Poblacion Correccional v. D De Correccion Y Rehabilitacion, KLAN202400795

Inmates at Bayamón Correctional Institution challenged a temporary suspension of privileges, imposed under Rule 9 of Regulation No. 9221, claiming constitutional violations and lack of due process.
Plaintiffs filed a motion for a preliminary injunction in the Bayamón Superior Court, seeking immediate judicial relief rather than first pursuing available administrative remedies.
The trial court (Tribunal de Primera Instancia, TPI) dismissed the complaint for lack of jurisdiction, finding the plaintiffs had not exhausted mandatory administrative remedies before the Department of Correction and Rehabilitation (DCR).
Plaintiffs moved for reconsideration, arguing exceptions to exhaustion applied because irreparable harm would result, the agency lacked authority to award damages, and the agency’s notification was defective.
The TPI denied reconsideration, and plaintiffs appealed, reasserting their arguments for bypassing administrative remedies and seeking direct judicial intervention.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must administrative remedies be exhausted before seeking judicial relief for suspension of privileges?	Exhaustion should be excused due to irreparable harm, futility, constitutional violations, and agency’s incapacity to grant damages.	Plaintiffs failed to exhaust the required administrative process, precluding judicial review.	Yes; exhaustion required unless strictly qualifying for exceptions.
Can the failure to notify of administrative remedies excuse exhaustion?	Procedural defects in agency notification violated due process and justify skipping exhaustion.	Administrative remedies were available and not pursued, regardless of notification adequacy.	No; the court rejected the argument, finding procedures existed.
Can damages be sought directly in court if agency cannot award them?	Since DCR can’t award damages, case should proceed directly in court.	Action was originally for injunctive relief, not damages, and administrative process was not followed.	No; because damages claim was not pled in initial complaint, issue not reviewable on appeal.
Is the appeal moot if privileges suspension has expired?	Not specifically argued.	No longer a live controversy; order would have no practical effect.	Yes; with remedy period ended, the case is now academic.

Colón Rivera v. ELA, 189 D.P.R. 1033 (P.R. 2013) (explains exhaustion of administrative remedies doctrine and its justifications)
Procuradora Paciente v. MCS, 163 D.P.R. 21 (P.R. 2004) (sets out exceptions to exhaustion where administrative remedies are inadequate or constitutional rights are implicated)
AAA v. UIA, 200 D.P.R. 903 (P.R. 2018) (discusses agency expertise and need for exhaustion)
Muñoz Barrientos v. ELA, 212 D.P.R. 714 (P.R. 2023) (details agency jurisdiction and claims for damages in the context of exhaustion)
Román Ortiz v. OGPe, 203 D.P.R. 947 (P.R. 2020) (due process in administrative proceedings)
Amador Roberts v. ELA, 191 D.P.R. 268 (P.R. 2014) (definition and application of academicity/mootness)