The Puerto Rico Court of Appeals recently dismissed an appeal from inmate Jonathan Murga Rodríguez regarding his access to medication. The court ruled that it lacked jurisdiction to hear the case because Rodríguez had not exhausted all administrative remedies available to him. This ruling affects not only Rodríguez but also other inmates who may face similar issues regarding their medical treatment while incarcerated.
The case, identified by docket number TA2026RA00210, was filed on April 29, 2026. Rodríguez claimed that he had been receiving Gabapentin, a medication for nerve pain, from 2022 until December 2025. However, he alleged that he stopped receiving the medication in December 2025, despite undergoing physical therapy and tests in 2026. He sought a court order to compel the Department of Corrections and Rehabilitation to provide him with the medication again.
Rodríguez's appeal stemmed from a request he made to the Department of Corrections and Rehabilitation, which he claimed was not adequately addressed. He argued that the department's failure to provide him with the medication constituted a denial of necessary medical care. However, the court found that the department had not issued a final decision that could be reviewed by the court.
The court explained that under existing regulations, a response from the department's evaluator is not considered a final decision. Instead, the inmate must first appeal to a coordinator within the department, who is responsible for issuing a final decision that can be reviewed by the court. The court emphasized that it could only review final decisions and that the lack of such a decision rendered Rodríguez's appeal premature.
In its ruling, the court stated, "the recurrent does not prove that the agency has issued a final decision that is reviewable by this Court." The panel included Judge Sánchez Ramos, Judge Romero García, and Judge Pérez Ocasio. They collectively determined that the appeal could not proceed due to jurisdictional issues.
This ruling highlights the importance of following proper administrative procedures before seeking judicial review. The court noted that the inmate must exhaust all available remedies within the agency before the court can intervene. The court also pointed out that the inmate's failure to include necessary documentation and adequately present his case further complicated the matter.
The impact of this ruling extends beyond Rodríguez. It underscores the procedural requirements that inmates must navigate when seeking medical treatment or other remedies while incarcerated. The decision serves as a reminder that inmates must adhere to established protocols and timelines when appealing administrative decisions.
Going forward, this ruling may influence how inmates approach similar issues regarding medical care and administrative appeals. It reinforces the necessity of exhausting all available remedies within the corrections system before seeking judicial intervention. This may lead to increased awareness among inmates about the importance of following procedural rules and timelines.
As for what’s next, it remains unclear whether Rodríguez will pursue further action within the administrative framework of the Department of Corrections and Rehabilitation. The court's ruling does not preclude him from seeking a final decision from the agency, which could then be subject to judicial review if he follows the proper procedures.