Judge Bélabre, serving at the Court of First Instance in Port-au-Prince, has come under scrutiny by the CSPJ following a complaint filed against him on January 7, 2025, regarding a case of sexual assault against a minor that he was handling. During a statutory meeting of CSPJ councilors held on Thursday, January 16, it was decided to place Judge Bélabre on leave for a three-month period while awaiting "his appearance before the disciplinary tribunal, which will make a final decision on his case."

Judge Bélabre is under investigation for his decision to release René Toussaint, the director of the Training and Research Institution in Delmas 60, who had been imprisoned for the sexual assault of a minor—a 14-year-old student who became pregnant by Toussaint. Toussaint was released in December following a ruling by Judge Bélabre.