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

Go back to reading ;-) because it is easier to throw 2 different custom 
exceptions NotEmptyCategoryException (has some products) and 
NotLeafCategoryException (has some subcategories) from beforeDelete() and 
then either react differently for them or (in controller):

try {
...
} catch (CakeException $e) {
   $this->Session->setFlash($e->getMessage());
}

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