Summary
The Puerto Rico Court of Appeals affirmed the dismissal of a complaint seeking declaratory and injunctive relief against the suspension of correctional privileges as a security measure. The court held that the trial court lacked subject-matter jurisdiction because the claim was subject to the doctrines of primary jurisdiction and exhaustion of administrative remedies, and that an injunction was not the proper vehicle to challenge the measure.
Topics
Practice areas
Questions Presented
- Whether the Court of First Instance had jurisdiction to issue an injunction challenging correctional privilege suspensions imposed as security measures under Rule 9 of Regulation No. 9221.
- Whether the appellants were required to pursue and exhaust the administrative-remedy process before seeking judicial review.
- Whether the challenged security measures were administrative, rather than quasi-judicial, actions subject to the primary jurisdiction of the Department of Corrections' Division of Administrative Remedies.
Holdings
- An extraordinary injunction is not the appropriate legal vehicle for challenging a privilege suspension imposed as a security measure under Rule 9 of Regulation No. 9221.
- The appellants were required to pursue and exhaust the available administrative-remedy process before seeking judicial intervention, absent a statutory exception.
- A privilege suspension imposed under Rule 9 of Regulation No. 9221 is an administrative security action, not a quasi-judicial adjudication requiring a determination of an inmate's individual responsibility.
Key quotations
“Es decir, que consiste en una medida profiláctica de seguridad, que no requiere adjudicar la responsabilidad individual de confinado alguno.”
“En virtud de lo anterior, el foro judicial se encuentra impedido de pasar juicio, mediante la expedición de un recurso extraordinario de injunction, sobre la corrección o adecuacidad de suspender privilegios a la población correccional, en calidad de medida de seguridad.”
Factual background
The appellants, who were incarcerated at correctional institution 216 in Sabana Hoyos, alleged that correctional officials suspended multiple privileges after institutional searches uncovered illegal contraband. The suspensions were imposed as security measures under Rule 9 of Regulation No. 9221 and were extended after administrative hearings. The appellants sought declaratory and injunctive relief, including a declaration that Rule 9 was unconstitutional, but the record did not show that they had initiated and exhausted the administrative-remedy process under Regulation No. 8583.
Procedural history
The appellants filed suit in the Puerto Rico Court of First Instance, Superior Part of Arecibo, on January 30, 2026. The trial court dismissed the action on February 6, 2026, concluding that it lacked jurisdiction because the appellants had not exhausted available administrative remedies and there was no final agency determination. The appellants appealed on March 11, 2026. The Puerto Rico Court of Appeals affirmed, holding that the challenged security measures fell within the primary jurisdiction of the Department of Corrections' Division of Administrative Remedies and could not be challenged through an injunction in the Court of First Instance.