The Puerto Rico Court of Appeals recently dismissed an appeal filed by inmate José A. Márquez Sánchez, ruling that the court lacked jurisdiction to consider the case. This decision, issued on April 27, 2026, affects Márquez Sánchez and potentially other inmates seeking administrative remedies within the Department of Corrección y Rehabilitación (DCR).

The case arose after Márquez Sánchez submitted a request for evaluation to participate in a rehabilitation program, known as the Programa de Desvío. He claimed he had been waiting for over two years for a response regarding his application. The court's ruling emphasizes the importance of proper legal procedures and jurisdictional requirements in administrative appeals.

Background

José A. Márquez Sánchez is currently incarcerated in a penal institution in Ponce, Puerto Rico. On December 22, 2025, he filed a request for administrative relief regarding his application to the DCR's rehabilitation program. He argued that he had fulfilled the necessary requirements set forth in a previous administrative order from 2023. Despite this, he had not received any evaluation or response from the DCR.

On January 20, 2026, Márquez Sánchez was informed that his application had not yet been evaluated due to missing documentation and the full occupancy of the rehabilitation center. Feeling that his due process rights had been violated due to the delay, he sought judicial review of the DCR's decision, claiming it was arbitrary and capricious.

The Ruling

The Puerto Rico Court of Appeals, led by Judge Pérez Ocasio, ruled that it did not have jurisdiction to hear Márquez Sánchez's appeal. The court stated, "the administrative process has not concluded, and thus, the appeal is premature." The judges emphasized that a final decision from the DCR was necessary before the court could intervene.

The court explained that the response from the DCR was not a final decision but rather an initial response that did not include factual determinations or legal conclusions. The ruling highlighted the need for an inmate to exhaust all administrative remedies before seeking judicial review, stating, "the court cannot consider the merits of the appeal in the absence of a final determination from the agency."

Impact

This ruling underscores the procedural requirements for inmates seeking administrative remedies in Puerto Rico. It highlights the necessity for a final decision from the DCR before an appeal can be made to the court. This decision may set a precedent for future cases involving similar administrative appeals, reinforcing the importance of jurisdictional compliance.

The ruling also serves as a reminder to inmates and their advocates about the complexities of navigating the administrative justice system. Inmates must ensure that they follow the required procedures and exhaust all available remedies before seeking judicial intervention.

What's Next

While Márquez Sánchez's appeal has been dismissed, he may still pursue the necessary steps within the DCR to obtain a final decision on his application. Details were not available in the court filing regarding whether he plans to reapply or if there are any related cases pending.