In a recent ruling, the Puerto Rico Court of Appeals upheld the Department of Corrections and Rehabilitation's (DCR) decision to deny an inmate's request for a change in custody classification. Guarionex Candelario Rivera, who is serving a lengthy sentence for multiple serious crimes, sought to be reclassified from maximum to medium custody. This decision impacts Rivera and potentially sets a precedent for how custody classifications are handled for inmates in Puerto Rico.
The case, Guarionex Candelario Rivera v. Departamento De Corrección Y Rehabilitación, was filed on April 27, 2026, under docket number TA2026RA00068. Rivera, currently incarcerated at the Ponce Maximum Institution, has been serving a sentence of 203 years, seven months, and six days for first-degree murder and other violent offenses since December 23, 2016. The court's ruling is significant as it affirms the authority of the DCR to make discretionary decisions regarding inmate custody classifications based on the severity of their crimes.
Rivera's request for reclassification was reviewed by the DCR's Classification and Treatment Committee on December 12, 2025. The committee's assessment recommended that Rivera be moved to medium custody. However, the DCR ultimately decided to maintain his maximum custody status, citing the gravity of his offenses as a key factor in their decision. Rivera's subsequent request for reconsideration was denied on January 13, 2026, leading him to appeal the decision.
In his appeal, Rivera argued that the DCR had erred in its decision-making process, claiming that the committee did not follow the guidelines outlined in the Classification Manual. He contended that the DCR's determination was unreasonable and lacked sufficient evidence to justify the decision to keep him in maximum custody.
The court examined the case and the applicable law, noting that administrative decisions typically carry a presumption of correctness. The court stated, "The general rule is that the decisions of administrative agencies must be considered with great deference by appellate courts due to the expertise and experience of the agencies concerning the powers that have been delegated to them." This deference means that unless Rivera could demonstrate that the DCR's decision was unreasonable or not based on substantial evidence, the court would uphold the agency's ruling.
The court found that the DCR had appropriately exercised its discretion in maintaining Rivera's maximum custody classification. It pointed out that the committee had considered Rivera's history of violent behavior, which included serious crimes that were not fully reflected in his score for violent history. The court highlighted that the DCR's decision was based on various factors, including Rivera's expected parole date and his completion of certain rehabilitation programs.
The court concluded, "Given the complexity involved in managing a penal population, it is difficult to conclude that only the outcome of a form should determine the custody level or the dangerousness of an inmate." The ruling emphasized the necessity of allowing discretion in such decisions, affirming that the DCR's actions were reasonable and justified.
This ruling has implications for other inmates seeking to change their custody classifications in Puerto Rico. It reinforces the DCR's authority to make decisions based on individual circumstances and the seriousness of the crimes committed. Inmates may find it challenging to successfully appeal custody decisions if they cannot provide substantial evidence to counter the agency's findings.
Looking ahead, Rivera has the option to appeal the court's decision to a higher court if he chooses. However, details regarding any related cases or further legal actions were not available in the court filing. The ruling serves as a reminder of the complexities involved in the correctional system and the importance of thorough evaluations when determining the custody status of inmates.