico has access to many Of the 29 federal programs GAO reviewed (which accounted for about 86 federal programs, and is subject to percent of federal program spending for states or their residents in fiscal year certain federal tax laws; however, for 2010), statehood would likely affect 11 programs. For 3 other programs, while some programs and for some aspects the programs themselves would likely not change under statehood, eligibility of tax law, Puerto Rico is treated determinations for these programs could be affected indirectly by changes that differently than the states. Options for could occur to benefits in other programs. Statehood would not likely affect the Puerto Rico’s political status include 15 remaining programs. See figure below. statehood. GAO was asked to review potential fiscal implications for federal programs if Puerto Rico were to become a state. This report examines potential changes to selected federal programs and related spending changes, and changes to selected federal revenue sources that would be expected should Puerto Rico become a state. This report also discusses economic and fiscal factors under statehood that could influence changes in spending and revenues. To evaluate potential changes to selected federal programs and revenue sources, GAO reviewed federal laws and regulations and interviewed federal and Puerto Rico agency officials.
    [Show full text]
  • Puerto Ricans in Orlando and Central Florida
    Centro de Estudios Puertorriqueños Hunter College (CUNY) Policy rePort | VOLUMe 1 | No. 1 |sPriNg 2006 Puerto Ricans in Orlando and Central Florida Jorge Duany Félix V. Matos-roDríguez Puerto Ricans in Orlando and Central Florida Jorge Duany Department of sociology and Anthropology University of Puerto rico, río Piedras This report was sponsored by the Orlando Regional Chamber of Commerce and Orange County Government. Félix V. Matos-roDríguez centro de estudios Puertorriqueños Hunter college, city University of New york Contents Summary of Main Findings . 2 Acknowledgments . 5 Introduction . 5 Changing Settlement Patterns . 8 Historical Background . 12 Centro de Estudios Puertorriqueños A Contemporary Socioeconomic Portrait . 15 Hunter College (CUNY) Political Incorporation . 22 695 Park Avenue, Room E-1429 New York, New York 10021 Cultural Identities . 24 212.772.5686 Toward a New Research Agenda . 26 www.centropr.org Conclusion . 29 Notes . 30 References . 33 Biographical Sketches . 39 ...2... ...1... SUMMARY OF MAIN FINDINGS • Between 1990 and 2000, the city of orlando experienced the largest increase (142 percent) in the number of Puerto ricans • During the 1990s, Florida displaced New Jersey as the second largest stateside. today, orlando is the fourth-largest metropolitan concentration of Puerto ricans in the U.s. mainland (after New york). area for Puerto ricans in the United states, after New york city, Florida’s Puerto rican population grew from slightly more than 2 percent Philadelphia, and chicago. of all stateside Puerto ricans in 1960 to more than 14 percent in the year • Puerto rican migration to central Florida is not highly selective by sex. 2000. Furthermore, the number of Puerto rican residents in Florida island-born and mainland-born residents have very similar proportions rose from 482,027 in 2000 to 571,755 persons in 2003.
    [Show full text]
  • Political Status of Puerto Rico: Brief Background and Recent Developments for Congress
    Political Status of Puerto Rico: Brief Background and Recent Developments for Congress R. Sam Garrett Specialist in American National Government June 12, 2017 Congressional Research Service 7-5700 www.crs.gov R44721 Political Status of Puerto Rico: Brief Background and Recent Developments for Congress Summary Puerto Rico lies approximately 1,000 miles southeast of Miami and 1,500 miles from Washington, DC. Despite being far outside the continental United States, the island has played a significant role in American politics and policy since the United States acquired Puerto Rico from Spain in 1898. Puerto Rico’s political status—referring to the relationship between the federal government and a territorial one—is an undercurrent in virtually every policy matter on the island. In a June 11, 2017, plebiscite (popular vote), 97.2% of voters chose statehood when presented with three options on the ballot. Turnout for the plebiscite was 23.0% of eligible voters. Some parties and other groups opposing the plebiscite had urged their bases to boycott the vote. (These data are based on 99.5% of precincts reporting results.) After initially including only statehood and free association/independence options, an amended territorial law ultimately permitted three options on the plebiscite ballot: statehood, free association/independence, or current territorial status. Before the latest plebiscite, Puerto Ricans most recently reconsidered their status through a 2012 plebiscite. On that occasion, voters were asked two questions: whether to maintain the status quo, and if a change were selected, whether to pursue statehood, independence, or status as a “sovereign free associated state.” Majorities chose a change in the status quo in answering the first question, and statehood in answering the second.
    [Show full text]
  • Puerto Rico and Florida Manatees Represent Genetically Distinct Groups
    Puerto Rico and Florida manatees represent genetically distinct groups Margaret E. Hunter, Antonio A. Mignucci-Giannoni, Kimberly Pause Tucker, Timothy L. King, Robert K. Bonde, Brian A. Gray, et al. Conservation Genetics ISSN 1566-0621 Conserv Genet DOI 10.1007/s10592-012-0414-2 1 23 Your article is protected by copyright and all rights are held exclusively by Springer Science +Business Media Dordrecht 2012 (outside the USA). This e-offprint is for personal use only and shall not be self-archived in electronic repositories. If you wish to self-archive your work, please use the accepted author’s version for posting to your own website or your institution’s repository. You may further deposit the accepted author’s version on a funder’s repository at a funder’s request, provided it is not made publicly available until 12 months after publication. 1 23 Author's personal copy Conserv Genet DOI 10.1007/s10592-012-0414-2 RESEARCH ARTICLE Puerto Rico and Florida manatees represent genetically distinct groups Margaret E. Hunter • Antonio A. Mignucci-Giannoni • Kimberly Pause Tucker • Timothy L. King • Robert K. Bonde • Brian A. Gray • Peter M. McGuire Received: 10 January 2012 / Accepted: 24 September 2012 Ó Springer Science+Business Media Dordrecht 2012 (outside the USA) 2012 Abstract The West Indian manatee (Trichechus manatus) suggested reclassification of the species to a threatened or populations in Florida (T. m. latirostris) and Puerto Rico delisted status. However, the two populations are geo- (T. m. manatus) are considered distinct subspecies and are graphically distant, morphologically distinct, and habitat listed together as endangered under the United States degradation and boat strikes continue to threaten the Puerto Endangered Species Act.
    [Show full text]