The Supreme Court of Puerto Rico issued disciplinary sanctions against two attorneys on Dec. 3, 2025, for violations of professional ethics rules and legal statutes governing attorney conduct. The court sanctioned Juan E. Medina Quintana and Enrique J. León Malavé in case CP-2020-0016, marking another exercise of the court's disciplinary authority over members of the legal profession.
The disciplinary action stems from violations of multiple professional conduct standards. Attorney Enrique J. León Malavé received sanctions for violating Law 402 of May 12, 1950, which regulates attorney fee arrangements in worker compensation cases against employers. León Malavé also violated Professional Ethics Canons 23, 24, 35, and 38. Attorney Juan E. Medina Quintana faced sanctions for violating Professional Ethics Canons 24 and 38.
The case was processed under the supervision of Special Commissioner Hon. Eloína Torres Cancel, with representation from the Attorney General's Office including Attorney General Omar Andino Figueroa, General Attorney Mabel Sotomayor Hernández, and Assistant General Attorney Yaizamarie Lugo Fontánez. The respondent attorneys were represented by attorney Daisy Calcaño López.
Law 402 of 1950, codified at 32 LPRA sec. 3114 et seq., specifically governs the awarding of attorney fees in cases involving worker claims against employers. This statute establishes specific parameters for fee arrangements and attorney conduct in employment-related legal matters. Violations of this law can result in disciplinary action by the Supreme Court of Puerto Rico as the governing body for attorney conduct.
The Professional Ethics Canons cited in the disciplinary action establish fundamental standards for attorney behavior. Canon 23 addresses professional responsibility and client relations. Canon 24 governs attorney conduct regarding fees and financial arrangements with clients. Canon 35 relates to professional courtesy and relations with other attorneys. Canon 38 addresses general professional conduct standards that all licensed attorneys must maintain.
The court issued its decision per curiam, indicating unanimous agreement among the justices on the disciplinary measures. The decision was rendered by a panel that included Judge Rodríguez and Associate Judges, though the full composition was not completely detailed in the available documentation.
This disciplinary action reflects the Supreme Court of Puerto Rico's ongoing oversight of attorney professional conduct. The court stated it was "once again obligated to exercise our disciplinary faculty over members of the legal profession for violating the Professional Ethics Canons." This language suggests the court views attorney discipline as a necessary and recurring responsibility in maintaining professional standards.
The sanctions imposed included formal reprimands and warnings to both attorneys. These disciplinary measures serve as official notice of professional misconduct and remain part of the attorneys' professional records. While not as severe as suspension or disbarment, these sanctions signal serious concerns about the attorneys' professional conduct and serve as deterrents for future violations.
Professional misconduct cases in Puerto Rico follow established procedural requirements, including investigation, formal charges, and adjudication before the Supreme Court. The timeline from the case number CP-2020-0016 indicates the disciplinary process began in 2020, demonstrating the thorough review process required for professional sanctions.
The decision carries implications for attorney practice standards in Puerto Rico, particularly regarding fee arrangements in employment law cases. Attorneys practicing in this area must ensure compliance with both the specific requirements of Law 402 and the broader Professional Ethics Canons to avoid similar disciplinary action.
The case also highlights the collaborative enforcement structure between the Attorney General's Office and special commissioners in professional misconduct proceedings. This system ensures thorough investigation and prosecution of ethics violations while providing due process protections for accused attorneys.
For the legal profession in Puerto Rico, this decision reinforces the importance of strict adherence to professional conduct standards. The Supreme Court's willingness to impose sanctions demonstrates its commitment to maintaining public confidence in the legal profession through enforcement of ethical requirements.
The decision will be subject to the compilation and official publication process for Supreme Court decisions, with electronic distribution provided as a public service. This accessibility ensures the legal community and public have notice of professional conduct standards and enforcement actions.
Attorneys León Malavé and Medina Quintana must now comply with the terms of their sanctions while continuing their legal practice under the supervision and oversight of the Supreme Court of Puerto Rico's disciplinary system.