> I need to do more reading on Exceptions, but my case seems more like a 
> flash message than throwing an exception.
>

If you have your own custom exception NotEmptyCategoryException, you can 
throw it from beforeDelete() and catch it in controller:

try {
    $this->Category->delete($id);
} catch (NotEmptyCategoryException $e) {
    $this->Session->setFlash('This category is not empty');
    $this->redirect($this->referer());
}

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