The Puerto Rico Court of Appeals recently dismissed an appeal filed by Mariano Maldonado Pagán against the Department of Corrections and Rehabilitation (DCR) due to a lack of jurisdiction. This ruling, issued on August 13, 2026, affects individuals seeking administrative remedies within the correctional system and emphasizes the importance of following proper legal procedures.
Maldonado Pagán, who represented himself in the case, sought a judicial review of the DCR's decision to deny his request for nicotine patches, which were prescribed by a cardiologist to help him quit smoking. The court's decision highlights the procedural requirements that must be met before an appeal can be considered.
Background
The case began when Mariano Maldonado Pagán attended a medical appointment on June 2, 2023, where a cardiologist recommended that he start using nicotine patches. However, he claimed that the DCR did not provide these patches, prompting him to file an administrative remedy request (number Q-284-24) with the department.
After the DCR denied his request, stating that nicotine patches are not provided in correctional institutions, Maldonado Pagán filed a petition for reconsideration. He alleged that the DCR violated his due process rights by failing to provide him with a copy of his reconsideration request and the department's response. This led him to seek a judicial review from the Court of Appeals.
The Ruling
The court ruled that it lacked jurisdiction to hear Maldonado Pagán's appeal, stating, "the absence of jurisdiction brings several consequences, such as the nullity of the issued rulings." The judges emphasized that the court must ensure it has the authority to adjudicate a case before proceeding with any review.
The panel, which included Judge Rivera Marchand, Judge Mateu Meléndez, and Judge Boria Vizcarrondo, noted that Maldonado Pagán's appeal was premature. They explained that he had not yet received a final decision from the DCR regarding his request for reconsideration, which is necessary for the court to have jurisdiction. The judges stated, "until the DCR adjudicates the referred request for reconsideration, the term for the Recurrente to appeal before this Court has not begun to run."
Impact
This ruling underscores the importance of following procedural requirements when seeking judicial review of administrative decisions. Individuals in similar situations must ensure that they exhaust all administrative remedies before appealing to the courts. The court's decision serves as a reminder that premature appeals will be dismissed due to a lack of jurisdiction, which can hinder access to justice for those affected.
Furthermore, the ruling may set a precedent for future cases involving appeals from administrative decisions within Puerto Rico's correctional system. It reinforces the need for clarity in the administrative process and the importance of timely and appropriate responses from agencies.
What's Next
Maldonado Pagán can potentially appeal the ruling if he receives a final decision from the DCR regarding his reconsideration request. However, until that process is completed, he cannot pursue further legal action. Details were not available in the court filing regarding any related cases pending.