The Court of Appeals of Puerto Rico has upheld a decision allowing the Department of Corrección y Rehabilitación (DCR) to change the psychiatric medication of inmate Eliezer Santana Báez. The court ruled on September 29, 2026, confirming that the DCR acted within its rights when it substituted Santana Báez's medication due to production issues with the original drug. This ruling is significant as it clarifies the authority of correctional facilities in managing inmate health care.
Eliezer Santana Báez, currently incarcerated at the Bayamón Correctional Institution, filed a request for administrative relief on June 10, 2026, after his medication, Diphenhydramine, was changed without consultation with his psychiatrist. The DCR responded on June 30, explaining that the medication was unavailable due to production problems and that Hydroxyzine would be provided as a substitute. Santana Báez was not satisfied with this response and filed for reconsideration on July 1, which the DCR accepted. However, on August 11, the DCR confirmed its decision, stating that medical staff had the authority to make changes to medication.
The case reached the Court of Appeals after Santana Báez formally challenged the DCR's decision. He argued that the DCR improperly revoked a psychiatrist's order without proper medical justification. The court filing included references to the DCR's responsibilities under the law and the guidelines established in previous cases regarding inmate health care.
The court ruled that the DCR acted appropriately in changing Santana Báez's medication. The opinion stated, "The Tribunal cannot order the DCR to administer a medication to which it does not have access." The judges emphasized that the DCR was fulfilling its obligation to provide alternative medications when the prescribed ones are unavailable. The ruling was delivered by Judge Pérez Ocasio, alongside judges Candelaria Rosa and Mateu Meléndez.
In its decision, the court acknowledged the legal framework surrounding the rights of inmates to receive medical treatment. It noted that while inmates have the right to challenge administrative decisions, the DCR's discretion in medical matters must be respected. The court highlighted that the DCR's actions were consistent with established protocols for providing alternative medications when the original prescriptions cannot be fulfilled.
This ruling reinforces the authority of correctional facilities in managing inmate health care and clarifies the legal standards for medication changes within the prison system. It underscores the importance of ensuring that inmates receive necessary medical treatment while also allowing correctional facilities to operate effectively within their available resources.
Moving forward, this ruling may affect how similar cases are handled in the future, particularly regarding the rights of inmates to contest changes in their medical treatment. It sets a precedent for how correctional agencies can respond to medication shortages and the process for informing inmates of such changes.
Details were not available in the court filing regarding whether Santana Báez plans to appeal this decision. However, the ruling indicates that the DCR has the authority to make necessary adjustments to inmate medications without prior notification, as long as those adjustments are medically justified.
