The Puerto Rico Supreme Court ruled in Carmen E. Reyes Cobián v. Autoridad de los Puertos de Puerto Rico (2026 TSPR 99) that going to the Judiciary’s Bureau of Alternative Methods for Conflict Resolution is a jurisdictional prerequisite to filing a court claim for workplace harassment under Article 10 of Law No. 90-2020, the Law to Prohibit and Prevent Workplace Harassment in Puerto Rico.
Chief Justice Maite D. Oronoz Rodríguez wrote the opinion. Associate Justice Luis F. Estrella Martínez concurred in part and dissented in part, and Associate Justice Camille Rivera Pérez did not participate. Reyes Cobián directed the Aerial Rescue Unit at Isla Grande Airport for the Puerto Rico Ports Authority (APPR) and had been a firefighter at Luis Muñoz Marín International Airport since 2012 until her 2015 transfer.
She alleged a hostile, discriminatory environment: no radio, a mobile wagon without a women’s bathroom, computer, phone or internet, and being the only woman on the team, with her requests ignored by Aerial Rescue chief Efraín Torres. She sued on October 21, 2022 under Law 100 (employment discrimination) and Law 90-2020. The Court of Appeals dismissed both claims.
The Supreme Court partly reversed, rejected the APPR’s argument that it is not an employer under Law 100, and held that its internal complaint process was not mandatory before suing. It said the bureau step requires no mediation or agreement, only that the bureau evaluate the mechanism and issue a recommendation. The case returns to the trial court for the Law 100 claim only.