Feliciano v. Rullan

This interlocutory appeal requires us to revisit a marathon class-action suit brought to remedy unconstitutional conditions of confinement in the Puerto Rico prison system. On this occasion, the Secretary of the Puerto Rico Department of Health (the Secretary) alleges that the district court's assignment of certain duties to the so-called chief health care coordinator (the CHCC) constitutes an unwarranted modification of a prior injunction and, in the bargain, violates the Prisoner Litigation Reform Act of 1995 (PLRA), Pub. L. No. 104-134, 110 Stat. 1321 (1996) (codified as amended in scattered sections of 18 U.S.C., 28 U.S.C., & 42 U.S.C.). The plaintiff class (composed of prison inmates) responds that this court lacks jurisdiction to consider the appeal on an interlocutory basis, and that, in all events, the challenged order is a proper exercise of the district court's authority. We agree with the first of the plaintiffs' assertions: the challenged order merely clarifies the court's prior decrees and imposes no serious consequences on the Secretary. Moreover, the order, in the last analysis, is a procedural measure that constitutes an exercise of the district court's housekeeping powers. For these reasons, immediate appellate review is not available to the Secretary as of right. Consequently, we dismiss the appeal without addressing the remaining issues briefed and argued by the parties. I. BACKGROUND