Navas Cordero, Hector F v. Administracion De Correccion, KLRA202300218

Background

Héctor F. Navas Cordero was sentenced in 2018 to a total of 119 years (including two first‑degree murder convictions and weapons offenses) and was initially classified to maximum custody.
The Manual required inmates with sentences of 99 years or more, initially classified to maximum custody, to remain in that custody for five years and then be re‑evaluated.
The CCT evaluated Navas Cordero on 21‑Oct‑2022 (12 points) and again on 26‑Apr‑2023 (3 points) but ratified maximum custody both times, citing factors beyond the numerical score.
The committee relied on: extreme violence in the underlying offenses, lack of demonstrated remorse or introspection, a disciplinary “administrative positive” for refusing a drug test, and the inmate’s pending need for addiction therapy (on a waiting list).
Navas filed an administrative remedy requesting addiction treatment and then sought judicial review asking the Tribunal de Apelaciones to overturn the DCR’s ratification and order a re‑evaluation.
The Tribunal de Apelaciones reviewed the DCR determination under the deferential administrative‑review standard and confirmed the agency’s ratification of maximum custody.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the DCR’s ratification of maximum custody lacked substantial evidence	Navas argued the Committee should have reduced custody or re‑evaluated because he completed some programs and awaited addiction therapy; he sought reevaluation	DCR argued the Committee properly applied Manual 9151, considered institutional record, violent offenses, disciplinary history, and validly exercised discretionary upward modification despite low score	Held: Affirmed — court found agency decision supported by record and within discretion; plaintiff failed to overcome presumption of administrative regularity
Whether the agency misapplied rules (5‑year rule / program access) so as to make the decision illegal or unreasonable	Navas contended lack of timely access to addiction therapy undermined fairness of custody assessment	DCR noted the inmate was on a waiting list, cited sentence severity and institutional conduct, and invoked discretionary factors in Manual 9151	Held: Affirmed — tribunal deferred to agency expertise; no legal error shown in applying the Manual or using discretion
Whether the administrative process violated procedural or constitutional standards (e.g., arbitrary action)	Navas sought reversal but did not identify specific legal or constitutional errors in the agency’s application	DCR maintained process complied with applicable regulations and evaluation procedures	Held: Affirmed — no arbitrary, illegal, or unreasonable action shown that would justify judicial intervention

Key Cases Cited

Torres Rivera v. Policía de Puerto Rico, 196 D.P.R. 606 (establishes judicial standard for deference to administrative determinations)
Rolón Martínez v. Superintendente de la Policía, 201 D.P.R. 26 (discusses scope of judicial review under the LPAU and deference to agencies)
Pérez López v. Departamento de Corrección, 208 D.P.R. 656 (addresses administrative remedies and the DCR’s remedial process for inmates)
Super Asphalt v. AFI y otros, 206 D.P.R. 803 (reiterates reasonableness standard and deference to administrative expertise)
Cruz v. Administración, 164 D.P.R. 341 (on balancing public interest in rehabilitation against safety in custody classification)