The Puerto Rico Court of Appeals recently ruled in a significant case regarding public access to information. The case, Nathanahel Arroyo Martínez v. Departamento De Justicia (Docket TA2026AP00337), centers on a dispute over the right of citizens to access government documents. This ruling affects not only the parties involved but also sets a precedent for how public information requests are handled in Puerto Rico.

The case began when Nathanahel Arroyo Martínez filed a complaint against the Department of Justice of Puerto Rico. The complaint arose after Arroyo Martínez sought access to documents related to an investigation involving the mayor of Isabela, Miguel E. Méndez Pérez. The mayor had alleged that Arroyo Martínez violated a protection order against him. After the Department of Justice concluded that there was insufficient evidence to pursue charges against the mayor, Arroyo Martínez requested various documents under the Transparency Law (Ley Núm. 141-2019).

Initially, the Department of Justice agreed to provide some documents, including a preliminary report and two sworn statements. However, they later reversed their decision, stating that the preliminary report was confidential and could not be released. Arroyo Martínez then filed a lawsuit claiming that the Department of Justice had provided incomplete information and had altered the documents he received. The Department of Justice responded by seeking to dismiss the case, arguing that they had fulfilled their obligation to provide non-confidential information.

The case eventually reached the Puerto Rico Court of Appeals after the lower court dismissed Arroyo Martínez's complaint, stating that it had become academic since the Department of Justice had provided all available information. Unsatisfied, Arroyo Martínez appealed, arguing that the lower court had made several errors in its handling of the case.

On May 22, 2026, the Court of Appeals ruled in favor of Arroyo Martínez, reversing the lower court's decision. The court emphasized the importance of public access to information, stating, "the citizens possess a right to access public information, allowing them to examine the content of records, reports, and documents compiled by the government of Puerto Rico during its governmental activities." The ruling highlighted that the preliminary report should be disclosed unless certain confidentiality criteria were met.

The panel of judges included Candelaria Rosa, Adames Soto, Campos Pérez, and Trigo Ferraiuoli. The court found that the lower court had erred in dismissing the case as academic, as it required a thorough examination of whether the requested documents could be disclosed or if they fell under confidentiality exceptions.

This ruling has significant implications for public access to information in Puerto Rico. It reinforces the rights of citizens to seek transparency from government agencies and ensures that requests for public documents are taken seriously. The court's decision also clarifies that cases should not be dismissed as academic without a proper evaluation of the documents in question.

Going forward, this ruling sets a precedent for how public information requests will be handled in Puerto Rico. It emphasizes the need for government agencies to provide clear justifications when denying access to documents. The decision also serves as a reminder that citizens have the right to challenge such denials in court.

As for what’s next, it is unclear whether the Department of Justice will seek to appeal this ruling. There may also be related cases pending that could further clarify the application of the Transparency Law in Puerto Rico. The court has sent the case back to the lower court for further evaluation of the requested documents, which may lead to more developments in this ongoing legal landscape.