The Puerto Rico Court of Appeals has upheld a lower court's decision regarding the suspension of privileges for 34 inmates at the Sabana Hoyos correctional facility. This ruling, issued on April 14, 2026, is significant as it addresses the legal rights of inmates and the authority of correctional officials to impose restrictions for security reasons.

The case, titled Ángel Burgos Olivera v. Supern: Samuel Arroyo Serrano, D.C.R., was filed under docket number TA2026AP00263. The court's decision confirmed the lower court's ruling that dismissed the inmates' request for an injunction against the suspension of their privileges.

Background

The appellants in this case, led by Ángel Burgos Olivera, are inmates at the Sabana Hoyos correctional facility. They filed a lawsuit against the Superintendent of the facility, Samuel Arroyo Serrano, and other officials after their privileges were suspended following security incidents. The inmates claimed that the suspension of privileges violated their rights and sought a court order to lift the restrictions.

The dispute arose after a series of security operations within the correctional facility. The Superintendent notified the inmates on November 18, 2025, that their privileges—such as recreation, food packages, and visitation—would be suspended due to the discovery of illegal contraband during a security operation. The suspension was initially set for 30 days but was extended after further incidents were reported.

On February 6, 2026, the lower court dismissed the inmates' request for an injunction, stating that it lacked jurisdiction over the matter. The inmates appealed this decision, arguing that their due process rights were violated and that the lower court should have addressed the merits of their case.

The Ruling

The Puerto Rico Court of Appeals, led by Judge Brignoni Mártir, along with Judges Salgado Schwarz and Aldebol Mora, reviewed the case and upheld the lower court's ruling. The court confirmed that the lower court correctly concluded it lacked jurisdiction to intervene in the matter due to the doctrine of exhaustion of administrative remedies.

The court ruled, "the forum a quo acted correctly in dismissing the Demand of epígrafe," emphasizing that the suspension of privileges was a security measure and not a disciplinary action.

The court noted that the inmates had not exhausted the administrative procedures available to them before seeking judicial intervention. The ruling highlighted that the measures taken by the Superintendent were within the scope of his authority and did not require a judicial review at this stage.

Impact

This ruling has significant implications for the rights of inmates in Puerto Rico. By confirming the Superintendent's authority to suspend privileges as a security measure, the court reinforced the discretion of correctional officials to maintain order within institutions. The decision may deter other inmates from pursuing similar legal actions without first exhausting administrative remedies.

Moreover, the ruling emphasizes the importance of following established procedures before seeking judicial intervention. It clarifies that inmates must utilize the administrative processes available to them, which are designed to address grievances before escalating to the courts.

What's Next

The inmates may consider further legal options, including potential appeals to higher courts, although details were not available in the court filing regarding any future actions. The case highlights ongoing discussions about inmates' rights and the balance between security measures and due process.