Quiñones Santiago, Luis Hiram v. D De Correccion Y Rehabilitacion
KLRA202500027
| Tribunal De Apelaciones De Pue... | Mar 31, 2025Background
- Luis H. Quiñones Santiago, an inmate in Puerto Rico, filed an administrative remedy request with the Department of Correction and Rehabilitation (DCR) seeking access to his criminal and social files held by the institution.
- Quiñones claimed he had repeatedly asked the appropriate staff (social and record technicians) for access, but was denied, contrary to DCR procedures.
- The initial administrative response from DCR’s command area incorrectly informed Quiñones he needed to request his file through the court.
- Quiñones sought reconsideration, arguing DCR regulations allow inmates access to their files via internal procedures, not court petitions.
- The DCR’s reconsidered response still denied him access, requiring him to specify which documents he sought and again referring him to process through social services, but did not directly provide access.
- Quiñones appealed the administrative denial to the Puerto Rico Court of Appeals, which reviewed whether DCR followed its own rules regarding inmate access to information.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Response by improper official | Quiñones: Only social or record staff, not the command area, should address such requests per DCR Manual | DCR: The error was corrected when the social area eventually participated | Court: No reversible error; later correction addressed this |
| Requirement to go to court for access | Quiñones: DCR Manual establishes internal procedure, does not require petition to judicial forum | DCR: Inmate must go to court, especially for certain documents | Court: Error; DCR Manual provides for direct inmate access via social/record staff |
| Denial for lack of document specification | Quiñones: Manual does not require specifying documents before access; access should be given first | DCR: Inmates must specify which documents are needed | Court: Error; DCR must allow access without prior specification; only specific requests for copies require identification |
| Inmate right of access to files | Quiñones: Rule grants access to criminal and social files via technical staff | DCR: Inmate can only review via sociopenal technician and not directly; social file is confidential | Court: Inmate has right to access criminal file via sociopenal tech; DCR erred in blocking access |
Key Cases Cited
- Otero Rivera v. Bella Retail Group, Inc., 2024 TSPR 70 (PR Supreme Court case affirming deference to agency decisions unless unreasonable or contrary to law)
- Hernández Feliciano v. Mun. Quebradillas, 211 DPR 99 (reiterates standard for judicial review of administrative action)
- Rolón Martínez v. Supte. Policía, 201 DPR 26 (clarifies when judicial intervention in agency fact-finding is warranted)
- Torres Rivera v. Policía de PR, 196 DPR 606 (summarizes deferential standard for agency decisions and limits to that deference)