Pa. Commonwealth Court panel reverses trial court ruling dismissing inmate's $71.47 claim as 'frivolous'

By Jon Campisi | Jun 5, 2013

A trial court judge from southwestern Pennsylvania may have felt a prison inmate’s

complaint seeking $71.47 in damages arising from alleged property damage during a contraband search was frivolous, but a state appeals court holds otherwise.

A seven-judge panel of Pennsylvania’s Commonwealth Court on May 23 reversed and remanded a case brought against the state Department of Corrections by Kevin Williams, who also goes by Kirby Stewart, an inmate at the State Correctional Institution-Somerset who claimed corrections officers damaged his footlocker during a search of his cell in the fall of 2009.

Williams initially filed a grievance with the prison, but it was denied without jail staff ever having visited his cell or examining the footlocker, the inmate claimed in his suit, which he had filed in early August 2011.

A judge sitting on the Somerset County Court of Common Pleas ultimately dismissed the claim, deeming the litigation to be frivolous, since the damages sought, $71.47, were less than the $75 fee to file the lawsuit, according to the Commonwealth Court opinion.

The trial court dismissed the suit pursuant to a section of the federal Prison Litigation Reform Act that allows a judge to toss a complaint if the litigation is deemed “frivolous or malicious.”

The act provides indigent prisoners with an opportunity to file lawsuits contesting prison conditions.

“Because Williams sought less compensation than the filing fee … and had no additional meaningful nonmonetary interest, the trial court found that a reasonable paying litigant would not have filed the same claim and dismissed the complaint as frivolous,” the appeals panel wrote.

In his complaint, Williams sought either a footlocker to replace the damage one, or the cost of a comparable footlocker.

While the Commonwealth Court panel acknowledged the trial court properly relied on case law and Third Circuit Court of Appeals precedence in coming to its decision to terminate the litigation, the appeals judges nonetheless reversed the trial court’s ruling.

The reason – “unlike the federal statute, which does not define the term ‘frivolous,’ our Act defines the term as ‘[l]acking an arguable basis either in law or in fact.’”

“We believe this to be a critical difference,” the appellate court opinion states. “Our courts simply to not have the flexibility to adopt the expansive definition adopted by our federal counterparts.”

In Williams’ case, the panel determined that while the inmate’s footlocker was not of great value, “neither was it trivial.”

“We do not interpret the Act as requiring our courts to waste time on nonsense, such as a suit to recover the value of a lost pack of gum,” the ruling states. “Therefore, we do not rule out the possibility that a suit seeking monetary compensation so trifling as to render the claim devoid of genuine merit, or to give rise to an inference that it is brought simply for purposes of harassment, may well be deemed frivolous under our Act.”

The judges went on to write that “to measure frivolousness by measuring the amount in controversy against the cost of the filing fee in the court of common pleas would be in derogation of the definition of the term under our Act.”

The Third Circuit case referenced by the trial court was Deutsch v. United States, which noted that the federal Prison Litigation Reform Act never defines the term “frivolous.

At the time of the act’s passage, the opinion notes, Congress had been concerned about the potential for the courts to be overwhelmed by abusive claims.

In the Williams case, the Commonwealth Court decided to reject the Deutsch paradigm simply because of the fact that the term “frivolous” is more clearly defined in Pennsylvania’s statute.

The panel sent the case back to the Somerset County Court of Common Pleas for further proceedings.

The opinion was penned by Commonwealth Court Judge Bonnie Brigance Leadbetter.

The other participating jurists were President Judge Dan Pellegrini, along with Judges Bernard McGinley, Renee Cohn Jubelirer, Robert Simpson, Mary Hannah Leavitt and P. Kevin Brobson.

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