Sanchez Roa, Jose Abner v. Junta De Libertad Bajo Palabra
KLRA202500054
Tribunal De Apelaciones De Pue...Mar 25, 2025Background
- José Abner Sánchez Roa is an inmate serving a lengthy sentence at the Guerrero Correctional Institution, set to expire in 2060.
- In 2020, the Board of Parole (Junta de Libertad Bajo Palabra) began reviewing whether Sánchez Roa should be granted parole.
- The Board denied parole, citing the lack of a viable residence plan, no employment offer, and conflicting mental health evaluations (one recommending ongoing psychological treatment, another stating none is needed).
- Sánchez Roa filed a motion for reconsideration, arguing the decision was arbitrary and violated his right to rehabilitation.
- After the Board maintained its position, Sánchez Roa appealed to the Court of Appeals, which reviews administrative decisions for reasonableness and adherence to statutory criteria.
- The Court affirmed the Board’s decision after reviewing the administrative record and applicable law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Board's denial of parole was arbitrary or capricious | Sánchez Roa: The Board’s denial was arbitrary, violated due process and his right to rehabilitation | Junta: Decision based on statutory criteria—lack of viable residence, employment, and mental health concerns; acted reasonably | The denial was not arbitrary/capricious; Board acted within discretion |
| Whether the Board violated rehabilitation rights | Denial impedes his reintegration and rehabilitation opportunities | Board evaluated all required factors, including mental health and reintegration prospects | No violation occurred; Board followed statutory mandate |
| Weight of conflicting evidence in mental health evaluations | Positive institutional record outweighs need for further psychological treatment | Board must consider all evidence, including recommendations for mental health treatment | Board’s evaluation reasonable; decision supported by substantial evidence |
| Presumption of correctness of administrative decisions | Board’s decision lacked adequate basis, should not be presumed correct | Decisions enjoy presumption of correctness unless evidence shows otherwise | Presumption sustained; no contrary evidence offered |
Key Cases Cited
- Asoc. Condómines v. Meadows Dev., 190 DPR 843 (Puerto Rico 2014) (establishing appellate review standards for administrative decisions)
- Pérez López v. Dpto. Corrección, 208 DPR 656 (Puerto Rico 2022) (reiterating that administrative agency findings are presumed correct)
- Maldonado Elías v. González Rivera, 118 DPR 260 (Puerto Rico 1987) (outlining scope and intent of parole as an aid to rehabilitation, not a right)
- Pueblo v. Negrón Caldero, 157 DPR 413 (Puerto Rico 2002) (confirming parole as a privilege, not a right, and that revocation is subject to administrative discretion)